CLOSING SUBMISSIONS on the behalf of the Around Newport, Newport Public Local Inquiry Note: this is the revised version of the Closing Submissions which addresses the typographical errors that were noted during the delivery of the speech on 28 March 2018

PINS reference number: APP/E6840/V/17/3166811 Called-in Listed Building Application for Woodland House reference number: DC/2016/01033 Highways Schemes

The (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The (Junction 23 (East Of Magor) Connecting Road) Scheme 201-

The London To Fishguard Trunk Road (East Of Magor To Castleton) Order 201-

The M4 Motorway (West Of Magor To East Of Castleton) And The A48(M) Motorway (West Of Castleton To St Mellons) (Variation Of Various Schemes) Scheme 201-

The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) (Supplementary) Scheme 201-

The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) (Amendment) Scheme 201-

The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) (Supplementary) (No.2) Scheme 201-

The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Amendment) (No. 2) Scheme 201- The Side Roads Orders

The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) And The London To Fishguard Trunk Road (East Of Magor To Castleton) (Side Roads) Order 201-

The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) And The London To Fishguard Trunk Road (East Of Magor To Castleton) (Supplementary) (Side Roads) Order 201-

C:5493805v1

The Compulsory Purchase Orders

The Welsh Ministers (The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) And The London To Fishguard Trunk Road (East Of Magor To Castleton)) Compulsory Purchase Order 201-

The Welsh Ministers (The M4 Motorway (Junction 23 (East Of Magor) To West Of Junction 29 (Castleton) And Connecting Roads) And The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) And The London To Fishguard Trunk Road (East Of Magor To Castleton)) Supplementary Compulsory Purchase Order 201-

The Welsh Ministers (the M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard trunk road (East of Magor to Castleton)) Supplementary (no. 2) Compulsory Purchase Order 201-

The Welsh Ministers (the M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and connecting roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard trunk road (East of Magor to Castleton)) Supplementary (no. 3) Compulsory Purchase Rrder 201-

The Welsh Ministers (the M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard trunk road (East of Magor to Castleton)) Supplementary (no. 4) Compulsory Purchase Order 201-

C:5493805v1

M4 CaN

______

CLOSING SUBMISSIONS on behalf of the WELSH GOVERNMENT

______

INTRODUCTION

1. The M4 is a route of strategic importance. It is critical to the Welsh

economy and society, linking two thirds of the Welsh nation to ’

largest trading partner. It connects the capital city of the Welsh nation with

the capital city of the UK and takes travellers to and from the Valleys and

West Wales, for business, social, cultural and tourist purposes. The M4

directly serves institutions which are central to defining the nation’s identity

and developing its future – its devolved Assembly, leading universities,

hospitals and colleges, concert halls, Bay City Region,

Capital City Region, National Botanic Gardens and its sports stadia

including Principality Stadium, home of the , a

supporter of the Scheme. The proper functioning of this road is

C:5493828v1

fundamental to the well-being of the nation – economically, socially,

culturally.

2. But there is a huge problem. The existing M4 between Magor and

Castleton does not meet modern motorway design standards and a greater

volume of traffic uses the motorway than that for which it was originally

designed. Around 100,000 vehicles per day use the M4 and the transport

related problems are only getting worse, with population and traffic levels

continuing to grow in Wales. Congestion, with frequent incidents, is a daily

occurrence. These characteristics bring adverse economic and

environmental impacts. Really serious hold-ups are a fact of life. When they

occur, this critically important corridor grinds to a halt, with traffic chaos

spilling out into Newport and surrounding areas.

3. The Scheme is proposed because of the manifest inadequacies of this

stretch of the M4. It is WG’s case that the evidence heard at this Inquiry

proves that there is a pressing problem demanding a solution, that the only

practical solution is one which involves an increase in road capacity and

that the Scheme is preferable to the various alternatives which have been

advanced. Furthermore, with the removal of the tolls, the

economic and traffic case for the Scheme is strengthened.

4. The engineering of the Scheme comprises the following principal

components:

- A new section of dual three-lane motorway to the South of Newport

connecting to the existing route at junctions 23 and 29. The 23 kilometre

route of three-lane motorway would pass south of Newport, crossing the

Gwent Levels, Estuary, , close to the

C:5493828v1 2

Llanwern Steelworks site and the Docks Way landfill site. To cross the

River Usk, the motorway would be raised on approach viaducts and a

cable stayed bridge.

- Re-classification of the existing M4 around the north of Newport

between junctions 23 and 29 as a trunk road, with changes to lane

configurations. The existing A48(M) between junction 29 and St.

Mellons in Cardiff would also be reclassified. The road between

Junction 24 (Coldra) and Junction 23 (Magor) would become a two-lane

dual carriageway.

- A new B4245/M48/M4 connection at Junction 23 which would reduce

traffic through Magor and improve accessibility, including to the Severn

Tunnel Junction railway station.

- A new interchange junction at Castleton would connect the proposed

new motorway to the existing M4 between Newport and Cardiff and to

the reclassified A48(M).

- Intermediate junctions at and Docks Way would connect into

existing roads at the A4810 and A48, serving Newport and its

development sites, and Newport Docks

- Re-opening of the west facing slip roads of Junction 25 (),

improving access to Caerleon and the St. Julians areas of Newport.

5. Opponents of the Scheme have generally been reluctant to acknowledge

the environmental benefits which it would bring, notably in terms of

improved air quality and noise conditions for the thousands of people who

live close to the current, overloaded M4.

C:5493828v1 3

6. By contrast, WG’s professional team has been open about the

environmental impacts of the proposals throughout the Environmental

Impact Assessment (“EIA”) and Statement to inform Appropriate

Assessment (“SIAA”) processes and in its evidence to the inquiry, including

the Ecosystems Services Appraisal (“ESA”). Effects have been assessed

throughout on a precautionary basis.

7. Following the failed challenge to the strategic Plan for a solution to the

problems, mounted on SSSI and other environmental grounds1, great

attention has been paid, as the Scheme has been developed, to its design

and to the mitigation of adverse environmental effects, reflecting the

acknowledged sensitivity of much of the proposed route. Ecological

mitigation measures would, given time, contribute positively to the

environment and to biodiversity, in particular, by means of three SSSI

mitigation areas and management of Coed Mawr woodland as dormouse

habitat (part of a comprehensive package of measures for this species).

Continuity of the Levels’ characteristic network of reens and ditches and

quality of the water going into them from the road have been addressed in

minute detail by a multi-disciplinary team of environmental and construction

engineers in consultation with WG’s ecologists and NRW. Rather than

simply demolishing the G2 listed Woodland House (known locally as

‘Magor Vicarage’), WG has worked, in collaboration with

County Council (“MCC”), to identify a new site to which it is committed to

moving the building, should MCC grant the necessary consents; other

heritage features also have their own bespoke mitigation measures.

1 Alleged failure to carry out Strategic Environmental Assessment properly and alleged failure to comply with statutory duties in relation to SSSIs. Breach of the Government’s duties in relation to carbon reduction (the latter ground was withdrawn): CD. 4.5.45

C:5493828v1 4

Contrary, perhaps, to popular impressions, the Scheme would, in time, be

carbon neutral as a result of user emissions reductions on the shorter route

offsetting construction emissions.

8. Many of those who presented evidence to the inquiry have objected to the

idea of the Scheme without doing justice to its detail; there have been

suggestions that the proposals, as a matter of principle and law, are

inconsistent with environmental legislation. Those contentions are wrong,

as we shall demonstrate. The time for challenging the idea of the Plan for

this road is past; the judicial review tested the Plan on a number of alleged

environmental grounds and it was roundly dismissed. The Ministerial

decision must now be made on the basis of the Scheme as it has actually

been developed and designed. It is, in truth, a very special Scheme,

imbued with Future Generations principles. It is an exemplar in the sense

that where a new road or motorway is necessary and justified, it should be

designed to the same high standards as the published Scheme. It offers

the chance to solve serious problems facing Wales now whilst preserving

the essential integrity of the areas through which it would pass for handing

on to future generations.

THE SCHEMES, ORDERS and LISTED BUILDING APPLICATION

9. A comprehensive list of the Schemes and Orders is set out in the section

below, together with their dates of publication and the statutory powers

relied on for each.

C:5493828v1 5

10. In addition to draft Schemes and Orders, there is also an application for

Listed Building Consent (“LBC”) which has been called in for the Welsh

Ministers’ determination.

11. The various Schemes and Orders have generated representations of

support and objection. At the end of the inquiry, the global tally stands at

216 supporters and 319 unique objectors (i.e. those who have submitted

individual objections with 6189 being the total objections including

campaigns).

12. Many of these people have chosen to leave their representations in writing

only. Others have appeared at the inquiry.

13. Annex 1 appended to these Submissions lists each unique objection and

charts where, in Welsh Government’s (“WG”) evidence, the objections have

been specifically addressed. Inevitably, there is a fair degree of overlap

and repetition of points of objection, not least because thousands (4859) of

objections are in a standard form from an RSPB campaign. These

Submissions will deal with the main points of support and objection in the

context of the network of statutory provisions which govern the decision-

making process.

STATUTORY POWERS and TESTS

14. We referred in the last paragraph to a “network” of statutory provisions and

the statutory context here is undoubtedly complex.

15. To help simplify matters, we shall present the statutory material and

supporting analysis in the following way:

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(1) Identify the Scheme / Order making/confirming powers under the

Highways Act 1980 (“HA 1980”)

(2) Set out and address the statutory requirements which must be met

to support confirmation of the HA 1980 Schemes / Orders

(3) Set out the statutory framework for determination of the LBC

application and analyse the evidence in relation to it

(4) Identify and analyse the relevant overarching environmental and

other legal duties informing the process of determination.

Draft Highway Schemes and Orders

16. There are six Schemes and one Order which will, if confirmed, become

Statutory Instruments pursuant to section 325 HA 1980. These are:

a) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor)) Connecting Road) Scheme 201-.

This is the main Scheme for the M4CaN which will be a

special road. It was published on 10 March 2016, together

with the Environmental Statement (“ES”). The period for

making representations closed on 4 May 2016. The powers

relied on were sections 16, 17, 19 and 106 HA 1980. The

procedural requirements of Schedule 1 to the Act apply and,

s. 105A imposes a requirement to carry out environmental

assessment not later than the date of publication. Section

105A and 105B require the WG to undertake an

C:5493828v1 7

environmental assessment (“EIA”) of the project, publish

notice of it and make the ES available to the public.

b) The London to Fishguard Trunk Road (East of Magor to Castleton) Order 201-

This directs that the new road, slip roads and certain lengths

of existing highway shall become trunk roads, with provision

being directed as to their maintenance. The Order was

published on 10 March 2016 together with the ES. The

period for making representations closed on 4 May 2016 It

was made under sections 10 and 41 HA 1980. The

procedural requirements of Schedule 1 to the Act and

sections 105A and 105B (EIA) apply.

c) The M4 Motorway (West of Magor to East of Castleton) and the A48(M) Motorway (West of Castleton to St Mellons) (Variation of Various Schemes) Scheme 201-.

This varies the original M4 Scheme taking the relevant

stretch of the existing M4 out of the special road category

and making it into a Trunk road. The Variation was published

on 10 March 2016, together with the ES. The period for

making representations closed on 4 May 2016. The powers

relied on were sections 16, 17, 19 and 326 HA 1980. The

procedural requirements of Schedule 1 and sections 105A

and B of the Act (EIA) apply.

d) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Supplementary) Scheme 201-

C:5493828v1 8

This provides for temporary restrictions on navigation in the

Rivers Ebbw and Usk during construction of the bridges. The

Supplementary Scheme was published on 5 September

2016, together with an Environmental Statement Supplement

(“ESS 1”) and the period for making representations closed

on 17 October 2016. The powers relied on were sections 16,

17, 19 and 106 HA 1980. The procedural requirements of

Schedule 1 to the Act and sections 105A and 105B (EIA)

apply.

e) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Amendment) Scheme 201-

This provides for raising of the proposed bridge, as explained

below. The Amendment Scheme was published on 14

December 2016, together with an Environmental Statement

Supplement (“ESS 2”). The period for making

representations closed on 31 January 2017. The powers

relied on were sections 16, 17, 19 and 106 HA 1980. The

procedural requirements of Schedule 1 to the Act and

sections 105A and 105B (EIA) apply.

f) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Supplementary) (No.2) Scheme 201-

This makes provision for the provision of an eastbound off

slip at Magor to connect with the A4810 at a roundabout with

the B4245 which leads to Junction 23A at . It

C:5493828v1 9

also amends the Supplementary Scheme Order published on

5 September 2016 so as to include a reference to Newport

Docks as navigable waters. The scheme was published on

21 March 2017 together with an Environmental Statement

Supplement (“ESS 3”). The period for making

representations closed on 10 May 2017. The powers relied

on were sections 16, 17, 19 and 106 HA 1980. The

procedural requirements of Schedule 1 and sections 105A

and 105B (EIA) apply.

g) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Amendment) (No. 2) Scheme 201-

This amends all the draft schemes above to provide for the

carrying out of a narrowing of the navigable waterway known

as Junction Cut within Newport Docks to 11m as part of a

Special Road. This scheme was published on 15 August

2017 together with an Environmental Statement Supplement

(“ESS 5”). The period for making representations closed on

26 September 2017. The powers relied on were sections 16,

17, 19 and 106 HA 1980. The procedural requirements of

Schedule 1 and sections 105A and 105B (EIA) apply.

17. There are also two draft Side Roads Orders:

a) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and The London to Fishguard Trunk

C:5493828v1 10

Road (East of Magor to Castleton) (Side Roads) Order 201- 2

b) The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton) (Supplementary) (Side Roads) Order 201-

18. The first of these Orders makes provision carrying out for improvements of

highways; to stop up highways or areas of highways; to construct new

highways; to stop up private means of access to premises; to provide new

means of access to premises; and to construct temporary lengths of

highways. It was published, together with the ES, on 10 March 2016.

19. The second provides for the stopping up of private means of access to

premises, and makes provision for new means of access to premises within

Newport Docks. It was published, together with a Supplemental

Environmental Statement (“ESS 4”) on 20 April 2017.

20. The periods for making representations closed on 4 May 2016 and 1 June

2017 respectively. The initial Side Roads Order was made under sections

12, 14, 18, 125 and 268 HA 1980. The Supplementary Side Roads Order

was made under sections 18 and 125 HA 1980. The procedural provisions

set out in Schedule 1 to the Act apply.

21. The basic power for making the draft Schemes is s.16(3) Highways Act

1980 (“HA 1980”), which provides as follows:

"A highway authority may be authorised by means of a scheme under this section to provide, along a route prescribed by the scheme, a special road for the use of traffic of any class prescribed thereby.”

2 Mod19 which modifies the SRO (of which two revisions were prepared) is explained in PIQ122. The PIQ confirms that NCC did not object to the proposal.

C:5493828v1 11

22. The Welsh Ministers are the relevant highway authority.3

23. The supplementary powers invoked in sections 17, 19 and 41 HA 1980

deal with the classification of vehicles that will be permitted to use the new

road and achieve trunk road status for the new road. There are no

procedural requirements associated with the use of these powers which

are, essentially, ancillary to s.16 and follow from the making of the Scheme.

24. S.106 HA 1980, which was relied on for the making of Schemes and

Orders a) d) e) f) and g), provides as follows (so far as relevant):

S.106(1) – “Provision may be made by an order made by the Minister

under this subsection or under section 10 above (orders for trunk

roads) for the construction of a bridge over or a tunnel under any

specified navigable waters as part of a trunk road”.

S.106(4) – “Provision may be made by an order under section 14

above (roads that cross or join trunk or classified roads) or section 18

above (supplementary orders relating to special roads) – (a) for the

construction of a bridge over or tunnel under specified navigable

waters as part of a highway which is to be altered or constructed in

pursuance of the order); (b) where the order authorises the highway

authority by whom it is made to provide a new means of access to any

premises from a highway, for the access to be provided by means of a

bridge over specified navigable waters and for the construction of the

bridge”.

S.106(5) – “Parts I and III of Schedule 1 to this Act have effect as to the

making of an order under subsection (1) above, Parts II and III of that

3 Though the convention throughout the inquiry has been to refer to the scheme – proposing arm as “Welsh Government” and the Scheme-confirming arm as “Welsh Ministers”.

C:5493828v1 12

Schedule have effect as to the making of a scheme under subsection

(3) above and Schedule 2 to this Act has effect as to the validity and

date of operation of any such order or scheme”.

S.106(7) – “References in this section, in relation to any order or

scheme, to specified navigable waters are references to such

navigable waters (whether the sea, a river or other waters) as may be

specific in the order or scheme”.

25. S. 107 HA 1980 provides as follows:

(1) Before making or confirming an order or scheme which provides for

the construction of a bridge over or a tunnel under navigable waters,

the Minister shall take into consideration the reasonable requirements

of navigation over the waters affected by the order or scheme.

(2) an order or scheme which provides for the construction of such a

bridge shall include such plans and specifications as may be necessary

to indicate the position and dimensions of the proposed bridge

including its spans, headways and waterways, and in the case of a

swing bridge shall contain such provisions as the Minister considers

expedient for regulating its operation.

(3) an order or scheme which provides for the construction of such a

tunnel shall include such plans and specifications as may be necessary

to indicate the position and dimensions of the proposed tunnel,

including its depth below the bed of the navigable waters.

(4) if objection to an order or scheme proposed to be made or, as the

case may be, to an order of scheme made and proposed to be

confirmed, is duly made in accordance with Schedule 1 to this Act by

C:5493828v1 13

the Environment Agency, the Natural Resources Body for Wales or any

navigation authority on whom notice is required to be served under

paragraph 3 or, as the case may be, paragraph 11 of that Schedule, on

the ground that the bridge or tunnel is likely to obstruct or impede the

performance of their functions under any enactment, or to interfere with

the reasonable requirements of navigation over the waters affected by

the order or scheme, as the case may be, and the objection is not

withdrawn, the order or scheme, as the case may be, shall be subject

to special parliamentary procedure.

26. S.326 HA 1980 grants the power of variation which is being exercised in

relation to the existing M4. By s.326(2), this power may be exercised in the

same way and subject to the same provisions as for making a scheme.

27. Schedule I to HA 1980 lays down procedural requirements in respect of the

making and confirmation of schemes under sections 16 and 106 and orders

under sections 10, 14 and 18. Decisions under sections 14, 16, 18 and 125

involve the determination of civil rights within the meaning of Art.6 to the

European Convention for the Protection of Human Rights and

Fundamental Freedoms (“the Convention”); the procedural protections

afforded by Schedules 1 and 2 to the Highways Act ensure compatibility

with the Convention4. These procedural provisions have been followed in

relation to public notice and the holding of the inquiry5. Human Rights are

dealt with in greater detail later in the closing statement.

28. Schedule 1 paragraphs 8 and 15 provide for the Minister to confirm

scheme/s and order/s with or without modification. Where s/he proposes to

4 R(Alconbury Developments) v. Secretary of State for the Environment, Transport and the Regions [2001]WLR 1389 5 WG 1.1.1: Matthew Jones Proof, para. 6.20

C:5493828v1 14

confirm schemes or orders subject to modifications, and the modifications

will, in his/her opinion, make a substantial change in the scheme or orders,

s/he must notify anyone who appears to him/her likely to be affected by the

proposed modification/s and give him/her an opportunity to make

representations on them which s/he must then consider.

29. There are many minor Modifications which have been proposed mostly to

mitigate practical difficulties which individuals have brought to WG’s

attention after publication of the Scheme. All such Modifications have been

presented to the Inquiry and are published on the Inquiry website. They are

listed in ID242. Modifications in the minor category have all been the

subject of discussion with relevant landowners and have, in many

instances, led to whole or partial withdrawal of objections. The consultative

process leading to the Modifications in this category has formed an

important part of the work undertaken by WG to ensure that the

interference with individuals’ human rights rendered necessary by the

Scheme is as limited as possible and, hence, proportionate and justifiable

under the Convention and domestic Human Rights legislation.

30. A few Modifications are of wider interest and have also been the subject of

evidence and discussion at the inquiry.

31. Scheme Modification 1 is proposed to the draft Scheme, changing the

layout of the Docks Junction and link road and the designation of Glan Llyn

Link road. Both, instead of being special roads, would be trunk roads and

are therefore removed from the draft Scheme via a modification, and are

added to the Line Order by a modification of that Order. This Modification

was proposed and published on 5th September 2016, before the start of the

C:5493828v1 15

inquiry, was the subject of consultation with statutory and other bodies and

written evidence and discussion at the inquiry. No objections specifically to

Scheme Modification 1 or the Line Order modification have been made,

however general objections to the Scheme and the proposed junction

strategy have been made since the publication of these two modifications.

32. Modification 2 is proposed to the Amendment (No.2) Scheme (item g)

above). It modifies the earlier Scheme by increasing the size of Junction

Cut from 11m to 13.5m. In other words, it reduces the total amount of

narrowing formerly proposed so that the inhibition to shipping would be

less. This revised proposal reflects the work done since September 2017

by WG and ABP to assess and address the risk of large ships colliding with

the proposed motorway bridge, as confirmed orally at the public inquiry by

Andrew Tait QC on behalf of ABP6 and in writing by WG and ABP by

means of ID/239, presented to the inquiry on 21.3.2018, which introduced

the necessary Modifications7. WG’s view is that a width of junction cut of

13.5m does not raise unacceptable safety concerns. In addition, the

powers of ABP, a statutory harbour authority are underpinned by a range of

national legislation which places statutory responsibility on ABP to ensure

navigation safety within harbour limits. As a result, in due course, further

mitigation measures would be implemented by ABP.

33. Associated Modifications are proposed to the Supplementary No.3 and

No.4 CPOs (CPO Modification 77A and 80) and these will be listed below

in the CPO section of these submissions; they were presented to the

Inquiry on the same day as the Modification to the Scheme).

6 On 31 January 2018 7 Submitted 21.3.2018

C:5493828v1 16

Representations were not sought and were not required by the legislation

for the reasons set out in ID/239, namely:

(i) the publication of updated evidence on the part of the Welsh

Government on 20 December 2017, when the possibility of the widening of

the width of junction cut to 13.5m from the original 11m was explained in

some detail;

(ii) on 25 October 2017, the Welsh Government published a supplement to

the Environmental Statement which contained its risk assessment of the

proposed widening of junction cut from the original proposal;

(iii) all port related tenants and occupiers, in addition to the usual statutory

and other consultees were provided with a copy of that evidence;

(iv) the publication of the Supplement to the Environmental Statement was

advertised;

(v) no response has been received and not withdrawn raising the potential

widening of junction cut to 13.5m from 11m as a ground of continuing

objection; and

(vi) the Welsh Government scheme evidence update was read in and

subjected to questions of clarification at the public inquiry over two days on

27 and 28 February 2018.

34. Modifications have also been proposed for the draft Side Roads Order.

SRO Modification 5 amends the layout of the Side Roads proposals for

Bencroft Lane,8 east of Magor. This modification was published on 5

September 2016 and included in the accompanying ESS Supplement 19,

8 Bencroft Lane was also incorporated as part of the supplementary CPO 9 CD 2.4.4

C:5493828v1 17

before the start of the inquiry and sent to statutory and non-statutory

consultees, and has been the subject of written evidence and discussion at

it.

35. SRO Modification 17 amends the side roads proposals around Newport

Road roundabout, west of Magor, to accommodate the eastbound off-slip

proposed in the Supplementary No.2 Scheme Order published on 21

March 2017. SRO Modification 17 was sent to statutory and non-statutory

consultees. This modification was also published on 21 March 2017 with an

accompanying ESS Supplement (No.3)10 and has been the subject of

amended Proofs of Evidence and of discussion at the inquiry.

36. The third, referenced as SRO Modification 18, amends the Order so as to

permit a new means of access into land south of the former

Steelworks to enable vehicles to enter that land for the purpose of

environmental mitigation, the details of which have been the subject of

extensive discussion with NRW and RSPB and are set out in the draft Bird

Protection and Mitigation Plan11. The only persons likely to be affected by

the proposed Modification are (“NCC”) as Highways

Authority for the road from which access would be taken and Tata Steel as

the owner of the land to be served, together with two statutory undertakers,

National Grid Electricity Transmission and Western Power Distribution, and

also SURF Telecom 12 who have overhead lines in the vicinity. All these

parties have been made aware of the proposed Order (and an associated

Modification to the CPO) and have signified in writing that they do not

object. There is therefore no need to publicise the Modification any further).

10 CD 2.5.1 11 PID187a revised 12 SURF Telecom are not a statutory undertaker.

C:5493828v1 18

The effect of including this land as essential mitigation for cranes (and

other wildlife) is described in the Bird Protection and Mitigation Plan which

is environmental information before the Inquiry.

37. As noted above, two further changes to the Scheme were published before

the inquiry. Firstly, a Supplement, making provision for temporary

restrictions over the navigable channels of the Rivers Ebbw and Usk during

construction, was published on 5th September 2016, the objection period

ending on 17th October 2016. Barry Woodman outlined the proposed

method of construction in his proof13 and oral evidence, and this is

described in the Buildability Report. 14

38. Secondly, by an Amendment to the draft Scheme15, published on 14th

December 2016 with an ESS (No.2), the height of the proposed crossing of

the Usk was raised by a minimum of 1.54m. This amendment was made in

response to information received from ABP after publication of the draft

Scheme to the effect that water in the docks is currently maintained at a

height of 7.74m (AOD), which is greater than the design height used by

WG. ABP also informed WG of their intention to provide new outer lock

gates at the entry to South Dock which would, together with associated

changes to the other lock gates, enable ABP to raise the dock water level

to 8.40m (AOD). ABP’s proposals are in response to anticipated climate

change and Paul Canning assesses their robustness in the light of

Government climate change guidance, concluding that the proposed crest

level of 8.41m AOD reasonably accounts for predicted climate change.16

13 WG 1.6.1 pp.78-84 14 Buildability Report, ES Vol.3, Appx 3.1 (Doc 2.3.2) 15 Pursuant to s 16, 17, 19 and 106 HA 1980 16 WG 1.16.1 pp.40-41; see also Jonathan Vine, WG 1.221 Sections 4.1 and 4.2 for navigational implications.

C:5493828v1 19

Taking account of this proposed change and navigational requirements,

WG accordingly published amended bridge proposals on 14th December

2016, the period for objection closing on 31st January 2017. The proposed

Amendment ensures that the Scheme takes proper account of climate

change and the operational requirements of the Docks.

39. Before moving on to address the statutory considerations and tests in

relation to the Schemes and Orders under HA 1980, followed by the

Compulsory Purchase Orders (“CPOs”), it will be convenient to summarise

the position in relation to Newport Docks.

40. ABP objected to the Highway Schemes and Orders and to the CPO, insofar

as they related to its statutory undertaking at Newport Docks. They also

submitted representations under the Acquisition of Land Act 1981 (“ALA

1981”) to the Secretary of State for Transport on the basis of the “serious

detriment” which they claimed would be caused to their undertaking by the

proposed acquisition. Five ABP alternatives (nos. 13 to 17) were proposed.

41. Discussions, which had been in progress before publication of the

Schemes and Orders, continued between WG and ABP for the rest of 2017

into early 2018. These discussions eventually bore fruit, in the form of

agreement to a proposal from WG comprising (in outline):

a) physical changes to and in the vicinity of the Junction Cut to limit the

size of ships able to go through it, whether intentionally or not, with

supplementary further safety measures;

b) physical changes to the docks to provide upgraded berthing facilities

in South Dock to mitigate for the reduction in usability of the North

Dock as a result of the narrowing of Junction Cut;

C:5493828v1 20

c) the construction of a swing bridge at Junction Cut to address

severance issues at the Docks as a result of the Scheme;

d) provision for supplementary mitigation measures to ensure the

continued operation of the Docks (e.g. cranes);

e) provision for ABP and WG to use their best endeavours to relocate

port tenants affected by the Scheme to regenerated Docks land to the

south of South Dock, supported by a Port Relocation Plan setting out,

in principle, how this could be achieved.

42. By their letter of 20 February 2018 to the inspectors, ABP stated: “on the

basis of the agreement reached with the Welsh Ministers, all of the

objections and representations that have been submitted on behalf of ABP

to the Secretary of State under section 16 of the 1981 Act and to the WG in

relation to the Highways and Compulsory Purchase Order insofar as the

proposed scheme impacts upon ABP’s Port of Newport,

were formally withdrawn by a letter dated 2 February 2018”. 17

43. ABP’s Statement to the Inquiry18 states: “Welsh Government initiated

extensive discussions with ABP, concerning principally the impacts of the

M4 proposals on marine safety, port operations and customers of the Port.

This eventually resulted in an offer by WG of a package of measures which

is designed to mitigate the serious detriment that would be caused to the

Port by the M4CaN scheme and which WG has reflected in its further

evidence to the Inquiry in December 2017. The evidence submitted by WG

on 20 December 2017 in relation to the Port, indicated that, “Since the

publication of the original draft Orders, the WG has also held discussions

17 PID/196 18 Op.cit.

C:5493828v1 21

with ABP regarding their operations at Newport Docks and are now

proposing to provide the following works to address the impacts of the

Scheme a) the phased creation of approximately 303m of new quay on the

north side of South Dock, b) Refurbishment of 250m of quay on the south

side of South Dock (at the eastern end of the Coal Terminal), c) provision

of a moveable bridge to facilitate mobile harbour cranes, other port

equipment and HGVs to cross the extended Junction Cut from west to east

(and vice versa) of South Dock with associated new roadway to connect

into existing port roads, d) preparation of areas of land and provision of

premises to facilitate the relocation of ABP, tenants and occupiers of the

port that are affected temporarily and permanently by the scheme,

including site preparation, new buildings, hardstanding and infrastructure”.

44. Agreements were signed to give effect to these arrangements on 2

February 2018. These agreements address the following matters:

a) the provision of various Port mitigation measures detailed in a

Settlement Agreement.

b) a Deed of Indemnity and Insurance from WG to ABP, recognising

that the construction, operation, maintenance and use of the motorway

and the bridge through Newport Docks may give rise to new risks to

operations in the Port and that certain risks may exist to users of the

motorway as a result of the operation of, and activities at, the Port.

c) an Access Agreement granting WG rights of access to the Port to

carry out various activities before, during and after construction of the

M4 Relief Road – for example pre-construction ground investigations,

C:5493828v1 22

construction of the motorway bridge and junction and post construction

bridge condition monitoring.

45. WG witnesses presented evidence to the inquiry explaining the proposed

physical measures at the Docks, the plans for relocating existing tenants,

the effects for shipping and the landside functions in the Docks,

arrangements and proposals for delivery of the measures and relocations,

including consideration of subsequent consenting processes,

environmental assessment and implications, financial / economic

implications and the relationship to Welsh and UK policy for docks and

integrated transport infrastructure. Clearly this was significant new

evidence and therefore arrangements were made for witnesses to read it

in, taking questions of clarification from the Inspectors and from objectors

to the Scheme. Some objectors commented in writing on the proposals for

the Docks and these comments were addressed in written rebuttals. All

those who submitted written representations on this new evidence were

given the opportunity to attend the inquiry, present evidence and cross

examine WG witnesses on their rebuttals.

46. More detailed reference will be made to this evidence below19 and the

statutory questions under s.107 HA 1980 addressed there.

47. We turn now to the remaining statutory tests laid down by the HA 1980 in

respect of the Highways Schemes and Orders.

48. S.16(8) HA 1980 provides that before making or confirming the Scheme,

the Minister “shall give due consideration to the requirements of local and

national planning including the requirements of agriculture”. This statutory

19 Para. 5.7.8

C:5493828v1 23

requirement has been addressed primarily through the evidence of John

Davies MBE and Julia Tindale and by means of the separate Listed

Building Consent (“LBC”) inquiry.

49. The phrase “the requirements of planning” is not defined and it sets up no

answering echo in Town and Country Planning legislation although the

specific mention of agriculture reflects the favoured position of this land use

in planning legislation which derives from the immediate post Second

World War era. National policy now sets out clearly how to balance

agricultural and other interests in planning decisions. Planning permission

is not required for any of the elements of the Scheme although

authorisation will be required in order to implement some of the proposals

for reorganisation in the Docks which are now the subject of agreement

with ABP. It is envisaged that such authorisation will be achieved using

ABP’s statutory powers and the Town and Country Planning (General

Permitted Development) Order 1995 (“GPDO”). These proposals have

been the subject of EIA and SIAA in the context of this Inquiry and will be

subject to further such assessment as necessary as part of the statutory

prior notification procedures under the GPDO. Listed Building Consent is

required to authorise demolition of the Grade II Listed Woodland House

(known locally as ‘Magor Vicarage’ – henceforth “Magor Vicarage”), which

lies on the line of the Scheme.

LOCAL and NATIONAL PLANNING

C:5493828v1 24

50. The Scheme straddles two Local Planning Authority (“LPA”) areas,

Newport City and Monmouthshire County Councils. The development plans

for both have, for many years, protected the Scheme’s route following

service by WG and its predecessors of TRIII notices. The object of this

procedure is to avoid causing unnecessary blight by means of referral of

potentially conflicting planning applications. The procedure also ensures

that the Scheme line shows up on searches so that intending purchasers of

land are not caught unawares. This latter “requirement of planning” is

relevant to consideration of Gwent Wildlife Trust’s (“GWT”) position insofar

as their objection is based upon their status as a statutory objector by virtue

of their ownership of land on the Scheme line in the vicinity of their Magor

Marsh Nature Reserve. It is fair to assume, having due regard to the

requirements of planning and their Newsletter dating from the same time20,

that they purchased the land in knowledge of the Scheme.

51. Both Local Development Plans (“LDPs”) accordingly protect the route.

NATIONAL PLANNING POLICY

52. The legal status of national planning policy in England has recently been

clarified by the Supreme Court in Suffolk Coastal DC v Hopkins Homes Ltd;

Richborough Estates Partnership LLP v Cheshire East BC [2017] UKSC 37

where it was held that the power of the Minister to formulate and adopt

national planning policy is derived, expressly or by implication, from the

Planning Acts which give him overall responsibility for oversight of the

planning system.21 In Wales, planning policy is formulated and published

20 ID 74 which was put to Mr Bakere in cross examination by MEQC 21 Per Lord Carnwath paras 19-20

C:5493828v1 25

by the Cabinet Secretary for Energy, Planning and Rural Affairs on behalf

of the Welsh Government.

53. The legal position in Wales is almost identical, the one exception being the

Wales Spatial Plan which the National Assembly for Wales was required to

prepare by the Planning and Compulsory Purchase Act 2004.22 That

document sets out a strategic framework to guide future development and

policy interventions in Wales. It emphasises the importance of connections

between Cardiff, Bristol and London and internationally in order to attract

inward investment and a high-skilled, high-paid work force. Importantly,

this statutory document also identifies the need to alleviate congestion on

the M4 around Newport as a key strategic issue. All other planning policy

and guidance is issued on the basis explained in Suffolk Coastal.

54. As a general principle, planning law does not prescribe that national

planning policy is to be followed in decision making. Decision makers,

even in the planning sphere, are not obliged “slavishly to adhere” to

policy.23 Therefore, whatever the phrase, “requirements of local and

national planning” in s.16(8) HA 1980 means, it should not be taken to

import a rigid adherence to policy as though it were statute, since that

would run counter to the way in which the Town and Country Planning

system is operated. “Due regard” is a matter for judgment, but cannot

sensibly mean applying planning policy more vigorously than those making

planning decisions. It is also important to remember, as Mr John Davies

MBE pointed out, that the decisions on Schemes and Orders here are not

22 See S.60; this Plan is due to be replaced by the National Development Framework but this is not programmed to be completed before March 2020: CD 5.2.7 para. 2.1 23 City of Edinburgh Council v Secretary of State for Scotland [1997] UKHL 38 per Lord Hope, citing Lord Guest in Simpson v Edinburgh Corpn 1960 SC 313, 318.

C:5493828v1 26

being made under the Planning Acts, whereas national planning policy is

directed towards planning decision makers.

55. National land use policy is set out in Planning Policy Wales (“PPW”) edition

9 (November 2016), supplemented by Technical Advice Notes (“TANs”).

Some of the TANs significantly predate PPW. PPW reflects the

sustainable development principle of recent Welsh environmental

legislation, whereas the older TANs do not. John Davies MBE reviewed

the Scheme against PPW (9), also having regard to TANs where relevant.

56. Importantly, PPW (9) specifically refers to and considers the implications of

the Well Being of Future Generations (Wales) Act 2015 (“FGA 2015”) and

the Planning (Wales) Act 2015 (“PWA 2015”) which cross refers to it.

PPW (9) reminds us that Wales remains one of the few nations in the world

to have enshrined the sustainability principle in law.24 Now, it states, s.2(2)

PWA has enacted a statutory purpose for planning in Wales. S.2(2)

provides as follows:

(2) “the function must be exercised, as part of carrying out sustainable

development in accordance with the Well-being of Future Generations

(Wales) Act 2015, for the purpose of ensuring that the development

and use of land contribute to improving the economic, social,

environmental and cultural well-being of Wales.”

57. PPW (9) specifically sets out the Government’s policy under the 2015

legislation insofar as relevant to planning in the context of the seven well-

being goals. It sets out that the basic goal of sustainable development is: to

24 CD 5.1.12

C:5493828v1 27

“enable all people throughout the world to satisfy their basic needs and

enjoy a better quality of life without compromising the quality of life of future

generations”. 25 The document then points the reader to the definition of

sustainable development in FGA 2015:

‘“Sustainable development” means the process of improving the

economic, social, environmental and cultural well-being of Wales by

taking action, in accordance with the sustainable development

principle, aimed at achieving the well-being goals. Acting in accordance

with the sustainable development principle means that a body must act

in a manner which seeks to ensure that the needs of the present are

met without compromising the ability of future generations to meet their

own needs.’

PPW records that development plans are statutorily required to be

prepared with the objective of contributing to the achievement of

sustainable development26.

58. Accordingly, whilst it notes that further guidance will be published, there

can be no doubt that PPW (9) is fully informed by the sustainability principle

of FGA 2015, setting out its implications for planning policy at a national

level.

59. A draft version of PPW edition 10 is now undergoing public consultation. Mr

John Davies MBE has considered the draft document, albeit that little

25 Para 4.1.1 PPW (9) 26 For forthcoming LDPs, a sustainability duty is contained in the Planning (Wales) Act 2015. The adopted Newport LDP was prepared under the duty in s.39 Planning and Compulsory Purchase Act 2004, which is summarised above

C:5493828v1 28

weight can currently be placed on it27, concluding that “there is nothing in

the consultation draft…to indicate that [Welsh Government’s] choice of the

published scheme as the best means to address…problems is in conflict

with emerging planning policies or the fundamental principles of decision

making”. 28 This conclusion is justified for reasons set out in his review, in

particular, by the continuing recognition in the draft document of the

balancing of the four elements of sustainability (economic, social, cultural

and environmental) considerations to be undertaken in planning decisions

– notably, they are to be given equal “consideration”, but there is no policy

(or legal) requirement to give them equal weight.29 This specific feature of

the draft document is important in the light of objectors’ claims that the

Scheme contravenes the sustainable development principle set out in the

FGA 2015 and the Environment (Wales) Act 2016. It is also important to

note, as did John Davies MBE in his initial proof, responding to criticism of

the WG’s Sustainability Review, that the sustainable development principle

has not arrived out of the blue with the FGA and PWA 2015.30 This recent

legislation and guidance issued under it expand and develop the concept in

practical terms, but they did not invent it. Work on projects, such as

M4CaN, begun before those Acts took effect, is not invalidated.

60. Obviously a major Scheme such as M4 CaN touches many of the topic

chapters within PPW (9). John Davies concluded that the Scheme:

27 In terms of the “requirements of planning”, it is well settled in planning practice that little weight can be placed on draft policy at an early stage of its development and that the weight to place on different material considerations is a matter of judgment for the decision maker. Much of the new draft document is in very similar terms to the extant PPW and this continuity of apparent policy direction can be noted, as well as the areas where development of the sustainability principle is suggested 28 PID 218 John Davies MBE’s response, para.10 29 Draft PPW para.2.24 30 CD 5.1.16, para. 1.11

C:5493828v1 29

"meets the WG’s planning policy objectives that seek to support economic and employment growth alongside social and environmental considerations within the context of sustainable development.”

61. He also acknowledged that the Scheme:

"would conflict with planning policies in respect of cultural heritage, landscape, ecology and nature conservation, as well as the ‘respect for environmental limits’”

62. WG called subject- specific expert evidence on all of these matters which

Mr Davies read and heard. Ecological evidence and the listed building

inquiry are dealt with in later sections of these submissions, but it is

convenient to summarise the general landscape and cultural heritage

evidence here.

63. Landscape and Visual Impact (“LVIA”) and Historic Landscape

(“ASIDOHL”) appraisals were carried out and reported in the ES.

Subsequent ESS have provided and assessed further information at each

stage of Scheme modification and in relation to the proposals for the

Docks.

64. Mr Rawlings acknowledged in the ES and his evidence that, by reason of

the route of the road passing through the northern edge of the two parts of

the Gwent Levels Landscape of Outstanding Historic Interest (“LOHI”) it

would have an effect of Large significance; there is the potential for buried

archaeological remains to be present, although a certain amount of survey

has been undertaken already and there are proposals for more to be done

in advance of construction. He also acknowledged direct and indirect

C:5493828v1 30

adverse impacts upon the Llanfihangel Conservation Area (“CA”),

giving rise to an effect of Moderate significance. He and Ms Longford, the

Conservation Officer for MCC agreed, however, that the effect on the CA of

moving Magor Vicarage would be to preserve its character or appearance.

This matter is dealt with fully below under the Listed Building Inquiry and Mr

Rawlings’ assessment of significance of effect obviously changed

considerably when considering a removal rather than demolition. The

Scheme has been designed to enable retention in situ of the Devil’s Quoit

standing stone at although there would be changes to its setting,

which Mr Rawlings assessed as being of Large significance. There would

be indirect effects of Moderate significance on a further Scheduled Ancient

Monument (a mediaeval moated site at Undy) and a number of listed

buildings. The most significant of these is the Grade 1 listed Transporter

Bridge. A number of unlisted historic buildings in the Docks would be

demolished and the route would go across the site of a Second World War

barrage balloon tether at Nash.

65. Where possible, mitigation had been achieved by design in terms of vertical

alignment – keeping the road low in the landscape - appropriate landscape

planting, reflecting the character and ecological features of the Levels, and

use of low noise surfacing. Two of the water treatment areas are located to

the north of the route, outside the LOHI. Bespoke measures for Devil’s

Quoit, the barrage balloon site and, latterly, Magor Vicarage also

demonstrate sensitivity to cultural heritage concerns, within the constraints

of the route. The Cultural Heritage Mitigation Plan provides for recording in

C:5493828v1 31

advance of demolition and for study / watching brief of the historic back-fen

areas traversed by the new road.

66. In his written evidence and in the ES and ESS, Mr Rowson identified the

effects of the Scheme across its different phases of construction and

operation. He recognised that the Scheme would have a permanent effect

on the landscape and appearance of the LOHI and on the landscape at the

undesignated Castleton and Magor extents of the Scheme. Landscape

impacts would, in different places, range, at Years 1 and 15, from Neutral

to Large Adverse. In the case of visual impacts, planting would be starting

to achieve mitigation. He described the consultative design process, in

which the interests of the SSSI were to the fore, the “overarching principle”

being to minimise landtake there. Through discussion with NRW and the

local authority landscape architects, a consensus emerged that, rather than

trying to hide the road with uncharacteristic landscaping, the approach

should predominantly be grassland planting, allowing long views into the

Levels and preventing the shading of the characteristic reens and ditches.

He used the video flythrough to illustrate his evidence, to aid understanding

for all. He had been fully involved, with other team members, in working up

the Environmental Management Plans (“EMPs”) which are vital to a full

understanding of the Scheme and its impacts. Unsurprisingly perhaps,

these appeared to be new territory for some objectors, but they must be

borne fully in mind when considering all the environmental issues which

arise. The final version of the EMPs, at the close of the Inquiry, is contained

in the September 2016 ES Supplement (ESS1) Figure R2.6 (all 16 sheets),

supplemented by further changes in the March 2017 ES Supplement

C:5493828v1 32

(ESS3) Figure TSR2.6 (sheets 12 & 13, east bound off slip at Magor), and

the August 2017 ES Supplement (ESS4) Figure August 2017 2.6 (sheets 5,

6 & 16 changes to Docks Way Link Road), together with those changes set

out in PIQ025 (updated sheets 8 & 9 with respect to the lighting of the main

line at Glan Llyn), PID 032 (updated sheets 13 & 14 clarifying vegetation

lost opposite Bovis site SAH6) and PIQ 075 (landscaping detail of borrow

pits). However in accordance with Commitment 203 WG, through detailed

design, will continue to develop the environmental and landscape design

with NRW. That design would be recorded in the final EMPs which would

also include all CPO modifications and supplements as well as blighted

land accepted into the Scheme.

67. Messrs Rowson and Rawlings were not challenged by NRW or Cadw on

their conclusions. A SOCG on Cultural Heritage and Landscape and Visual

Effects (“CHALAVE”) was signed by WG and NRW.31 Cadw are not an

objector to the Scheme. In his Closing on behalf of NRW, Richard Wald

referred to the three matters not agreed in CHALAVE. No (i), potential use

of CPO powers for offsetting cultural heritage impacts was a mystery to the

WG at the time and Mr Wald was not able to assist the inquiry in this

regard. NRW were offered the opportunity, after Mr Wald had closed, to

clarify in writing what they mean. This they did in a letter to Welsh

Government from Justin Amos dated 26th March 2018 in which NRW

referred back to its original objection letter of 4th May 2016 which stated at

paragraph 5.2.2 “We welcome the proposal to take forward an integrated

programme of historic landscape analysis in order to offset some of the

31 ID / 155

C:5493828v1 33

impacts on the historic landscape. We recommend that interpretation of

and access to the physical historic landscape should also be considered,

given the significant adverse effects on the Gwent Levels Registered

Landscape. We would expect these proposals to be taken forward within

the Statement of Commitments.” “In relation to the above”, Mr Amos

continued “NRW’s advice has only been that WG should consider providing

or making available additional land, including possibly on a multi-functional

basis (e.g. land already owned by Welsh Government and/or land identified

as ecological mitigation land under the M4 CaN scheme) to help offset the

likely significant effects of the M4 CaN on the Gwent Levels Registered

Landscape”. WG has taken on board those recommendations via

Commitment 74 which commits it to undertaking an integrated programme

of historic landscape analysis, whilst Commitments 204 and 205 refer to a

multifunctional approach to future land use.

68. With regard to No.(ii), Dr Ireland explained that the ASIDOHL had been

agreed by NRW and that this assessment fully acknowledges the reens

and ditches as an important element of the historic character of the Levels.

The undisputed Buildability Report, Cultural Heritage Mitigation Plan and

SSSI mitigation plan leave no room for serious doubt as to the depth of

WG’s understanding and intentions with regard to the reens and ditches.

No. (iii) is a matter of judgment; evidence has been given as to their nature

and appearance, there is no objection from Cadw and where possible, they

have been located outside the LOHI. Mr Wald acknowledged that he had

not called evidence on landscape / cultural heritage and that NRW’s written

C:5493828v1 34

evidence was therefore entitled to less weight, adding that none of these

points is central to their case.

69. At the end of the Inquiry, Mr John Davies MBE reviewed matters and,

particularly, the progress made in terms of removing most of NRW’s

objections. Clearly, the proposal to move rather than simply demolish

Magor Vicarage is a further major step forward in terms of cultural heritage

considerations. Finally, although the Ecosystems Services Assessment

(“ESA”) is not a requirement of planning policy, Mr Davies reviewed it and

commended it as a useful and even handed way of assessing the

Scheme’s effects across all the relevant ecosystems, referring to the

benefits it predicts over the long term. He concluded that the ESA did not

alter the conclusion in his original evidence that, when the extensive

mitigation is taken into account, the balance of advantage lies with the

Scheme.

70. Moreover, although Mr Rawlings took a precautionary approach to

assessing the indirect impact of the new bridge upon the Transporter

Bridge, it should be noted that the Design Commission for Wales, with

whom WG voluntarily consulted and collaborated at design stage, found

the design for the new bridge to be elegant and well considered, forming an

intriguing pair of structures with the Transporter Bridge. Mr Rowson

considers that the new bridge would be generally beneficial in visual terms,

particularly in medium to distant views where its scale, form, design and

location within the landscape can be more fully understood. Mr John

Davies MBE considered these matters carefully in the round, agreeing with

Mr Rawlings that there would be some diminishing of significance for the

C:5493828v1 35

Transporter Bridge as a result of the new bridge crossing the Usk further to

the south, but pointed out that the ability to appreciate the Transporter

Bridge from elevated views would be greatly increased and, with it, the

significance and appreciation of it. There are, therefore, pros and cons and

doubtless the inspectors will have their own opinions formed on site. In

terms of assessment, however, WG has adopted a precautionary

approach.

71. A particular area of importance in the policy context is flood risk. This is

covered in PPW 9 (2017) Chapter 13 and TAN 15 (2004)). The latter is still

extant, although the WG has started a review of it.

72. The technical details of the extent and potential consequences of flood risk

for the Scheme are all agreed with NRW and summarised below. In terms

of national policy, Mr John Davies MBE concludes that the Scheme is not

in accordance with the general policy of WG articulated in PPW and TAN

15 that development should be directed away from areas of flood risk. The

line of the proposed motorway is largely in a C1 area with a small area of

C2. He notes, however, that PPW recognises that there will need to be

exceptions to the overarching policy objective and it singles out essential

transport and utilities infrastructure in this regard. PPW 13.3.2 provides

that such infrastructure should:

- be constructed so as to remain operational even at times

of flood;

- result in no net loss of flood plain storage;

- not impede water flows; and

- not increase flood risk elsewhere.

C:5493828v1 36

73. PPW 13.4.1 introduces the following further tests for new development in

areas of high flood hazard:

- new development can be justified in that location;

- new development would not result in the intensification of

development which may itself be at risk; and

- new development would not increase the potential

adverse impacts of a flood event.

74. TAN 15 also imposes tests for development in Zone C2. These are that:

i. its location in zone C is necessary to assist, or be

part of a local authority regeneration initiative or a

local authority strategy required to sustain an

existing settlement; or

ii. its location in zone C is necessary to contribute to

key employment objectives supported by the local

authority, and other key partners, to sustain an

existing settlement or region; it concurs with the

aims of PPW and meets the definition of previously

developed land (PPW fig 2.1); and

iii. the potential consequences of a flooding event for

the particular type of development have been

considered, and in terms of the criteria contained in

sections 5 and 7 and appendix 1 found to be

acceptable.

C:5493828v1 37

75. PPW and TAN 15 anticipate that such exceptional developments will be

allocated in development plans. As noted above, both of the relevant LDPs

protect the line of the Scheme but they do not allocate it as such. This is

one example in which “due” consideration of “planning requirements” must

be interpreted in context. This national road Scheme is being brought

forward under Highways Act rather than Planning powers32.

76. It has been demonstrated, through WG’s evidence, that the Scheme is

essential in the national interest and the Programme for Government

makes a commitment to an M4 relief road as part of its “United and

connected” theme. The national strategy Prosperity for All, published

alongside WG’s revised well-being objectives under FGA 2015 s.3(2)(a),

requires a significant improvement to the M4 around Newport33. This

nationally significant infrastructure scheme transcends the local authority

level and it would obviously be impossible for a local authority to deliver a

venture of this scale. The road is required to sustain the SE Wales region

and, through it, the nation as a whole. The local authorities through whose

areas the Scheme principally passes – NCC and MCC - support it, as do

Cardiff, Caerphilly, Rhondda Cynon Taf and Neath Port Talbot Councils. 34

Other supporters, reflecting a range of economic, social and cultural /

sporting interests, include organisations such as Newport Civic Society,

Monmouthshire Local Access Forum, Wales and West Utilities, Network

Rail, Cardiff Airport, Gwent Police, the Freight Transport Association, the

Port of Milford Haven, Confederation of British Industry Cymru, South

32 Doc 5.1.11 See all the Proofs of Evidence of John Davies MBE and, specifically on Prosperity for All, his Scheme Evidence Update,WG 1.23.5 34 ID131

C:5493828v1 38

Wales Chamber of Commerce, Institute of Directors Wales Division, Welsh

Rugby Union, Welsh Football Trust, Institution of Civil Engineers, Wales

Cymru Retired Engineers Group, TATA Steel and St Modwen

Developments. The last representor, which submitted expert planning

evidence to articulate its recognition of the need for the Scheme and the

environmental, social and economic benefits that it would bring, is

particularly significant in the context of the adopted planning strategy for

Newport. In this respect, Mr Gent,35 an experienced town planner with a

detailed knowledge of the M4 corridor, gives a more detailed exposition of

the central role of the Glan Llyn development in delivering the brownfield

regeneration strategy of Newport LDP, as alluded to by Mr John Davies

MBE.

77. TAN 15 (2004) does not specify which “aims of PPW” it refers to and it

must be remembered that the PPW which applied at the time was different

from the current one. In particular, the current version of PPW includes the

following guidance, drawn from TAN 23: Economic Development (2014):

"Local planning authorities are required to ensure that the economic benefits associated with a proposed development are understood and that these are given equal consideration with social and environmental issues in the decision-making process, and should recognise that there will be occasions when the economic benefits will outweigh social and environmental considerations.”36

78. PPW 9 was updated specifically to translate into policy the sustainable

development principle enacted in the recent Welsh environmental

35 Hearing Statement SUP 139 36 PPW para 7.2.2

C:5493828v1 39

legislation. It is therefore highly significant that it includes this statement on

the weighing of potentially competing considerations. There are many

“aims” set out in PPW, the unifying principle being that of achieving

sustainable development. As this important paragraph recognises, in some

instances the achievement of sustainable development may involve

allowing that economic benefits should outweigh certain other

considerations.

79. As Mr John Davies MBE points out, it would be impossible for the PPW

exception of essential transport infrastructure to meet the TAN criterion of

unobstructed floodplain. To the extent that there is inconsistency, “due

consideration of the requirements of planning” should afford greater weight

to the modern PPW, drafted in the context of current legislation.

80. The last of the TAN 15 criteria concern flooding consequences:

- no flooding elsewhere

- Scheme to be flood free in a 0.5% (1:200 year) event

- flooding up to 600mm acceptable beyond the 0.5% (1:200

year) event

81. In line with the advice in TAN 15, WG’s engineers have liaised extensively

with NRW’s flooding team. As a result, there is agreement on all relevant

technical matters.37 The broad statements of common ground are:

(i) Following the recent completion of the Tabbs Gout and Portland

Grounds Flood Risk Management (FRM) schemes, the and

Caldicot Levels tidal defences currently (year 2017) have a 0.1% Annual

37 ID/048 Flood Risk Statement of Common Ground

C:5493828v1 40

Exceedance Probability (AEP) Standard of Protection (SoP) against breach

or greater, relevant to the Scheme. The only exceptions to this are near

Stephenson Street on the River Usk (overtopping in the 10-3.3%AEP

event), Goldcliff Pill (overtopping in 0.5-0.1% AEP event), between

Coldharbour Pill and Sudbrook Point (piping breach in the 20-0.5%AEP

events; wave, tidal overtopping and/or breach in the 0.5-0.1%AEP events);

and small-scale works where tidal defences are only slightly lower than

recommended and over a short length (subsequently referred to as small-

scale works).

(ii) Following construction of the Stephenson Street Scheme (submitted to

the Welsh Government for funding under its Coastal Risk Management

Programme with subsequent allocation of funds for “Stephenson Street

Risk Management Scheme” in the WG’s draft 2018-19 Budget38) and any

schemes relating to the locations noted above, the Wentlooge and Caldicot

Levels tidal defences will have a 0.1%AEP SoP in 2030, relevant to the

Scheme.

(iii) NRW has responsibility for ongoing localised small-scale works

(consisting of inspection, maintenance and addressing locally lower or

weaker sections of defence) on the Wentlooge and Caldicot Levels. These

works are funded by the NRW annual maintenance budget.

(iv) With regard to fluvial and pluvial flooding there would be no increased

flood risk as a result of the Scheme and hence no conflict with PPW or

TAN15.

38 PID 205 para.3.51

C:5493828v1 41

81A. With regard to tidal flooding, the Severn Estuary Shoreline Management

Plan 2 (SESMP2), which was agreed by Welsh Ministers on 26th November

2014, sets the preferred policies for the Wentlooge and Caldicot Levels

shoreline as ‘Hold the Line’ for the next 100 years. The importance of

SMPs is emphasised in WG’s first draft Marine Plan, published in draft in

December 2017. This is a statutory document being produced pursuant to

the duty in s.51 Marine and Coastal Access Act 2009. Of course, as it is in

draft, it can carry only limited weight, but it shows the direction of policy

being to carry forward the SMP approach in a cross-cutting way, as its

sustainable response to the issues of climate change. The draft states that

SMPs provide important context for decision making by setting out the

preferred policies for specific areas. Wentlooge and Caldicot Levels are

shown as being subject to the “Hold the Line” policy.39

81B. The Severn Estuary Flood Risk Management Strategy (SEFRMS)

recommends a programme of improvements to the tidal flood defences for

the Wentlooge and Caldicot Levels that is independent of the Scheme and

would provide a 0.1% AEP SoP over the next 100 years. Two of the three

priority schemes identified in the SEFRMS on the Wentlooge and Caldicot

Levels have been completed i.e. Tabbs Gout and Portland Grounds; with

Stephenson Street, Newport currently at project appraisal stage with a view

to be implemented in the short term. Any further schemes related to the

overtopping and breach locations in NRW (2016a) would also be justified

and recommended by the SEFRMS, thus providing the necessary

39 See Doc 5.1.5

C:5493828v1 42

protection to 2030. Implementation of this programme beyond 2030 would

protect the Levels to a 0.1% AEP SoP over the life of the M4 Scheme.

82. Moreover, NRW are satisfied that the implications of climate change have

been appropriately assessed for the lifetime of the Scheme using a period

of 100 years;40 that the Scheme satisfies the acceptability criteria in TAN

15 for fluvial and pluvial flooding; and that it would not cause any

unacceptable impacts from fluvial flooding elsewhere.

83. With regard to tidal flooding, two temporal scenarios need to be

considered. The first covers the period to 2025 (at the latest). By 2025,

certain relatively minor works of flood protection will have been completed.

It is agreed with NRW that, from completion to 2030, the new road would

comply with the requirements of PPW and TAN 15 not to increase flood risk

or the consequences of flooding.41

84. The second period is from 2030 onwards. The sole issue between WG and

NRW on flooding turns on the appropriate assumption to make about this

period with regard to implementation of the “Hold the Line” policy approved

by the Government within the Severn Estuary Shoreline Management Plan

2 (“SESMP2”).

85. The pertinent facts are agreed.42 SESMP2 is a Shoreline Management

Plan, prepared in accordance with DEFRA guidance in the context of

coastal environmental powers and duties. The lead promoting body in

Wales is NRW though there is a steering group comprising also relevant

local authorities, the English Environment Agency, DEFRA and WG.43

40 Op-cit para 5.1.7 41 Op cit para 5.1.11 42 See ID/048 and Gary Purnell cross examination (ME QC) 43 John Davies MBE, re-examination

C:5493828v1 43

86. The current Plan was agreed by WG. It includes preferred policies to “Hold

the Line” for the Wentlooge and Caldicot Levels for the next 100 years.

“Hold the Line” is defined in the DEFRA guidance as:

"Hold the existing defence line by maintaining or changing the standard of protection … to improve or maintain the standard of protection provided by the existing defence line.”

87. Agreement by WG in November 2014 signifies that WG consider the policy

to be a sustainable one, a stance recently reaffirmed by inclusion of the

Stephenson Street Scheme in the Budget and Wentlooge and Caldicot

Levels in the draft Marine Management Plan under this designation.

88. The Benefit to Cost Ratio (“BCR”) of the policy was 31 in relation to the

Caldicot Levels (the only area of concern to NRW in this regard). Mr Purnell

said that the BCRs for the Levels were the highest for a long term project

that he has ever encountered. The more recent budgetary and policy

developments are, therefore, entirely what one would expect. Moreover, he

agreed, the BCR is likely to go up with the passage of time and would

certainly do so if M4 CaN were built. By virtue of the Natural Resources

Body for Wales (Establishment) Order 2012, Art 8, NRW, in considering

whether or not to exercise any power conferred on them, are obliged to

take into account the likely costs and benefits of exercising or not

exercising that power i.e. BCRs. Mr Purnell agreed that these BCRs would

be a “very material consideration” for NRW in deciding whether or not to

exercise their powers to implement SESMP244 and that it would “probably

44 Cross examination (ME QC)

C:5493828v1 44

be very favourable in getting the scheme delivered in the future”.45 The

physical consequences of failing to implement the policy in the longer term

would be catastrophic. The whole of Newport, Cardiff, the main railway

line, a vast amount of housing, industry and energy infrastructure would be

submerged. In WG’s submission, it is inconceivable that any future

Government would countenance risks of such magnitude remaining

unchecked. Therefore the only tenable assumption to make for the

purposes of evaluating policy compliance is that SESMP2 will continue to

be implemented, as has started already under Severn Estuary Flood Relief

Management Scheme (“SEFRMS”).

89. NRW’s position is, apparently, that such an assumption should not be

made unless and until WG commits its successors to funding for the next

80 years or so. Clearly, no government can commit its successors to policy

or expenditure on policy implementation in that way46. The analogies

drawn by NRW with ongoing maintenance for mitigation measures in other

infrastructure projects and in the Schedule of Environmental Commitments

are inapt. These Commitments provide assurance that the physical

impacts of the Scheme will be met as it is constructed and operated and

requirements imposed on Development Consent Orders similarly relate to

impacts of those projects. The physical impacts of failing to implement the

Hold the Line policy would be incurred irrespective of the M4 CaN. Mr Wald

found it “curious” that WG relied on the gravity of effects of potential post

2030 flooding in the absence of implementing the SEFRMS; with respect,

45 Re-examination (RW) 46 This is a matter of democratic common sense and not based on the earlier suggestion in correspondence based on the impermissibility of fettering an administrative discretion. That legal principle is not necessary in order to support the validity of WG’s approach

C:5493828v1 45

this comment misses the point, which is that it is inconceivable that “Hold

the Line” would cease to be the order of the day, but none of this has

anything to do with M4CaN. Save for the agreed fact that the new road

would create an even stronger case for funding the policy in the future, it is

irrelevant. Characterising the matter as one of finance versus safety in

NRW’s Closing simply did not do justice to the evidence, including

admissions made in cross examination by their flooding witness, which

were reviewed above. NRW’s approach is counter-intuitive and should not

be adopted as an assumption for the purposes of assessing policy

compliance.

90. In relation to s.16(8) HA 1980 and “the requirements of national planning”,

however, it is pertinent to note NRW’s agreement that, once the short term

works have been undertaken (by 2025 at the latest), there would be no

conflict with national planning policies in the longer term on the basis that

future funding does occur to comply with WG’s “Hold the Line” policy and

recommendations.47 WG’s strong submission is that it is inconceivable that

the “Hold the Line” policy or better would not be achieved in the period from

2030 onwards.

91. On WG’s case, there is therefore a short period of non-compliance with

TAN 15 up to 2025 at the latest, before the local flood defence works are

done. Dr Canning has, at NRW’s request, modelled the practical

implications of this non-compliance on the basis of NRW’s most up to date

data, in the 0.1% (1:100 year) + climate change event. Mr Purnell agreed

the results of this modelling,48 which may be summarised as follows:

47 Op cit para 5.1.13 48 Cross-examination (ME QC)

C:5493828v1 46

- In 2018, with existing tidal defences, the M4CaN would

cause up to 25 property detriments and 86 property

betterments in the 0.1%AEP event. The detriments

consist of 0.01 – 0.08m increased flood depth to

properties already experiencing 0.18 – 2.42m flood

depth. The betterments consist of 0.01 – 0.15m

decreased flood depth to properties already

experiencing 0.17 – 0.83m flood depth.

- In 2018, with the Stephenson Street scheme

(excluding raised defence east of the railway line), the

M4CaN would cause up to 23 property detriments and

38 property betterments in the 0.1%AEP event. The

detriments consist of 0.02 – 0.24m increased flood

depth to properties already experiencing 0.03 – 1.98m

flood depth. The betterments consist of 0.02 – 0.31m

decreased flood depth to properties already

experiencing 0.21 – 0.69m flood depth, and 26

properties completely removed from flooding

(decreased from 0.15 – 0.45m flood depth).

- In 2025, with Stephenson Street scheme (including

raised defence east of the railway line), Goldcliff Pill

and Coldharbour Pill to Sudbrook Point works, the

M4CaN would cause no property betterments or

detriments, up to the 0.1%AEP event.

C:5493828v1 47

- In conclusion the modelling work indicates that with the

identified tidal defence works being constructed by

2025, the M4CaN would not increase the numbers of

properties that would already flood in 2019 or 2025

without the M4CaN in place.

92. It is notable that no new properties which would not already be subject to

flooding would be affected by flooding as a result of M4 CaN.

LISTED BUILDING APPLICATION

93. In recognition that the “requirements of planning” include listed building

consent (“LBC”), an application for the demolition of Grade II Listed

Woodland House (known locally as ‘Magor Vicarage’) was submitted to

Monmouthshire County Council (“MCC”) as LPA on 1 September 2016,

and validated by MCC on 9 September 2016. The application was called in

by Lesley Griffiths AM for her own determination on 22 December 2016.

The reason given for the call-in was:

“The application for listed building consent is inextricably linked

with the major proposal to construct the M4 relief road which is

being determined by the West Ministers as a Roads Order. This

in itself satisfies one of the criteria for call-in set out in

paragraphs 76-77 of Circular 61/96, being a matter related to a

decision being taken by the Welsh ministers. Additionally a

justification for the demolition is its requirement for the

construction of the ‘M4 Corridor around Newport Scheme’,

C:5493828v1 48

which in the Cabinet Secretary’s view may also raise issues of

exceptional significance or controversy”.

94. S.6 Planning (Listed Building and Conservation Areas) Act 1990 makes it a

criminal offence to demolish a listed building without authorisation. S.8

provides for the giving of such authorisation, as follows:

“(1) Works for the alteration or extension of a listed building are authorised if— (a) written consent for their execution has been granted by the local planning authority or the Secretary of State; and (b) they are executed in accordance with the terms of the consent and of any conditions attached to it. (2) Works for the demolition of a listed building are authorised if— (a) such consent has been granted for their execution; (b) notice of the proposal to execute the works has been given to the Royal Commission; (c) after such notice has been given either— (i) for a period of at least one month following the grant of such consent, and before the commencement of the works, reasonable access to the building has been made available to members or officers of the Royal Commission for the purpose of recording it; or (ii) the Secretary of the Royal Commission, or another officer of theirs with authority to act on their behalf for the purposes of this section, has stated in writing that they have completed their recording of the building or that they do not wish to record it; and

C:5493828v1 49

(d) the works are executed in accordance with the terms of the consent and of any conditions attached to it. (3) Where— (a) works for the demolition of a listed building or for its alteration or extension are executed without such consent; and (b) written consent is granted by the local planning authority or the Secretary of State for the retention of the works, the works are authorised from the grant of that consent. (4) In this section “the Royal Commission” means— (a) in relation to England, the Royal Commission on the Historical Monuments of England; and (b) in relation to Wales, the Royal Commission on Ancient and Historical Monuments in Wales. (5) The Secretary of State may by order provide that subsection (2) shall have effect with the substitution for the references to the Royal Commission of references to such other body as may be so specified. (6) Such an order— (a) shall apply in the case of works executed or to be executed on or after such date as may be specified in the order; and (b) may apply in relation to either England or Wales, or both. (7) Consent under subsection (1), (2) or (3) is referred to in this Act as “listed building consent”.”

95. As acknowledged in WG’s evidence to the Listed Building Inquiry, such

applications are subject to s.16 Planning (Listed Buildings and

Conservation Areas) Act 1990 (“LBCAA”) which provides that special

regard is to be paid to the desirability of preserving or enhancing the listed

C:5493828v1 50

building or its setting or any features of special architectural or historic

interest which it possesses. Caselaw has established that these words

mean that there is a presumption against harming a listed building “of

considerable importance and weight”.49

96. By making the Listed Building Application and calling it in for determination,

WG and the Welsh Ministers, respectively, have observed the listed

building procedural planning requirements. Whilst there is a strong

presumption against harm, the evidence has demonstrated that its

demolition is essential. This case is exceptional, given both the need for

M4 CaN, its national significance and the lengthy and detailed work

undertaken to arrive at the Scheme and test alternative alignments which

would not involve demolition. As Mr Matthew Jones explained, in order to

accommodate the preferred route and junction strategy while avoiding the

Gwent Levels SSSIs where practicable, the alignment needs to run parallel

to the A4810 to the west of Magor, tying in to the existing M4 to the north

west of the settlement. To fit the alignment in, between the A4810 and the

residential properties to the north of Magor, while meeting design standards

and not causing serious economic impacts to the Brewery and Wales One

Business Park, it is impossible to avoid the listed building50. TAN 2451, and,

indeed, the legislation itself, recognises that there can be occasions when

other considerations will outweigh impacts to heritage assets. The TAN

accepts that alterations to the historic environment are inevitable and can

be the result of, amongst other things, the need to respond to social,

49 Barnwell Manor Wind Energy v East Northants DC, English Heritage and the National Trust [2014] EWCA Civ 137. 50 See Jones Proof WG 1.1.6 Section 4 51 ID/077 Doc 3, para.1.8

C:5493828v1 51

cultural, economic and technological changes; plainly, this approach is

relevant here. Mr Smith pointed out that his Green Route would avoid the

Vicarage; this submission raises wider considerations which are dealt with

elsewhere in these submissions. In short, after its appraisal during the

Highway Inquiry, WG submits that the Green Route is not a satisfactory

alternative way of meeting the need for the Scheme. Legislation and policy

require a balance to be struck.

97. In striking this balance, Mr Rawlings followed the assessment in the ES

and treated the magnitude of impact due to outright demolition of the

Vicarage and its coach house/stable as Major, with a consequent Large

Adverse significance of effect. In reaching this judgment, he had regard to

the listed status of the building, albeit at Grade 2 (the lowest listing

grade)52. He identified the significance of the building as deriving

principally from its architectural qualities and association with a

distinguished architect with some associative values derived from

connection with Magor church. Ms Longford, the LPA’s Conservation

Officer, agreed with this assessment of value and significance.

98. It is now the case, however, that very substantial mitigation for the

demolition is proposed. WG have made a Commitment53 to relocate the

Grade 2 listed Magor Vicarage to a suitable location, subject to the

outcome of the Magor Vicarage Public Inquiry and grant of planning

permission and LBC (if the latter is required) by MCC. Such a location has

been identified on land next to the Old Court, Llanfihangel. This is a site

which WG has accepted that it will acquire on account of blight and it would

52 Rawlings Proof WG 1.9.4 Section 5 53 ID 231 Commitment 207

C:5493828v1 52

be available early in the Project so that the listed building and its coach

house could be carefully dismantled and re-erected there. Consideration

has been given to practical considerations such as drainage and the

building could be satisfactorily accommodated. Mr Rawlings explained that,

as most of the significance of the building lies in its architecture, fixtures

and fittings, the proposed solution would enable much of the building’s

heritage significance to be preserved. Whilst the building would obviously

be moved from its existing location in Magor, he did not consider that it had

a strong relationship with the church or the settlement, partly because of

the circumstances of its construction relatively remote from the church and

partly because of surrounding roads and landscaping which mean that

there is no visual relationship with the church. In terms of distance from the

motorway and noise, the new position would be better because further

away from the motorway and its slip roads. Ms Longford said that she

agreed with Mr Rawlings’ assessment.

99. Whilst MCC cannot pre-judge the outcome of these proposed applications,

officers have worked collaboratively with WG to examine the options and

they have confirmed that, notwithstanding its location outside a settlement

boundary within a Green Wedge, the very exceptional circumstances of this

case mean that the Old Court site “could in principle be considered

favourably as an exception to LDP policies”. 54 This confirmation and WG’s

Commitment, together with the manifest conservation advantages, mean

that substantial weight can be given to the mitigation proposal, although all

recognise that it would not be appropriate to impose a Grampian condition

54 ID/204 second document para. 15, confirmed orally on 16.3.18 by Mr Hand, Director of Planning Monmouthshire County Council

C:5493828v1 53

because delivery of the consents is not in WG’s complete control. Turning

to the effects upon the receiving environment, Mr Rawlings and Ms

Longford both considered that the character of Llanfihangel Rogiet

Conservation Area would be preserved. As the Conservation Officer

explained, the area, when designated, was considered a fine example of a

detached farming community; in spite of the residential conversions to

which Mr Hand referred, in her opinion that character assessment remains

valid and she did not consider that Magor Vicarage would have a

detrimental impact, such that the character and appearance of the

Conservation Area would be preserved. Nor did she consider that there

would be any adverse effect on the settings of the existing listed buildings

in the vicinity. Mr Rawlings agreed with this assessment and demonstrated

that careful thought has been given to detailed siting already, taking

advantage of existing vegetation. Cadw have been consulted; they do not

oppose the listed building application and have not commented on the

proposed relocation. Mr Smith asserted the opposite and, whilst the

strength of his feeling cannot be denied, his disagreement with the expert

witnesses was not supported by analysis.

100. Drawing together heritage matters, WG submits that the following

conclusions can be reported to the Welsh Ministers:

i. That demolition of the Grade 2 listed building is physically necessary

to enable the Scheme to go ahead on an alignment which occupies

as little of the Gwent Levels SSSIs as possible; alternative routes at

this point have been considered and rejected on the basis of

excessive impacts on residential and employment properties.

C:5493828v1 54

ii. That the Scheme is necessary and desirable, for all the reasons

explained in the main Public Inquiry.

iii. That the statutory / policy presumption against loss or damage to the

significance of the listed building is outweighed by the need for the

Scheme.

iv. Notwithstanding the overriding case for demolition, WG has

responsibly explored the mitigation option of relocation; the solution

proposed is supported by MCC, subject to proper caveats, and

would enable the fabric of the listed structure to be transferred to an

appropriate new setting.

v. Much of the building’s significance as evidenced by the listing

description and Mr Rawlings’ professional assessment, now lies in

its physical features rather than its setting; the relocation proposal, if

implemented, would therefore enable much of the building’s

significance to be preserved.

vi. The achievement of relocation lies outside WG’s control, so it would

be inappropriate to impose a Grampian condition on the LBC. WG

has made a Commitment to pursue relocation.

vii. Weight should be given to the proposed mitigation in view of the

SOCG agreed with MCC; this proposal, and the exercise underlying

it, are in line with the principles of the FGA 2015, as Mr John Davies

MBE has demonstrated.

viii. Mr Green explained that an initial survey in February 2017 revealed

that the Vicarage and its coach house / stable provide bat habitats.

Subsequent surveys over 26 days and nights in May and June 2017

C:5493828v1 55

confirmed that there is a small number of common pipistrelles

roosting by day under the porch roof. This is not a maternity roost.

Similarly, despite a large number of old bat droppings in the coach

house / stable, he considers that this structure provides a day and

night roost for a small number of lesser horseshoe bats. Discussion

of potential mitigation has taken place with NRW, who have agreed

with the principle of providing mitigation by means of a bat house,

subject to there being appropriate arrangements in place for its long

term management, maintenance and monitoring. These measures

are likely to be required in connection with the granting of a licence

under the Habitats Regulations. Proposed conditions are agreed,

including one which provides for such future maintenance etc. and,

on this basis, NRW do not object to the listed building application55

Furthermore, there are relevant Commitments which have been

proposed in the Highways Inquiry. Other draft conditions are

unremarkable and are set out in the SOCG with MCC.56

101. Accordingly, WG submits that LBC should be granted for demolition of

Magor Vicarage in this exceptional case.

THE REQUIREMENTS OF AGRICULTURE

102. Mrs Tindale’s proof gives details of the agricultural resources and land

take. There is no dispute about the figures. 57

103. Mrs Tindale also explained, during presentation of her main evidence and

in the sessions devoted to examining the Schemes and Orders in detail,

55 ID/102 Note on Future management of Bat Mitigation Measures and letter 19.6.17 56 ID/102 57 Reference 2.4.4 ES Supplement September 2016 Volume 2, Figures R15.7 (ALC) and R15.8 (Farm Holdings)

C:5493828v1 56

her engagement with farmers before and after making the Scheme. Many

of the Scheme’s features and several of the proposed Modifications are

designed to reduce impacts on farming operations as much as possible. A

number of individual farmers’ objections remain and these are dealt with in

the evidence, with references set out in the attached Annexes 1 and 2. In

all instances, the effects of the Schemes/Orders engage the individual

human rights of farmers, because of interference with their property and/or

homes. This important consideration, which is distinct from the general

public interest in agriculture expressed through planning policy, is dealt with

in further detail later in the closing statement.

104. Consultants on behalf of WG carried out a comprehensive appraisal of the

farm holdings affected by the Scheme, which formed part of the ES (March

2016). WG representatives have consistently liaised with landowners and

their agents throughout the development of the Scheme, the submission of

draft Orders and through the period of the Inquiry. Wherever possible,

refinements to the Scheme were incorporated into the development of the

draft Orders to reduce, as far as possible, potential impacts on individual

farm holdings. Since the submission of draft Orders and statutory

objections, further detailed discussions have led to the development of

proposed Modifications to address remaining concerns, wherever

possible.58

105. Impacts on agriculture generally are also considered in the ESA, which

recognises the role played by agricultural land to be lost as a result of the

58 Evidence in ID007d updates on those relevant matters.

C:5493828v1 57

Scheme. The loss of the relevant “services” performed by that land are

monetised and duly taken into account in the overall evaluation.

106. WG have clearly given due consideration to the requirements of agriculture

in working up the Scheme and presenting it to the scrutiny of Public Inquiry.

107. Mr John Davies MBE put the effects on best and most versatile (“BMV”)

land (i.e. Grades 1, 2 and 3A) into their planning policy context. PPW

states that BMV land should only be developed where there is an

overriding need and land in lower agricultural grades is unavailable or has

an environmental value which outweighs the agricultural considerations.

Where BMV land has to be used, development should be directed to land

of the lowest grade. Therefore, planning policy recognises that society may

have needs more pressing than the desirability of preserving even BMV

land. There is no absolute “requirement” to do so.

108. In this case, more than 80% of the land take overall comprises non-

agricultural land or non BMV agricultural land. Serious efforts have been

made to reduce land take and to work with farmers to mitigate the

operational effects of the road, such as severance. Mr John Davies MBE,

having considered the effects on agriculture in its policy context, concluded

that the evidence has demonstrated “an overriding need to address the

traffic, economic and social problems caused by the serious deficiencies of

the M4 around Newport”. We invite the Inspectors and the Welsh Ministers

to agree that the impacts upon agriculture do not outweigh the need for the

Scheme, having given the matter “due consideration”.

PLANNING BALANCE

C:5493828v1 58

109. PPW covers many specialist topics and the TANs expand on them. Town

and country planning is a practical discipline. Whilst it is policy led,

planning law recognises that “other material considerations” must always

be taken into account and may outweigh policy presumptions.59 In giving

“due consideration to the requirements” of planning, the decision maker

under s.16 HA 1980 must bear in mind the nature of the planning process.

As Mr John Davies MBE repeatedly explained in his written and oral

evidence, there is a balance to be struck here between beneficial and

adverse impacts. All the guiding legislation recognises that this is the stuff

of decision making in the environmental sphere, although there has been

considerable reluctance in some quarters to recognise this fact during the

Inquiry.60 Mr John Davies MBE weighed all relevant matters within the

wider context of the EWA 2016, FGA 2015 and the PWA 2015, which

embed the sustainable development principle into decision making

generally, both in the planning and the highways sphere. He also

considers the specifics of local and national planning policy and concludes:

i. that the Scheme is fully in accordance with a number

of national planning policies;

ii. that where conflicts exist, the benefits of the Scheme

in relieving the existing problems associated with the

M4 around Newport are sufficient to justify an

exception in this particular case.61

59 S.70 Town and Country Planning Act 1990; s.38(6) Planning and Compulsory Purchase Act 2004. 60 Eg. RSPB correspondence (OBJ0030); FG C’s reps (OBJ0024); Woodland Trust (OBJ0271) : Mr Barnes proof (OBJ033) and cross examination 61 Proof (WG 1.23.1) para 249

C:5493828v1 59

110. Save for the “Hold the Line” policy issue, on which he was cross examined

by NRW, Mr Davies was not directly challenged on his conclusion, though it

is accepted that many objectors profoundly disagree with his assessment

of where the balance lies between the negative effects of the Scheme,

which WG’s documentation and witnesses have candidly admitted, and its

benefits which Mr Davies regards as outweighing the harms. Of course,

one would not expect a forensic challenge of this sort from local people,

such as Mrs Picton MBE and Mr Smith, but it is noticeable that no such

assault has come from the numerous counsel employed by GWT, nor was

there any attack on the overall need for the Scheme by leading counsel for

Roadchef; neither of these objectors called any professional planning

evidence. Roadchef support the principle of the Scheme and object simply

in relation to its design at Junctions 23/23A.

111. GWT and the Future Generations Commissioner, rather than leading

planning evidence of their own, concentrated on locking horns with WG

over its interpretation of the FGA 2015 and Mr Byrne asked Mr John Davies

MBE if he was prepared to keep his mind open to change in the light of the

unfolding evidence at the inquiry. Mr Davies agreed that his mind was open

and he has conscientiously followed the entire inquiry process, written and

oral, throughout. He has updated his evidence in the light of policy and

other developments, drawing his assessment to a conclusion in his final

sustainability appraisal of the Scheme.62 He was made available for cross

examination / inspectorial questioning on each occasion, including

62 Doc 1.23.7

C:5493828v1 60

presentation of his final assessment.63 Without in any way seeking to

usurp the judgments of the Inspectors or Ministers, it is the case that,

given his distinguished career within the Planning Inspectorate, Mr Davies’

comprehensive consideration of the Scheme in the light of policy and all

the evidence is entitled to considerable respect and weight.

DRAFT COMPULSORY PURCHASE ORDERS (“CPOS”)

112. Five CPOs have been made in order to deliver the Scheme. They are:

a) The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton) Compulsory Purchase Order 201-

This authorises the acquisition of land for the construction of

the special road and improvement of highways comprised in

the Scheme, the provision of new means of access comprised

in the Side Roads Order, the improvement of the Motorway,

construction of new highways and slip roads comprised in the

Line Order, construction of works on watercourses in

connection with the above, the provision of buildings and

facilities in connection with the construction, use and

maintenance of the special and trunk roads, use in connection

with the works and the mitigation of adverse effects in

connection with the existence or use and the highways. The

63 An opportunity taken up, on the final occasion, by Mrs Picton MBE (OBJ 0203) and Dr Varley (OBJ 087)

C:5493828v1 61

Order was published on 24 March 2016. The period for

making objections closed on 4 May 2016. The Order was

made under sections 239, 240, 246, 250, 260 HA 1980 and

section 2 and paras 1(1)(b), (3) and (4) of part 1 of Schedule

2 Acquisition of Land Act 1981 (“ALA 1981”). Procedural

requirements and protections for those whose land is being

expropriated are provided in the ALA 1981. Here again,

human rights are engaged.

b) The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton) Supplementary Compulsory Purchase Order 201-

The Order was published on 5 September 2016 to authorise

acquisition of land for the construction of the realigned

Bencroft Lane and for the realigned outfall from a proposed

Water Treatment Area. The period for making objections

closed on 17 October 2016. The Order was made under

sections 239, 240, 250, 260 and paras 1(1)(b), (3) and (4) of

part 1 of Schedule 2 ALA.

c) The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton) Supplementary (No 2) Compulsory Purchase Order 201-

C:5493828v1 62

The Order was published on 21 March 2017 to authorise

compulsory purchase of additional land for the Magor

Eastbound offslip as part of the Scheme. The period for

making objections closed on 10 May 2017. The Order was

made under sections 239, 240, 260 HA and paras 1(1)(b), (3)

and (4) of part 1 of Schedule 2 ALA.

d) The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton) Supplementary (No 3) Compulsory Purchase Order 201-

The Order was published on 25 May 2017. This authorises

the acquisition of extra land for bridge protection measures

within Newport Docks. The period for making objections

closed on 20 June 2017. The Order was made under sections

239, 240, 250, 260 HA and paras 1(1)(b), (3) and (4) of part 1

of Schedule 2 ALA.

e) The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton) Supplementary (No 4) Compulsory Purchase Order 201-

The Order was published on 22 August 2017. This authorises

the acquisition of additional land for the construction of

amended bridge protection measures in Newport Docks. The

period for making objections closed on 13 September 2017.

C:5493828v1 63

The Order was made under sections 239, 240, 260 HA and

paras 1(1)(b), (3) and (4) of part 1 of Schedule 2 ALA.

113. As with the Highways Schemes and Orders, so with the CPOs,

modifications have been proposed. In many instances, these reflect the

processes of refinement through discussion referred to above in the context

of the Highways Schemes and Orders and they are relied on as part of the

evidence to justify the confirmation of CPOs as proportionate and

compatible with the human rights of those to be expropriated. 64

114. Three particular modifications merit specific comment here. These are

Modifications 77A and 80, amending the third and fourth Supplemental

Orders respectively (items d) and e) above) and Modification 79 modifying

the main Order (item a) above).

115. Modifications 77A and 80 amend the earlier Supplemental Orders to reflect

the ability to reduce the land take for narrowing of the Junction Cut

consequent upon the agreement between ABP and WG that 13.5m is

acceptable, taken together with the other safety measures proposed.65

116. Modification 79 includes the land south of the former

land which is required for environmental mitigation. The rationale for this is

set out, in brief, in ID/243 and, in greater detail, in the draft Bird Protection

and Mitigation Plan.

117. S.14 and Sched.1, para.5 ALA 1981 authorise the Minister to confirm a

CPO with modifications if all “persons interested consent”. In the case of

the Junction Cut, the relevant interested person is ABP, which consents, as

64 See ID 243 65 Set out in ID 239

C:5493828v1 64

set out above. In the case of the TATA land, there are four such persons –

Tata, National Grid, WPD and SURF Telecoms.

118. ALA 1981 includes several protective provisions relating to particular

classes of land which are of relevance.

119. S.16 ALA 1981 provides as follows:

“16.— Statutory undertakers' land excluded from compulsory purchase.

(1) This section applies where the land comprised in a compulsory purchase order includes land which has been acquired by statutory undertakers for the purposes of their undertaking and on a representation made to the appropriate Minister before the expiration of the time within which objections to the order can be made he is satisfied that—

(a) any of the said land is used for the purposes of the carrying on of their undertaking, or (b) an interest in any of the said land is held for those purposes and the representation is not withdrawn.

(2) The compulsory purchase order shall not be confirmed or made so as to authorise the compulsory purchase of any land as to which the appropriate Minister is satisfied as aforesaid except land as to which he is satisfied that its nature and situation are such—

(a) that it can be purchased and not replaced without serious detriment to the carrying on of the undertaking, or

(b) that if purchased it can be replaced by other land belonging to, or available for acquisition by, the undertakers without serious detriment to the carrying on thereof, and certifies accordingly.”

S.16(1) representations were submitted in response to the first CPO by

ABP and WPD.

C:5493828v1 65

120. ABP also made objections and s.16 representations in respect of the

second, third and fourth Supplemental CPOs. By the end of the inquiry all

relevant representations and the associated objections to the CPOs had

been withdrawn.66 There is therefore no need for any separate reporting

under s.16. However, it is important to note the special status afforded to

statutory undertakers within the statutory scheme for compulsory

acquisition of land, to set into context certain criticisms levelled by

objectors67 of WG’s decision to expend substantial sums of money to

resolve the impacts at the Docks. These comments were not substantiated

and pay no regard to s.16 which affords a high level of protection to the

interests of statutory undertakers.

121. There are no outstanding objections to the Highway Schemes or Orders or

their enabling CPOs from any statutory undertaker.

122. S.19(1) ALA 1981 provides as follows:

“(1) In so far as a compulsory purchase order authorises the purchase of any land forming part of a common, open space or fuel or field garden allotment, the order shall be subject to special parliamentary procedure unless the Secretary of State is satisfied— (a) that there has been or will be given in exchange for such land, other land, not being less in area and being equally advantageous to the persons, if any, entitled to rights of common or other rights, and to the public, and that the land given in exchange has been or will be vested in the persons in whom the land purchased was vested, and subject to the like rights, trusts

66 Details are set out in Annex 1. 67 Most notable, CALM and GWT

C:5493828v1 66

and incidents as attach to the land purchased, or (aa) that the land is being purchased in order to secure its preservation or improve its management (b) that the land does not exceed 250 square yards in extent or is required for the widening or drainage of an existing highway or partly for the widening and partly for the drainage of such a highway and that the giving in exchange of other land is unnecessary, whether in the interests of the persons, if any, entitled to rights of common or other rights or in the interests of the public, and certifies accordingly.”

123. The Scheme requires and the main CPO covers the acquisition of s.19 land

in the form of:

(a) a strip of Registered Common Land running along the

eastern foreshore of the River Ebbw; and

(b) the northern part of the Green Moor Lane allotment site.

124. Exchange land is to be secured, also by way of CPO pursuant to sections

239(5) and 240(6) HA 1980, which expressly authorise the purchase of

exchange land in such circumstances. Mrs Tindale described the proposed

exchange in her written and oral evidence, pointing out that there would be

small gains in area in order fully to mitigate the land take in terms of quality

as well as quantity68. Landscape and Visual and Noise and Vibration

effects were assessed by Messrs Rowson and Evans respectively.69

Consultation has taken place with the Open Spaces Society and Magor

68 Proof WG 1.10.1, paras 7.35 – 7.37; 7.39 – 7.40. 69 Proofs WG 1.8.1 and WG 1.14.1

C:5493828v1 67

and Undy Community Council, neither of whom object to the specific

proposed arrangements, although the Community Council does object to

the Scheme overall and supports the Blue Route.

125. WG accordingly submits that the recommendation to the Welsh Ministers

should be that they can certify that the statutory requirements of s.19(1)(a)

are satisfied.

126. Circular 14/2004 “Revised Circular on Compulsory Purchase Orders” sets

out the principles to be applied when considering a CPO. In order to

confirm a CPO the decision maker has be satisfied that:

- there is a compelling case for acquisition in the public

interest;

- this justifies interfering with the human rights of those

with an interest in the land affected;

- the acquiring authority has a clear idea of how it is

intending to use the land it seeks to acquire;

- the acquiring authority can show that all necessary

resources to carry out its plans are likely to be

available within a reasonable timescale; and

- the scheme is unlikely to be blocked by an impediment

to implementation.

127. The next sections of these Submissions address the criteria laid down in

the CPO circular. In doing so, they will also provide the material to justify

confirmation of the Highways Act Schemes and Orders.

C:5493828v1 68

COMPELLING CASE IN THE PUBLIC INTEREST

Transport Need

128. The Scheme is proposed because of the manifest inadequacies of the

existing M4 between Magor and Castleton. It is WG’s case that the

evidence heard at this Inquiry proves that there is a pressing problem

demanding of a solution, that the only practicable solution is one which

involves an increase in road capacity and that the Scheme is preferable to

the various alternatives which have been considered.

129. In this section, we will focus on the first question; namely, whether there is

a pressing problem which demands a solution. The existing road was

designed and built as the Newport by-pass in the mid to late 1960s and

does not meet modern motorway design standards. It has many lane drops

and lane gains, resulting in some two lane sections, an intermittent hard

and frequent junctions70. Congestion arises with monotonous

regularity during peak hours with the Tunnels presenting a

particular bottle neck71. That bottleneck is aggravated by the proximity of

junctions which can lead to vehicles queuing to leave and access the

motorway. GWT and Cycling UK assert that the problem is simply a peak

hour or, perhaps more accurately, a peak period problem72. This section of

the M4 is, so it is suggested by GWT, no different to any other motorway or

trunk road in the UK in which a degree of peak hour congestion has to be

tolerated. That, however, is a bare assertion which is undermined by the

70 See ID 18 for the detail in respect of hardshoulders and their absence 71 See the heat chart in BW revised proof (WG 1.2.6) page 15/Table 3.3 72 In traffic modelling peak period is a 3 hour period, one in the morning and one in afternoon

C:5493828v1 69

evidence adduced. Mr Bryan Whittaker, who has some 38 years of relevant

professional experience, states that he has not come across another road

which experiences congestion caused by incidents on such a frequent

basis as this section of the M4. The data from the Traffic Wales Unit for

2015 showed that there were 82 incidents unrelated to peak hours

congestion or one incident every 4 or 5 days73. The impact of relatively

mundane incidents, such as a routine breakdown, in terms of traffic flow is

significant precisely because of the sub-standard design of the existing

road such as the absence of hard-shoulders. This was a point corroborated

by the police74: a broken down vehicle can cause mayhem because it

cannot be maneuvered on to a hard-shoulder. Mr Whittaker’s evidence is

further corroborated by the statistical analysis for the relevant section of the

road which was brought to the inquiry’s attention by Mr Tim Gent on behalf

of St Modwen Developments (see PIQ 91, the INRIX report). During the

period 1 April 2016 to 31 March 2017 the experienced

approximately 4 traffic jams per day75. There were, moreover, incidents

whose impact went way beyond peak period congestion – a traffic jam of

some 14 miles and a queue lasting 8 hours76. In short, as well as the

regular and predictable fact of congestion77, there are frequent but wholly

unpredictable incidents which can give rise to very lengthy delays causing

widespread congestion on the broader network. These more serious

73 See BW proof (WG 1.2.6) at page 20/para 3.5.3 74 See the email dated 8 March 2017 from Dave Matthews the Traffic Management Advisor to Gwent Police, supporter 207 75 These will include peak period congestion and inter-peak incidents 76 The 14 mile tail back may or may not have been the queue coinciding with the Wales v Ireland rugby match mentioned by Eddie English in his evidence on 23 March. 77 Even the peak hour congestion is, however, unpredictable. See Figures 13.9 to 13.13 pages 17-19 of BW proof (WG 1.2.6). We shall return to this point in more detail when addressing the economic problems caused by the status quo.

C:5493828v1 70

incidents lead to gridlock within Newport as set out by those who have sent

letters supportive of the Scheme78. In short, the M4 is neither a reliable nor

a resilient network. That something ought to be done in respect of this

problem is a long-standing policy of WG and, before it, the Welsh Office.

We will set out in short form the history below. A proper appreciation of that

history together with an analysis of the latest evidence as to traffic flows

and volumes shows that the GWT’s critique of this Scheme as something

out of the 1960s playbook to be facile.

130. The original M4 was built in the 1960s with two lanes in each direction.

Over time the existing M4 has been widened and re-configured79. The first

assessment of the need for a new road was undertaken in 1990 as part of

the Area Traffic Study (WG 4.1.1). The authors of that Study

accurately foresaw that, in the absence of a comprehensive solution in the

form of a new road, the conditions which have become all too familiar to

road users in this part of Wales would simply continue and worsen. Whilst

the details of recent assessments underpinning the Scheme are different

from those in that early Study, the basic problems and choices identified

are similar.

131. In June 1993 (WG 4.1.11) and July 1994 (WG 4.1.17) documents were

published by the Welsh Office stating that routes to the north of Newport

and along the coast or near to the coast had been assessed and rejected

as options, for reasons set out in the reports. There was a consultation in

1993 in respect of three routes to the south of Newport which, unlike this

78 See BW’s evidence re the wider impact of incidents (WG 1.2.6) pages 20 – 22/para 3.6. Those attending the Inquiry had first hand experience of the gridlock caused in Newport when there is an incident on the M4 on 8 March 2018. 79 Most of the M4 was widened to three lanes, save for the Tunnels, in the early 1980s (WG 4.1.17, para 1.5), junctions 29 to 32 to the west were widened between 2007 and 2010.

C:5493828v1 71

Scheme, ran to the south of Magor. As a result of that consultation, the

Welsh Office decided to consult on a route to the north of Magor80.

Following a second consultation the Welsh Office published a report in July

1995 expressing a preference for a route passing to the north and not the

south of Magor (WG 4.1.19).

132. Little progress was made after 1995, save for modifying the route in 1997

to cater for the LG development, until the WG undertook a comprehensive

route review which led, in 2006, to the preferred route being aligned further

to the north to reduce the impact upon the Gwent Levels SSSIs (WG 4.2.4-

4.2.7). Consultations were conducted as to strategic objectives in 2006 and

2007 but in 2009 the Deputy First Minister announced that the plans for a

new motorway to the south of Newport were not to be progressed as a

motorway would be unaffordable. Significant roadworks were undertaken

between 2009 and 2011 on the existing road between junctions 24 and 28

which consisted of resurfacing, the installation of a concrete central barrier

and the necessary infrastructure to implement the Variable Speed Limit

(VSL) system81. The VSL and associated works alleviated some of the

difficulties experienced but they were not a substitute for a comprehensive

solution to the problems of the M4. Therefore, in September 2010, WG

launched a comprehensive engagement programme relating to the M4

Corridor Enhancement Measures (M4 CEM). This considered more than

100 possible measures in packages including network improvements,

travel planning, demand management and alternative modes of transport.

Following appraisal and option sifting in accordance with the then adopted

80 (WG 4.1.17, paras 8.1 and 8.3) 81 It is for this reason that we do not have traffic flow data for the M4 between 2009 and 2011, Whittaker Figure 3.1, page 6

C:5493828v1 72

Welsh Transport Planning and Appraisal Guidance (WelTAG) there was a

public consultation opening in March 2012 (WG 4.3.5). Consultation took

place on four options including a dual carriageway in broadly the same

corridor as this Scheme (option A), options involving the enhancement of

the SDR82 (options B and C) and widening of the existing M4 (option D).

These various options were considered in the context of a package of

measures consisting of public transport improvements and complementary

measures called Common Measures e.g. to encourage the use of public

transport, active travel etc. The M4 CEM consultation was commended by

the Climate Change Commission for Wales as ‘a good example’ of

engaging a wide range of stakeholders in a position paper on Transport

whose lead author was Professor Whitmarsh83. She confirmed in cross

examination that she stood by that commendation. The upshot of the

consultation and the appraisals undertaken in light of the consultation was

that a dual carriageway to the south of Newport along what became known

as the red route provided the best solution.

133. In 2013, however, discussions between WG and UK government with

regard to finance meant that motorway options became financially feasible.

Accordingly, a WelTAG appraisal was undertaken comparing the red route

dual carriageway with the black route and purple route motorways and

published in the WelTAG report of June 2013 (WG 4.3.15). The main

differences between the purple and black routes pertained to the path over

the Usk and Newport Docks. The purple route went to the north of the

Docks and across the Docks Way Landfill site. The WelTAG report

82 But not the steelworks road which is the other component of the Blue Route 83 Climate Change Commission for Wales, June 2012 PIQ 78

C:5493828v1 73

recommended progressing with the black route as the preferred route. In

due course WG announced and published a draft Plan which, following a

period of consultation and Strategic Environmental Assessment (“SEA”),

was adopted in July 2014.

134. Having reached this stage in the chronology it is perhaps worth exploring

the position of some of the main protagonists in this inquiry to the question

of whether this section of the M4 was a problem in need of a pressing

solution. In December 2013, the Institute of Welsh Affairs published a

report authored by Professor Stuart Cole entitled ‘The Blue Route: A cost

effective solution to relieving M4 congestion around Newport’84. The paper

was sent to the relevant Welsh Minister Mrs on 9 December

2013 by a number of NGOs including GWT and Friends of the Earth

Cymru85. Accordingly, GWT and Friends of the Earth Cymru were, at that

stage, commending the IWA report86.

135. In terms of there being a problem in need of a solution ‘The Blue Route’

stated:

“There is a consensus that additional capacity is required to cope with

peak period on the M4 around Newport. There are

three main reasons:

- The Brynglas Tunnels on the M4 directly to the north of Newport

are an acute pinch-point, reducing a six-lane motorway to four

84 On 12 July 2013 Wildlife Trusts Wales wrote to WG to say that Professor Stuart Cole had been commissioned to prepare a paper. Professor Cole gave evidence to the Environment and Sustainability Committee on 6 November 2013 (see WG’s December 2016 Appraisal of the Blue Route (WG 6.2.35) page 9/3.1.1 to 3.1.3) 85 See Appraisal of Blue Route (WG 6.2.35) page 11/3.1.7 86 James Byrne is acknowledged for his assistance with regard to site knowledge and peer review, page 23 of ‘The Blue Route’.

C:5493828v1 74

lanes. There have been many instances when there have been

closures due to traffic incidents at this sport. For instance, in

July 2011 the M4 was closed for two days after a lorry caught

fire in the Brynglas tunnels. Nearby structures – the Usk Bridge

to the east of the Tunnels and the canal bridge to the west –

accentuate the difficulty of any road-widening project.

- There were faults in the original design of the Newport northern

by-pass/northern distributor road, later linked to the M4,

including the lack of a hard shoulder for some of its length. This

reduces its capacity for current traffic volumes.

- The M4 is used by local traffic as a local distributor road for

short journeys within the local urban area.87”

136. In oral evidence, Professor Cole confirmed what was implicit in ‘The Blue

Route’88 which is that his report was informed by actual traffic data along

this section of the M4 up to and including 2012. The factors identified in the

above quotation remain pertinent. Indeed, due to the significant growth in

traffic since 201289 the problems are more acute than they were when the

report was published and, just as importantly, more acute than had been

anticipated. Professor’s Cole prediction in respect of traffic flows of a “low

percentage increase but with the current plateau demand pattern

87 Extract from page 5 of ‘The Blue Route’ 88 Figure 6 at page 17 of ‘The Blue Route’ 89 See Bryan Whittaker’s revised proof (1.2.6) pages 5-6, Tables 3.1 & 3.2

C:5493828v1 75

continuing for some time”90 has not come to pass. The acknowledgment in

2013 of a problem in need of a solution fundamentally undermines the

proposition, if such is advanced by GWT and others, that there is no need

for a significant investment of some form to alleviate the current and future

problems afflicting this section of the M4.

137. Certain economic consequences flow from the existing problems along the

M4 corridor. As well as the evidence of Mr Steve Bussell cogent evidence

was provided by WG’s chief economist Jonathan Price, the CBI and the

Chambers of Commerce of South Wales as to the significant economic

harm which ensues from the status quo. As we will set out in the section

addressing economics none of this evidence was effectively challenged91.

There are, furthermore, human health advantages implied by the Scheme

in terms of alleviating noise and air pollution along the heavily population

sections of the existing M4.

138. There is, in short, a problem which demands a solution. There is a policy

commitment to delivering “a significant improvement to the M4 around

Newport”92. WG aver that this Scheme constitutes the appropriate solution

to that problem. A number of arguments have been adduced by objectors

in contesting WG’s case for the Scheme. They include arguments that:

i. The Scheme is based on erroneous traffic forecasts;

ii. Induced traffic has not been properly considered and/or will render

the Scheme self-defeating;

90 The Blue Route page 21 91 Professor Calvin Jones accepted, for instance, that the CBI and the South Wales Chamber of Commerce were correct to opine that the Scheme would help their members. 92 Prosperity for All, page 21

C:5493828v1 76

iii. Peak car renders a new motorway unnecessary;

iv. The advent of connected and autonomous vehicles mean that, in

future, the existing road will have sufficient capacity;

v. The UK government’s announcement that the prohibition of the sale

of diesel and petrol cars in 2040 somehow undermines the case for

the Scheme;

vi. Modal shift in the form of further public transport and active travel

provision is a sufficient and better solution;

vii. The claims that the Scheme will promote the Welsh economy are

erroneous and/or illusory and the Scheme may actually hinder the

Welsh economy;

viii. The Scheme is a carbon intensive development contrary to WG’s

duties under the WFG Act 2015, the EWA 2016 and inconsistent

with global agreements re climate change;

ix. The Scheme’s impact on the Gwent Levels is such that the Scheme

is contrary to WG’s duties under the Future Generations Act 2015,

the Environment (Wales) Act 2016 and other environmental

legislation.

139. We will address each of these arguments in turn. None stand up and they

do not, therefore, undermine WG’s case that there is an overwhelming

case in the public interest justifying the acquisition of land by compulsion.

The final objection concerning the FG Act and the other statutory

environmental duties will addressed in a later section.

Traffic forecasts, induced traffic and peak car

C:5493828v1 77

140. These matters are closely associated with one another and will be treated

together. All are properly the subject of expert opinion. Some elements,

moreover, are subject to the Bushell principle. WG relies upon the evidence

of Mr Whittaker. GWT relied on a number of expert witnesses who gave

opinions on these matters though many seemed to have only a superficial

knowledge of the topics and the lead expert was Professor Whitelegg.

Cycling UK relied upon Professor Cole and Dr Melia. Others who gave

evidence on these included Robert Waller, Pippa Bartolotti and T N D

Anderson of Pace Transportation Ltd.

Traffic forecasts

141. The long-term traffic forecasts published by the in

1989 and 1997 predicted a quantum of increase in traffic significantly

higher than the increase which actually occurred. It is these forecasts which

are relied upon by objectors in support of the proposition that the Scheme

relies upon exaggerated predictions of future traffic growth. Mr Whittaker

agrees that these forecasts overstated future traffic though he pointed out

that DfT predictions do not and cannot take into account fluctuations in

growth consequent upon the economic cycle. To that end the impact of the

recession of the early 1990s and the more significant depression which

started in 2008 on traffic volumes do not, of themselves, constitute a

critique of the DfT’s forecasts. Mr Whittaker also pointed out, moreover,

that the DfT’s forecasts did not always over-predict traffic growth. Indeed,

C:5493828v1 78

the forecasts in 1980 and 1984 significantly underestimated the traffic

growth which was experienced in the 1980s and which no doubt influenced

the very much higher estimates reached by DfT in 1989. It is simply

factually incorrect, therefore, to state that the DfT always overestimates

traffic growth.

142. The Scheme, of course, does not rely on the forecasts of 1989 or 1997.

Rather, in accordance with WG policy, the traffic modelling is based on the

latest DfT growth factors in the National Trip End Model (NTEM). The data

in NTEM is accessible via computer software provided by the DfT called

TEMPRO. The PLI was due to commence in November 2016. The

evidence and assessments had been prepared based on TEMPRO 6.2 but

the inquiry was adjourned in order for WG to consider a revised version of

TEMPRO and to produce economic, traffic and environmental reports

based on the latest DfT traffic growth factors. Those growth factors provide

a lower estimate of future traffic growth. The WG’s evidence and reports

are based on TEMPRO 7.1 Interim for Wales. On 1 March 2017 TEMPRO

7.2 was published and though there are differences between TEMPRO 7.1

Interim for Wales and TEMPRO 7.2 they are negligible (see PIQ 4). WG’s

case is based, therefore, on the latest DfT forecasts. In one sense, there is

little more to be said. In accordance with established WG policy the

Scheme has been assessed against the latest government forecasts and

those cannot be challenged pursuant to the Bushell principle. Nevertheless,

the allegation that the Scheme is predicated upon exaggerated traffic

forecasts was addressed in evidence and cannot go unanswered.

C:5493828v1 79

143. Bryan Whittaker explained that the latest NTEM is posited on a fall in trip

rates between 2011 and 2016 with trip rates staying constant thereafter93.

Trip rates, it should be pointed out, relate to the number of trips undertaken

by individuals regardless of the mode of transport – walking, cycling, public

transport or private motor vehicle. The growth factors take heed of the fall

in trip rates for certain purposes in the period 2003 to 2010 which are

apparent from the National Travel Survey e.g. a fall of 6% and 10% in

respect of shopping and commuting respectively94 and assume that those

trends will continue until 2016. The latest NTEM, moreover, though still

maintaining a relationship between travel growth and factors such as

incomes, costs and population takes into account other factors as well95.

Insofar as regional accuracy of the growth factors is concerned the NTEM

takes into account detailed planning data and that too is a departure from

the methodology employed in producing NRTF 89 and NRTF 9796.

144. The objectors are therefore arguing against a straw man when asserting

that DfT forecasts systematically overestimate traffic growth. The criticism

is of NRTF 89 & 97, neither of which plays any role in WG’s economic,

environmental or traffic case. Furthermore, the NTEM has been very

substantially revised in terms of methodology and takes into account recent

changes in patterns of work, shopping, car ownership and so on and posits

the continuation of such trends beyond 2010. There was not a single

specific evidential criticism of DfT’s latest forecast.

93 BW revised proof (WG 1.2.6) page 53/9.3.5 94 BW revised proof page 52/9.3.4 95 BW revised proof page 52/9.3.2 96 See POPE page 38/penultimate paragraph

C:5493828v1 80

145. It may be useful to say a little at this stage about the National Travel

Survey. Mr Waller gave evidence in respect of this towards the end of the

inquiry97. In his evidence, he identified a number of trends in respect of

travel patterns and behaviour. Across a range of metrics travel by motor car

appears to have stabilised or decreased and this, so the argument goes,

gives rise to the need to be cautious about future traffic volume growth.

There are a number of difficulties with what looks, at first blush, to be a

plausible and common-sense argument. First, these trends are not new.

They are trends which became apparent in the mid 1990s and the early

2000s. If one looked at these metrics in isolation one would have expected

traffic growth to have stopped or even reversed. But, in fact, traffic volumes

on the M4 have grown consistently since 2011. The inference which Mr

Waller and others invite the inquiry to draw from these trends is

contradicted by data relating to observed traffic on the M4. Secondly, the

Department for Transport is cognisant of these trends and Mr Whittaker

has confirmed that TEMPRO 7.2 takes them into account; for example, a

decline in trip rates is assumed for 2010 to 2016 with stable trip rates

thereafter. In short, there is nothing in the NTS to undermine the core

scenario forecast in the M4CaN traffic model.

146. The TEMPRO 7.2 growth factors relate to the years from 2010 onwards. To

that end it is possible to ascertain whether those growth factors

overestimate actual growth at least for the 6 or 7 year period up to the

present day. As to that Mr Whittaker stated that the latest version of the

NTEM predicted a growth in traffic on motorways in Wales of 6.9%

97 8 March 2018

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between 2010 and 201598. Though no actual data is available for 2010 it is

apparent that growth on the relevant section of the M4 for the 5 year period

between 2011 and 2016 varies between 6.1% and 14% with a median

growth rate of 12.3%. Though the comparison between 2010-2015 and

2011-2016 is not exact it seems clear that the latest NTEM does not

overestimate growth on this section of the M4. In conclusion, the

proposition that WG’s case is based on exaggerated estimates of future

traffic growth is demonstrably false: a matter which is established by the

incontrovertible actual traffic data available on this section of the road since

2011. It is also, as noted earlier, caught by the Bushell principle.

Peak car

147. This is a variation on the theme that the case for the Scheme is based on

exaggerated traffic forecasts. Wales, it is said, is a developed country and

there is widespread evidence across the developed world that use of the

car has peaked or plateaued. As with the argument that the traffic forecasts

were exaggerated, peak car was often deployed as a slogan: the argument

was not developed with any clarity or precision beyond citing the name of

Professor Phil Goodwin. Mr Whittaker did, however, address the argument

in his rebuttal evidence99.

148. The starting point in considering peak car is to define it: it is the hypothesis

that per capita car use is close to its maximum and may stabilize or turn

down. If the population is growing, therefore, traffic will continue to

increase. Accordingly, more road capacity will be required to provide the

98 PIQ 18, page 6/2.10 99 See BW’s rebuttal of Prof Cole pages 8-9/3.1.10 – 3.1.12

C:5493828v1 82

same level of functionality even if the hypothesis is true. The second point

to note is that unqualified assent or dissent to the hypothesis betrays a

misunderstanding of both the theory and transportation in general. As Mr

Whittaker points out, in a densely urban metropolis such as London per

capita car use may well have stabilized. But this Scheme is not situated in

London. Across the UK aggregate vehicle kilometres continues to grow and

that growth is greater on motorways and rural A roads100. Of even greater

relevance, there has been growth in excess of 2% per annum on this

section of motorway since 2011. The vehicular journeys which are being

undertaken less frequently tend to be the shorter trips101. The actual local

data, therefore, undermines the argument that the peak car hypothesis

applies to this section of the M4. Similarly, the broader patterns discerned

across the UK in terms of traffic volumes and the National Travel Survey

support the proposition that traffic volumes will increase along this section

of the M4 and that, absent a solution, the existing serious problems will

only get worse.

Induced traffic

149. A considerable amount of heat has been generated by the issue of induced

traffic. The question is not whether the phenomenon exists - it does – but

rather how significant it might be in quantitative terms in the context of this

Scheme. To the extent that it occurs would its consequences be good, bad

or indifferent?

100 BW rebuttal of Prof Cole page 8/3.1.10 101 BW revised proof (WG1.2.6) page 52/9.3.4

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150. In GWT’s closing much is made of induced traffic. Building this Scheme, it

is said, would be self-defeating:

“Evidence from around the globe shows that building motorways to

fight congestion doesn’t work. Building a motorway to ease congestion

has been likened to ‘loosening your belt to fight obesity’. It may provide

short-term relief, but soon afterwards the extra road capacity generates

more traffic than there was before. In the long term motorways just

allow congestion to grow further: they don’t reduce it.”102

“Professor Whitelegg stated that any objective assessment of the

weight of evidence, both scientific evidence and public policy, would

lead inevitably to the rejection of a proposal that claimed economic and

social gains from a large item of transport infrastructure. It would

further reject the assertion that such investments could maintain

accessibility improvements over time as traffic levels rise and

erode the temporary gains made in the few months following the

opening of the scheme.”103

151. The section in bold is a reiteration of paragraph 48 of Professor Whitelegg’s

proof of evidence. Professor Whitelegg was closely cross examined on that

proposition and on his other evidence regarding induced traffic. He did not

take the opportunity to resile from what is a demonstrably absurd

statement. On that point, and in general, Professor Whitelegg’s evidence

102 page 9 of GWT closing 103 page 53 of GWT closing. Italicisation added by the authors of this closing.

C:5493828v1 84

was unsatisfactory. The inquiry is invited to prefer Mr Whittaker’s evidence

in its entirety. Before, however, making further points about the reliability of

individual witnesses it is necessary to define what is meant by induced

traffic in different contexts and to say something of the various reports

referred to by the witnesses. It will become apparent that the term is used

differently in different contexts by different people.

152. POPE104 defines induced traffic as follows:

“Highway improvement schemes can impact upon traffic patterns over

a significant area, leading to a number of demand responses. Changes

in traffic flows on a road after the implementation of a scheme could be

for a range of reasons including:

- General background traffic growth (that would have happened

with or without the scheme);

- Reassigned traffic (people changing their route);

- Mode change (i.e. switching to or from public transport);

- Destination change;

- Time of travel change;

- Trip frequency increase; and

- Generated or new trips (e.g. from different land use patterns)

In the context of POPE, changes in background traffic growth and

reassigned traffic can be identified using observed data. It is not

104 Post Opening Project Evaluation (POPE) of Major Schemes

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possible, however, to distinguish between the other reasons for traffic

flow changes listed above. For the purpose of this analysis, therefore,

additional traffic due to changes in mode, destination, time and

frequency, as well as new trips, are considered to be ‘induced’

traffic.”105

153. This is also the definition used by the CPRE report106. A number of things

are worth noting in respect of this definition. First, changes in destination

may or may not increase the aggregate amount of vehicle kms. If someone

who shops in Bristol because they are deterred by congestion from

shopping in Cardiff switches to Cardiff once the Scheme is built a trip to

Cardiff is induced but the trip to and from Bristol is avoided and there may

or may not be an increase in distance travelled – this type of effect is not

undesirable per se107. Secondly, a change in the timing of a trip counts as

an induced effect though what would amount to a reversal of peak-

spreading would not have any impact on distance travelled or even the

route travelled – such a change may be a good thing108. A change in mode

due to a new road would, all other things being equal, be a bad thing on the

presumption that the change of mode was from public transport or active

travel to a private vehicle. An increase in trip frequency implies, all other

things being equal, more vehicle kms. As for new trips due to land use

changes even those trips will not unambiguously increase aggregate

105 Page 53 of POPE 106 See page 13 of CPRE. The summary is ID 27 107 In this instance the induced traffic would be good from the point of a view Cardiff shops, bad from the point of view of Bristol shops and good from the consumer’s point of view. 108 Workers are able to travel to work at their preferred time and don’t have to get in early just to avoid congestion

C:5493828v1 86

vehicle kms because the new trips may be substitutes for trips which are no

longer undertaken (and which may be longer or shorter). Accordingly,

induced traffic is not necessarily a bad thing from the perspective of

aggregate vehicle kms as one has to take into account the trip which is

forsaken as a result of the induced trip. And, as the evidence relating to this

Scheme shows, vehicle kms cannot, without more, be taken as a

barometer for carbon consumption – vehicle kms travelled in less

congested circumstances involve less production of carbon. Furthermore,

those aspects of induced traffic which are unambiguously undesirable from

a carbon/sustainability point of view such as a proliferation of out of town

shopping centres are subject to control under the planning system. Induced

traffic can also have positive social and economic effects. A person taking

up a new employment opportunity as a result of lower travel times will be

undertaking an induced trip; but the new job is a benefit both to the person

undertaking the trip and to the wider economy. It is accepted, of course,

that induced traffic can have disadvantages and may in certain

circumstances depress the BCR for a new road109. The important point is

that the topic is complex and the effects have been modelled in respect of

the Scheme and taken into account in the economic appraisal.

154. Another point which flows from the above definition and a proper

understanding of induced traffic is the one made by Bryan Whittaker under

cross examination by Cycling UK110 which is that there is no single and

definitive way of measuring an induced effect – the results will depend on

the geographical area one considers. For instance, in ID 43 Bryan

109 Because new or induced motorists add to congestion thereby increasing journey times for those who would have undertaken the trip regardless of the new road. 110 4 May

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Whittaker sets out the induced traffic across a screenline represented by

the river Usk and compares the extent of induced traffic under the Scheme

(4.2%) and under the Blue Route (3.3%). In the no toll scenario ID 43a the

figures are 5% and 3.8% respectively. This represents the extent of the

induced traffic across the screenline. What it does not do, however, is

capture all of the trips which are forsaken as a result of, for example, a

change in destination from B to C111. A broader measure of the net impact

of the Scheme on vehicle kms is captured by the evidence provided by Mr

Whittaker.

155. Table 2112 in Mr Whittaker’s proof dealing with the abolition of the tolls sets

out the difference in aggregate vehicle kms travelled as between the Do

Minimum and Do Something in 2022, 2037 and 2051 in the AM peak, the

inter peak and the PM peak over the whole of the modelled area. Under the

Do Something scenario that analysis captures the increased vehicle kms

as a result of induced trips as well as the decrease in vehicle kms in

respect of trips which are no longer undertaken within the modelled area.

Importantly, however, it also captures the decrease in vehicle kms in

respect of traffic which reassigns from the old M4 to the new road and the

new road is 2.8 kms shorter. So there will be a decrease in vehicle kms for

all those vehicles who would travel from A to B in any event and have

switched from the old road to the new road.

156. The relative scale of these countervailing impacts are shown to some

extent in ID 43a. In 2037 the two way AADT across the new Usk crossing

under a fixed demand model is 68,878. That is all traffic which has

111 Some of those will be captured e.g. if B and C involve crossing the screenline. 112 Page 8 of WG 1.2.6

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reassigned from other routes (mostly but not wholly the old M4). To the

extent that the traffic is through traffic which has reassigned from the old

M4 to the new road then there is a 2.8 km distance saving. The induced

traffic over the new Usk crossing is the difference between the fixed

demand and VDM AADT which is 6,944. There is induced traffic over the

other routes crossing the Usk as well but that provides a flavour of the

extent of the induced traffic. Finally, what ID 43a does not do is identify

those trips which are forsaken as a result of the Scheme and which did not

cross the Usk e.g. shopping or commuting trips from Monmouthshire to

Bristol which are replaced by trips to Cardiff.

157. Mr Whittaker has, therefore, provided evidence of the net increase or

decrease in aggregate vehicle kms within the modelled area and he has

also provided a measure of the induced traffic across the screenline. His

evidence rebuts the two discrete critiques of the Scheme based on induced

traffic.

158. The first critique is the one quoted in paragraph 150 hereof which is that it

will lead to an increase in traffic along the corridor to such an extent that

the effort to alleviate congestion by additional road traffic is self-defeating.

The second critique is that induced traffic will lead to a significant increase

in aggregate vehicle kms and thus to an increase in user carbon. This

carbon critique of the Scheme is misconceived unless the focus is on the

overall net increase or decrease in vehicle kms. In other words the focus

should be on any net increase in aggregate vehicle kms having regard to (i)

induced trips, (ii) the impact of reassignment and (iii) the impact of trips

which do not take place due to changes in destinations. The witnesses

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called by GWT and Cycling UK did not address in their written evidence

factors (ii) and (iii) and under cross examination were reluctant to

acknowledge the obvious and beneficial implication, all other things being

equal, of the Scheme being shorter than the existing M4.

159. Before addressing the two critiques separately it is necessary to make

some general observations as to the credibility of the witnesses who gave

evidence as to these matters. Neither Professor Cole nor Dr Melia on

behalf of Cycling UK nor Professor Whitelegg on behalf of GWT had the

professional competence to construct a traffic model of the kind built by Mr

Whittaker and his team. It is perhaps not surprising, therefore, that there

was no specific criticism either of the traffic modelling or of the evidence

adduced by Mr Whittaker as to the additional vehicle kms or the induced

traffic across the river Usk screenline.

Professor Whitelegg

160. In his proof of evidence Professor Whitelegg adopts both strands of the

induced traffic critique though the focus is on the first critique. He states

that “a large amount of induced traffic will usually have the effect of

cancelling or minimizing the travel time savings that have been predicted

for a road scheme”113. Though he does not provide any opinion as to the

magnitude of the induced traffic which he foresees he concludes:

113 Para 32

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“For the avoidance of doubt it is my settled view that the decision

making process around the M4 relief road cannot be regarded as

sound and reliable if it does not follow the findings of the SACTRA

1994 report and the detailed empirical evidence presented in the

CPRE, 2006 report “Beyond Transport Infrastructure” report and the

detailed review of induced traffic by an acknowledged expert in this

field…Induced traffic renders the VFM calculations unsound and

undermines the BCR and it would not be the in the best traditions of

evidence-based UK decision taking on major investments to proceed

with a very expensive project that is based on deeply flawed

calculations.”114

161. There is no acknowledgment in Professor Whitelegg’s proof that the

M4CaN model is a variable demand model (VDM) and that induced traffic

has therefore been taken into account in the traffic results and the BCR. In

evidence in chief he stated that SACTRA 1994 was the gold standard and

that it was the basis for his critique. In cross examination, however, he was

unable to identify the primary recommendation of SACTRA 1994 and when

it was suggested to him that it was that variable demand modelling (VDM)

should be adopted he was still unable to express his assent or dissent to

that proposition. This was a stark illustration of Professor Whitelegg’s lack

of familiarity with the core research literature and his ignorance of the work

carried out by the experts in the project team. The fundamental

recommendation of SACTRA 1994 is for fixed trip matrix appraisals to be

114 Para 37

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abandoned115. That recommendation has been followed in constructing the

M4CaN traffic model as would be apparent to anyone who had read the

relevant report116.

162. By the time he came to give oral evidence Professor Whitelegg was aware

that the model took into account induced traffic117. But he did not take this

on board at all in refining or qualifying his critique that the new road would

be self-defeating. He was unable to identify any flaw in Bryan Whittaker’s

model or in his evidence.

163. SACTRA 1994 concluded that “induced traffic can and does occur,

probably quite extensively, though its size and significance is likely to vary

widely in different circumstances”118. It is because induced traffic varies so

much that the effect needs to be modelled. And that is what Mr Whittaker

has done. Professor Whitelegg’s attention was drawn to the capacity of the

new road when challenged about the proposition advanced in paragraph 48

of his proof; namely, that the congestion relief provided by the new road

would be ephemeral. Whilst he eventually conceded that the capacity of the

new road was greater than that of the existing road he did not make the

clearly appropriate concession that induced traffic in excess of the

magnitude identified in SACTRA 1994119 would not lead to congestion

returning to previous levels along the corridor in a matter of months or

years. While the model is robust no-one supposes that it is likely to be

115 Page 208, paragraph 15.25 of SACTRA 1994 116 Local Model Validation Report November 2015 (WG 2.3.9) 117 It was a point made by BW in his rebuttal of Professor Whitelegg’s evidence page 20/2.3.1/4 118 SACTRA 1994 page 168, paragraph 11.16 and quoted in WG rebuttal of Professor Whitelegg page 19/para 2.3.1/1 119 The average induced traffic figures of 10% in the short run and 20% in the long run are not set out in SACTRA 1994 but have been produced by Professor Goodwin who was a part of the committee who produced the report.

C:5493828v1 92

precisely correct. But the level of induced traffic which it forecasts could be

wrong by a factor of 10 and the new road would still provide very

considerable congestion relief in the long term. In short, we submit that the

proposition that the Scheme would be self-defeating as a consequence of

induced traffic is demonstrably false. Induced traffic as well as increases in

background traffic growth will have an impact in eroding to some extent

travel time savings as is apparent from the journey time tables120. But these

impacts have been quantified and it is clear that background traffic growth

is more important than the induced traffic effect because the time savings

between Do Something and Do Minimum increase rather than decrease

over time.

164. As for the proposition that induced traffic will increase user carbon

Professor Whitelegg’s reasoning is set out at paragraph 17 where he

states:

“…as I show in section 4 of this proof of evidence these greenhouse

gases will be larger than those associated with current traffic levels

because of the phenomenon known as ‘induced traffic’. New roads

generate new traffic and this is discussed in s 4”

165. We will not repeat the criticism of Professor Whitelegg’s evidence on

induced traffic. An equally fundamental flaw is his disregard of the carbon

effects of reassigned traffic. Vehicles which reassign from the old road to

the new road will travel a shorter distance and hence, all other things being

equal, burn less fuel. All other things, however, are not equal because

120 See WG 1.2.7 page 14, table 7 for through traffic journey times up to 2051

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under the Do Something scenario there will be less congestion and fewer

accelerations and decelerations and therefore vehicles will travel in a more

fuel efficient manner. The impacts of congestion alleviation compound the

savings in terms of distance travelled insofar as reassigned traffic is

concerned.

166. In short, neither limb of the induced traffic critique of the Scheme stands up

to scrutiny. The notion that the new road would become as congested as

the existing road within a matter of months is absurd. Mr Whittaker’s model

is a variable demand model which takes into account induced traffic and

the results for the design year show that the new road will still be free-

flowing121. Similarly, Mr Whittaker has produced tables relating to

aggregate vehicle kms, trips and vehicle hours within the modelled area.

There are increases in terms of aggregate vehicle kms but they are

extremely modest. These tables capture all of the countervailing effects of

the Scheme on distance travelled. It is of note that aggregate vehicle hours

within the modelled area falls as a result of the Scheme and that is

because traffic in the entire area benefits from congestion relief122. Mr

Chapman’s carbon analysis shows that, due to less congestion, the

Scheme will result in less user carbon being expended.

Connected and autonomous vehicles (CAVs) and electric cars

167. Many of the objectors have raised the prospect of connected and

autonomous vehicles as a technological innovation which will render the

121 There is a decline in journey times but nothing which suggests that the new road would be blighted by congestion. 122 Table 3 at page 8 of WG 1.2.7

C:5493828v1 94

Scheme redundant. CAVs are vehicles that drive themselves. If and when

all vehicles on the highway network become CAVs then it is anticipated that

the capacity of the network will increase because of the lower headway

between vehicles123. This was first raised by Professor Calvin Jones and

Pippa Bartolotti. Others have adopted the same point including the FG

Commissioner. There is a great deal of uncertainty in respect of the rate of

progress of this technology and its impact on network capacity prior to all

vehicles becoming CAVs. The research is summarized in Mr Whittaker’s

section of WG’s response to the FG Commissioner’s first written

statement124.

168. The impact of CAVs on network performance is anticipated to become

much greater as the proportion of CAVs in the vehicular fleet increases.

That gives rise to the notion of a tipping point where network performance

will increase substantially. The research published by the DfT in May 2016

suggested a tipping point somewhere between 50% and 75%. In terms of

relieving congestion that research predicted a 7% improvement in delay

with 50% of vehicles being CAVs, with a 40% improvement in delay with a

fully automated vehicle fleet. As to when significant penetration may occur

Mr Whittaker refers to the paper presented at the European Transport

Conference 2016 which summarized the outcome of a ‘Delphi’ survey of

global transport professionals. The mean prediction for when CAVs would

reach 10% of the vehicle fleet was 2032, with a prediction for 20%

penetration of 2040. With penetration of 20% the experts predicted an

increase in network capacity of 10%. While there is a great degree of

123 Headway is the distance between vehicles as they travel. The two second rule would be reduced to a fraction of that if all vehicles were CAVs. 124 ISU0024 September 2017, pages 44 to 47

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uncertainty the best evidence appears to be that CAVs may increase the

carrying capacity of the existing M4 by 10% in 2040; traffic volumes grew

by more than that in the 5 year period between 2011 and 2016. In short,

CAVs do not provide a solution or even a material part of any solution for

the foreseeable future. There is, moreover, a Bushell point here: no doubt

because the potential impact of CAVs is distant and uncertain no provision

is made in government guidance for predicting any congestion relief as a

consequence of CAVs.

Public transport investment and modal shift as a solution or alternative

169. The feasibility of resolving the current problems on the M4 through public

transport and active travel measures was explored in detail during the M4

CEM process. In 2013 a public transport appraisal concluded that a

doubling of public transport utilization in and around Newport would only

remove up to 5% of the traffic from the M4125. An updated Public Transport

Overview concluded that, with elements of phases 1, 2 and 3 of Metro, and

the park & ride scheme at Llanwern the upper bound assessment of traffic

extracted from the M4 during the PM peak hour would be less than 4%126.

This analysis was progressed further to include an assessment of the

impact of Rapid Bus Transport in Newport; WG’s evidence on the potential

for public transport measures to extract traffic from the M4 is set out in

ID73. The peak hour abstraction of traffic from the existing M4 is, at most,

5.9%.

125 Document WG 4.3.16 cited in Matthew Jones’s main proof WG 1.1.1 at page 42/9.1 126 The Updated Public Transport Overview is document WG 2.4.19. This is summarised in ID73.

C:5493828v1 96

170. This level of relief will not be sufficient to solve the long-term problems of

the M4. It amounts to about 3 years’ traffic volume growth. The public

transport measures which have been assessed in ID73 include all those

which are feasible and which bear on east-west traffic. Some of the

measures are committed as part of Metro, others are not and are more

speculative. WG is committed to Metro which brings significant benefits

over and above those which would pertain to the M4. It is, moreover,

largely, but not wholly, a package which will facilitate north-south travel and

not east-west travel. The response of objectors has been to say that there

should be even more investment in public transport and that if there were

more investment then the rate of abstraction would be greater. The

difficulty with this argument is that increasing the quantum of user of public

transport requires provision which is feasible, affordable and which will be

attractive to those who would otherwise use the M4. The measures which

are already committed parts of Metro are precisely those measures which

are the most feasible, attractive to travellers and therefore provide better

value for money. No public body would invest first in those measures

whose returns are low and leave the most feasible, affordable and

attractive public transport measures until a later time. Accordingly, the

argument that one should simply increase public transport provision until it

is sufficient to solve congestion on the M4 won’t do. Provision which is

feasible and is attractive to travellers and hence provides decent value for

money will become increasingly hard to find once those measures in Metro

have been implemented. The law of diminishing marginal returns applies

and thus doubling the amount of investment in PT will not double the

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amount of patronage or the extent of abstraction of traffic from the M4127.

During the M4 CEM process the WG looked very closely at the feasibility of

solving the problem with public transport measures. The exercise was

undertaken again during the course of this inquiry and all measures, both

committed and those which are more speculative, which could contribute to

solving the problem were assessed. With ambitious assumptions in favour

of the efficacy of public transport measures the abstraction is 5.9%128. It

should also be borne in mind that some of this abstraction is already

included in the M4CaN traffic model129.

171. The law of diminishing marginal returns was illustrated by the evidence of

Ms Bartolotti and Mr Anderson in respect of light rail provision. At first

blush, a tram which has many stops between Magor and Castleton has its

attractions until one considers the costs of the infrastructure, the ongoing

subsidy requirement130, the land required and the delays caused by

multiple stops which may undermine the attractiveness of the tram. In

short, there is no evidence before the inquiry to suggest that there are

practicable public transport measures which could take a significant

proportion of vehicles from the existing M4. It is easy, moreover, to

overlook freight but in practice HGVs are the only viable option in most

cases for the movement of goods. The only robust evidence is that

adduced by the WG and making all reasonable assumptions in favour of

127 See Mr Whittaker’s evidence under cross examination from Mr Waller on 20 March 2018 and ID156b subsequently adduced by WG. 128 The lower bound figure is 3.2%. See para 13 of ID 73. 129 See para 5 of ID 73. The level of abstraction already included in the modelled flows for peak hour PM in 2037 is in the region of 1.2 to 2%. 130 Existing rail services in Wales are subsidised by Government; it is likely, therefore, that any light rail/tram service would also require a subsidy

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public transport the degree of abstraction is no greater than 6% during

peak hours.

Alternatives

172. Twenty nine alternatives have been advanced and examined during the

course of the inquiry. A number have been withdrawn131. Of those which

remain the approach which the inquiry ought to take to their assessment is

set out in the Advice for Inspectors – Transport Orders132 at paragraphs

2.50, 2.51, 2.166, and 2.167 set out below:

“2.50 It is not the role of the Inspector to make a recommendation in favour of an alternative proposal. However, the Inspector must understand any alternatives proposed sufficiently well to be able to decide whether they appear to be worth further investigation. An important factor in such decisions will be whether or not the alternative would overcome or sufficiently mitigate some deficiency in the Order proposal that would otherwise render it incapable of passing the statutory tests. Should he or she come to the conclusion that an alternative proposal before the inquiry warrants further investigation as compared with the order proposal, it would clearly not be logical to recommend the making or confirmation of the orders.

2.51 When an alternative route is considered at an inquiry, the promoters should produce an evaluation of the merits and practicability of the alternative proposed, whether it would meet the aims and objectives set for the original scheme, taking into account its comparative impacts on the environment and adjoining owners, and comparative costs. When considering comparative costs, there will usually be an assessment of the cost of the delay, which would follow from considering an alternative scheme. An alternative would no doubt

131 Those withdrawn are alternatives 8-10 and alternatives 13-17 132 ID 240

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require detailed design work, followed in all probability by the preparation of new orders and the holding of a new inquiry. The assessed cost of delay is therefore often very substantial. In Smith & Others v SoS for Transport and Barnsley MBC (1995 QBCOF 95/1433 – 4D) the Court of Appeal held that delay and its costs could be a material consideration to be weighed along with all others in considering whether an alternative should be further considered, but that except in special circumstances it should not be regarded as an overriding and decisive factor. Decisions should be based upon what is appropriate in the public interest, and therefore all relevant factors should be taken into account.

2.166 Although the Inspector is not in a position to make a recommendation in favour of any alternative proposal, any such proposal (and any counter-objections to it) must be given due consideration, and its apparent advantages and disadvantages compared with the published proposal. This is because the Inspector will need to advise the SofS/WM on whether the alternative in question appears to warrant further investigation where the Inspector comes to the conclusion that, whilst the original proposal may be justified in principle, the objections made against it are sufficiently overwhelming to lead the Inspector to recommend against it.

2.167 There will then follow an overall judgement on the proposal, together with the reasoning which leads to any recommended modification, bearing in mind the submissions and objections made, any relevant policies and any criteria specified in the enabling Act. “

173. In determining whether the alternatives are worthy of further investigation

“an important factor …. [is] whether or not the alternative would overcome

or sufficiently mitigate some deficiency in the Order proposal that would

otherwise render it incapable of passing the statutory tests”133. The same

point is put in even more forthright terms at 2.166: a recommendation that

an alternative appears to warrant further investigation only arises “where

133 Taken from 2.50

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the Inspector comes to the conclusion that, whilst the original proposal may

be justified in principle, the objections made against it are sufficiently

overwhelming to lead the Inspector to recommend against it”.

174. Accordingly, when assessing the advantages and disadvantages of

alternatives, the context must be borne in mind; the fundamental question

is whether the objections to the scheme itself are ‘sufficiently

overwhelming’ that it cannot meet the statutory tests and that therefore the

inspectors should recommend against it. It is submitted that none of the

objections to the scheme meet this test.

175. Another important factor is the delay which would be implied by the further

investigation of any alternative or alternatives. On the basis that

construction inflation does not differ materially from general inflation WG do

not argue that the delay would increase the costs of construction. There is,

however, a long-standing and existing problem on the M4. Delay in delivery

of a solution will mean the prolongation of those problems to the detriment

of the Welsh economy and the welfare of those who need to use the

motorway. That is a telling factor against all the alternatives.

176. In view of the very many alternatives the inquiry is referred to the

assessment in the Alternatives brochure, the rebuttals and responses

adduced and PIQs 152, 155, 156 and 230. Detailed submissions will only

be made in response to the alternatives which were promoted in person at

the inquiry.

Blue Route, Alternatives 1, 2, 23 & 24

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177. This is an alternative promoted by Cycling UK. This alternative was

articulated in a report prepared by Professor Cole and commissioned by

GWT, FoE and others “The Blue Route”134. Certainly prior to the inquiry, it

was the most prominent of the alternatives. It has been scrutinised by the

Assembly’s Environment and Sustainability Committee and formed an

important plank of the judicial review challenge heard by Hickinbottom J. It

is also a comprehensive alternative to the Scheme: it adopts no part of the

Scheme and is not simply a variation of the Scheme along part of its length.

178. Cycling UK adduced expert evidence from Professor Cole and Dr Melia as

well as evidence from Dr MacKay and Mr Geffen. The first to give evidence

was Professor Cole. Notwithstanding a considerable amount of liaison

between Professor Cole and the WG project team as to the best

articulation of the Blue Route and the various scenarios set out in the

Appraisal of the Blue Route published by WG in December 2016 (WG

6.2.35) there was some confusion as to which variation was advocated by

Professor Cole: in chief he introduced the gold, silver and bronze versions.

After some discussion, he agreed that scenario 7 was a fair representation

of the Blue Route. At the outset of his cross examination he was asked

whether he continued to advocate a road based alternative to the Scheme.

He prevaricated. Things, he said, had moved on; in 2013 Metro was not

within his contemplation135. Eventually, he confirmed that he was still

supporting the Blue Route. It was apparent, however, that Professor Cole

had not revisited the reasoning set out in ‘The Blue Route’ in light of

134 See paras 135 and 136 135 That was not quite right. Metro is addressed in some detail at page 14 of ‘The Blue Route’

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developments and information which had become available since its

publication in late 2013.

179. Professor Cole’s ambivalence about the Blue Route was a taste of things to

come. Mr Geffen was asked whether he advocated the Blue Route. He said

that it should be considered only if a package of measures encouraging

public transport and active travel would not be sufficient. He then said that

he was in favour of modest road proposals, which is hardly an accurate

description of the cost and impact of the Blue Route. Eventually, after a

brief adjournment, he expressed lukewarm support for the Blue Route.

Some clarity was provided by Dr Melia: he was against the Blue Route and,

indeed, any road proposal. Dr Mackay supported the Blue Route but had

not considered its impact on cyclists or discussed the same with Professor

Cole.

180. Reverting to Professor Cole it is instructive to examine his reasoning in

2013136. First, he said that there was a consensus that additional road

capacity was required137. Secondly, he noted the plateauing of traffic along

the M4:

“There was substantial growth in the late 1990s, but a levelling off from

2001 with a slight fall to 2012. There is therefore limited evidence to

suggest any change from the plateau in traffic flow that has occurred

since 2001138”.

136 These points were all put in cross examination 137 See above para 135 hereof where the full quotation from page 5 of ‘The Blue Route’ is provided 138 Page 13 ‘The Blue Route’

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181. Thirdly, he thought government forecasts of future traffic growth were too

high. Scepticism and uncertainty as to these forecasts was central to his

reasoning:

“The primary reason for putting forward the Blue Route is the

uncertainty of current traffic forecasts. These look likely to be lower

than has been assumed139”

182. Professor Cole did, however, address the position should the forecasts be

borne out:

“Even with the Department for Transport’s forecasts showing a 20 per

cent growth in traffic flow between 2012 and 2030, the Blue Route

could satisfy capacity requirements to 2025”.

183. The implication of this statement is that beyond 2025 the Blue Route would

lack capacity. This point was addressed at page 16 of ‘The Blue Route’:

“The Institute of Directors Cymru Wales wants a solution to ease

congestion on the M4 as quickly as possible. At the same time it says

that any scheme has to be ‘future proofed’. Not unreasonably, the

business community does not want to see a repeat of the current M4

position in 20 years time. The Blue Route answers this point since, if

traffic flow were to rise sharply, it could be upgraded to full motorway

139 Top of page 17 ‘The Blue Route’

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standard for the whole length.”

184. At that time Professor Cole was addressing a situation which, if he was

wrong about traffic growth, was 12 years away.

185. Some 4 or 5 years have elapsed since the publication of ‘The Blue Route’.

Professor Cole acknowledged that he had not reconsidered his proposal in

the light of developments since 2013. The most recent traffic data available

to him at the time of his report were those for 2012. Professor Cole was

invited to consider Mr Whittaker’s evidence regarding the MIDAS traffic

data for 2011-2016. The median level of growth over that 5 year period is

12.3%. A conservative figure of 11% was put to Professor Cole as to the

actual level of growth over 5 years. He was invited to agree that this growth

was not the plateau followed by low growth predicted by him in ‘The Blue

Route’ and that this information strengthened the case for the Scheme and

weakened the case for the Blue Route. No concession was made140. The

data set of 5 years, was, according to the Professor, too short. That stance

was, respectfully, untenable.

186. The Professor’s statement that the Blue Route would, should national

forecasts be correct, have capacity to 2025 equated to an ability to

accommodate a growth of 14% in traffic volumes along the corridor141. As

there had already been growth of 11% then growth of even 1% per annum

140 Professor Cole gave evidence over two days. This point was put to him on the first day. It was put again on the second day on the basis that Professor Cole had not considered the MIDAS data prior to giving evidence and witnesses are understandably reluctant to make concessions on the hoof when they have not had time to reflect. Despite having time for overnight reflection Professor Cole declined again to concede what was blindingly obvious. 141 The arithmetic was put in cross examination and Professor Cole did not quibble with the numbers. To recap, the DfT forecast growth of 20% over 18 years which equates to 1.1% per year. There are 13 years between 2012 and 2025 which equates to traffic growth of 14.4%.

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would mean that the Blue Route would reach capacity in 2019. It is not

relevant, therefore, whether the growth seen in 2011-2016 was likely to

persist for another 5 or 10 years. If it persisted for a year and half the Blue

Route would reach the capacity envisaged by Professor Cole in the middle

of 2018.142 Even if growth slowed to 1% per annum capacity would be

reached by the end of 2019.

187. Though ‘The Blue Route’ canvassed the possibility of widening the new

road - “if traffic flow were to rise sharply, it could be upgraded to full

motorway standard for the whole length” – no evidence was adduced by

Cycling UK to support that rather glib observation. In fact, the sharp rise in

traffic flow has already occurred. There is no alternative before the inquiry

for a full-blown motorway along the line of the SDR and SAR. Professor

Cole clarified that the statement in ‘The Blue Route’ was directed towards

the A4810 section of the Blue Route and not the A48 section. He also said

that in view of subsequent developments along the SAR he was not

positively averring an ability to upgrade the Blue Route to a 6 lane

motorway along any part of its length. There is no basis, therefore, for

supposing that the Blue Route could be substantially upgraded in light of

higher levels of traffic.

188. Mr Sibert’s evidence as to the timescale for starting and completing

construction of the Blue Route – namely, a start in 2023 and completion in

2027 or 2031 depending on the amount of traffic difficulty which was to be

tolerated during construction – was put to Professor Cole. He was not

qualified to comment in detail on construction timescales but acceded that

142 18 months growth from the start of 2017 at 2% per annum.

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the start date was reasonable and acknowledged that on-line schemes take

longer than off-line schemes for obvious reasons relating to traffic

management.

189. The Blue Route, if it were ever a sensible option (a variant, Option C, was

considered as part of the M4 CEM process and rejected), has been

rendered untenable by subsequent events; namely, the growth of traffic

along the M4 confounding the prediction for a continuing plateau followed

by low growth. The capacity of the Blue Route to abstract significant traffic

from the M4 will be exhausted long before it is built. On Professor Cole’s

original analysis143 the Blue Route is not a tenable alternative. That is

telling and it is confirmed by the detailed analysis undertaken by the WG

project team. That is set out in detail in the December 16 report, the

rebuttals of Cycling UK’s case and subsequent IDs.

190. The thinking behind the Blue Route was underpinned by a simple

arithmetical approach: if one increases the capacity of the SDR/SAR by x

thousand vehicles a day then that means that x thousand vehicles a day

can be extracted from the M4 thereby solving or alleviating sufficiently the

congestion on the M4. For the reasons outlined above, growth in traffic flow

means that even when conceived in these terms the Blue Route simply

won’t work. But individual motorists undertake journeys which suit them;

they do not simply transfer from route A (the M4) to route B (the Blue

Route) in accordance with best laid plans of transport planners. More

importantly in this context, individuals using routes C, D and E etc may

populate route B once it is enhanced thereby thwarting the transport

143 That analysis was flawed in that it did not quantify the amount of local non-M4 traffic which would populate the Blue Route thereby making it less attractive to M4 traffic.

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planners’ intention to move traffic from A to B. The latter problem is one of

the reasons why the Blue Route will not work and would not have worked

even had observed traffic growth been lower. This is illustrated vividly in ID

43a which addresses induced traffic in a no toll scenario.

191. The 2 way volume of traffic along junction 26-25A with the Blue Route in

place in 2037 is 88,344. The corresponding figure in the Do Min in 2037

with no tolls is 90,414144. The level of extraction from the AADT at the

Brynglas Tunnels is just over 2,000 and is a reduction of 2.3% in the AADT

through the Tunnels. It is not the case, however, that the Blue Route does

not attract additional traffic. The AADT over the A48 SDR Bridge in 2037 in

the no toll scenario with the Blue Route is 69,263; that compares with

around 45,000145 in the Do Min no toll scenario in 2037. The increase

across the A48 SDR Bridge is much greater than the 2070 abstracted from

the Tunnels. That is because most of the traffic which will be attracted to

the Blue Route will be local traffic abstracted from the local network in

Newport, not traffic from the M4. The benefits, therefore, of the Blue Route

are largely derived from enhancing the journey times of intra Newport trips

and not from solving the problems of the M4. While the BCR of the Blue

Route is significantly lower than the Scheme this does not fully capture its

disadvantages: that is because most of the Blue Route benefits accrue to

local traffic. It does precious little to alleviate the congestion afflicting the

strategic traffic along the M4.

192. Over and above the fact that it simply does not address the problems which

the Scheme is designed to solve and provides low value for money there

144 Tables produced by BW on 7 & 8 March 2018 ID 248 145 This is an approximation from Figure 10.10 of the Traffic Forecasting Report of December 2016 (WG 2.4.13). It is an approximation because Figure 10.10 is based on a half toll.

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are a number of other significant disadvantages. As these are addressed at

length in the Appraisal of the Blue Route and in evidence they will only be

noted in short form:

i. As the Blue Route does not extract significant traffic from the M4

then it does not produce noise and air quality improvements along

the existing M4 while properties alongside the Blue Route would

sustain noise and air quality detriments;

ii. The online nature of construction would cause significant traffic

management problems and travel disbenefit during the construction

period of 4 to 8 years - these costs have not been quantified and

are not reflected in the BCR;

iii. The Blue Route would sever Newport in two and reduce

permeability to non motorised users: ironically it would be worse for

cyclists;

iv. There would be a number of junctions and as the CBI stated in

evidence it would be an upgraded local bypass replicating the

weaknesses of the existing M4 around Newport.

193. When the main Blue Route case was heard the core scenario was a half

toll. The abolition of the tolls, which increases traffic on the existing M4

particularly at its eastern end, strengthens the case for the Scheme. There

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is a modest increase in the benefits delivered by the full Blue Route but the

increase is significantly smaller as a proportion than the increase in

benefits as a result of the Scheme. Accordingly, abolition of the tolls further

undermines the merits of the Blue Route in comparison to the Scheme.

194. In conclusion, the Blue Route at £832 million146 is an expensive scheme,

the main advantages of which would accrue to local vehicular traffic. It

would provide little relief in terms of congestion on the M4. It was

predicated upon two propositions. First, that traffic growth would continue

to plateau to be followed by a period of much lower growth. Secondly, that

if the SDR and SAR were enhanced traffic from the M4 could be

transferred on to the Blue Route in order to fill up the additional capacity on

the Blue Route. Incontrovertible evidence as to observed levels of growth

on the M4 between 2011 and 2016 show that the first proposition was

wrong. The second proposition was based on a simplistic notion of driver

behaviour which failed to take account of the fact that when the road

network changes drivers change their behaviour. If the Blue Route were

built traffic would reassign from the local road network in Newport, leaving

little spare capacity or attraction for those travelling on the M4. It is ironic,

given the noise made by the Cycling UK witnesses about induced traffic,

that the Blue Route is based on ignoring this fundamental point about

human behaviour and traffic modelling. Another irony is that the Blue Route

would hinder rather than encourage modal shift towards active travel in the

urban areas where there is most scope for such journeys. The Blue Route

has little to commend it and the ambivalence and, in one case hostility, of

146 Cost for appraisal of alternative 1 in PIQ 152

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those witnesses called to advocate for it is telling. We submit that the report

should conclude that the Blue Route in any of its variants does not warrant

further consideration.

The Green Route, Alternative 3

195. This is the route advanced by Mr Wynton and Mr Smith. It consists of

various changes to the Scheme at the eastern end. The detail is set out in

the Alternatives Report, the evidence of Messrs Smith & Wynton and in

WG’s rebuttal evidence. There is a detailed analysis of the Green Route’s

BCR in PIQ 155. Unlike the Blue Route, the Green Route would meet most

of the TPOs and it would bring significant relief to the M4. By and large it

would meet the strategic objectives. It has some advantages over the

Scheme in terms of historic landscape and cultural heritage. It also avoids

the direct impact on the Llanfihangel Rogiet Conservation Area which is

implied by the Scheme. That impact, however, has to be put into context.

The land-take impacts upon a field within the conservation area and not on

the historic built environment of the village. None of the buildings will be

disturbed. Furthermore, a lot of the land to be acquired will be used for soft

landscaping and situating an attenuation pond. Mr Rawlins opined that he

could not see a justification for revoking the conservation status of the

village. While the Green Route is superior to the Scheme in terms of impact

on heritage it also heritage disadvantages e.g. the impact on the setting of

Dewstowe House. In terms of traffic movements the Green Route

enhances access to Magor Services. There are, however, significant traffic

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disadvantages which are set out in WG’s rebuttal evidence and which were

explored during oral evidence. For instance, the access to the B4245 is not

as well situated as it is in the Scheme with the consequence that there

would be increased traffic on the B4245 through Magor, particularly at the

western end. That is because the dumbbell junction between the B4245

and M48 is too far to the east for it to be attractive to traffic from Undy and

the west of Rogiet. The access provided to the main M4 is also less direct

and impracticable for eastbound traffic. Insofar as environmental matters

are concerned the Green Route would have a reduced impact on the

Gwent Levels, but the impact on the three westernmost SSSIs is the same

as the Scheme. On the other hand, there would be greater tailpipe

emissions on the Green Route because it is 950 metres longer and

because of congestion at the eastern end.

196. It is submitted that the advantages and disadvantages of the Green Route

outlined in paragraph 195 are not decisive either way. There is, however, a

significant difference between the initial BCR of the Scheme, 1.69, and the

initial BCR of the Green Route, 1.34 and PIQ 155 merits close scrutiny as it

explains why there is this difference. The costs of the Green Route are

higher because it is longer and involves additional fill requirements. The

costs are, however, only a small part of the story; the discrepancy is

explained by the more significant difference in the benefits147. Under the

half toll scenario the PVB of the Scheme was £1,573 million versus a PVB

of £1,490 million for the Green Route – a difference of £83 million. Under

the no toll scenario, however, the PVB of the Scheme becomes £1,822

147 If one divides the PVB of the Green Route with the PVC of the Scheme the ratio is 1.4; the ratio of the PVB of the Scheme over the PVC of the Green Route is 1.63. Most of the disparity is thus due to the differences in PVB between the two.

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million versus a PVB of £1,502 million for the Green Route – a difference

of £320 million. The explanation for this big difference relates to the inability

of the Green Route to cope with the additional traffic caused by abolition of

the tolls. The increase is at its greatest at the eastern end of the Welsh

section of the M4. Between junctions 23 and 23A the Green Route provides

6 running lanes of traffic; the Scheme provides 10 running lanes. As is

apparent from Table 2 of PIQ 155, by the design year the Green Route is

saturated and queues will form in the peak periods adversely impacting on

journey times. The Green Route was inferior to the Scheme in a half toll

scenario and congestion between junctions 23 and 23A by 2037 was noted

in the Alternatives Report as one of the disadvantages of the Green Route.

But, as is apparent from the detail in PIQ 155, the abolition of the tolls has

significantly increased this disadvantage. The Scheme is decidedly

superior to the Green Route even before one considers the disadvantages

of delay and uncertainty which would ensue should the Green Route be

further investigated.

Junction 23A West Bound On-Slip, Alternative 11

197. This is an alternative promoted by the owners of Magor Services,

Roadchef. Unlike all the other alternatives it does not involve deleting any

part of the road to be built under the Scheme. It is, conceptually, a

supplement or addition to the road rather than an alternative route. While it

is quite proper that it is treated as an alternative in terms of being subject to

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the tests set out in the Advice to Inspectors148 this distinction is important.

Roadchef’s case is that the Scheme would be better should the WB on-slip

be added. No doubt, it would be better for them. WG accept that the

absence of direct unimpeded WB egress on to the new road will deter

some customers. But the same is true of the EB egress and that, according

to Roadchef, is acceptable. The fact, therefore, that Roadchef might enjoy

more trade if the egresses were differently configured does not mean that

the Scheme would be improved by reconfiguration: consideration would

have to be given to a whole host of factors including, in a world of finite

public finance, cost. Whether the Scheme would be improved by the

addition of the WB on slip is not, however, the test. The test is whether,

without the WB on-slip, there is “some deficiency in the Order proposal that

would otherwise render it incapable of passing the statutory tests”149 or that

“whilst the original proposal may be justified in principle, the objections

made against it are sufficiently overwhelming to lead the Inspector to

recommend against it”150. We argue below that Roadchef do not come near

to satisfying this test.

198. Roadchef adduced evidence from its chief executive Mr Simon Turl, its

Business Development Director Dr Ian McKay, and from a traffic and

transport consultant Mr Mike Axon. They also relied on hearsay evidence in

the form of a letter from one of Mr Axon’s colleagues, Professor Pickup,

who is a social scientist. Mr Axon advanced the general proposition that

Motorway Services Areas (‘MSAs’) are intended to serve a road safety

function, in addition to meeting the demand of the public for convenient

148 Set out in paras 45 to 49 hereof 149 Test as articulated in 2.50 150 Test as articulated in 2.166

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services. That general proposition is uncontroversial. It does not establish,

however, that the design of the Scheme is such that it presents an

unacceptable safety risk without the addition of alternative 11. As to that

issue Mr Axon does not advance any case based upon his own expertise.

Rather, he relies upon the experience and judgment of Messrs Turl and Dr

McKay as to the level of decrease in turn in rates as a result of the

Scheme. He also purports to rely upon the observations of Professor

Pickup. Properly understood, however, the evidence of Messrs Turl and

McKay is not based on their experience or judgment; instead, they adopt a

misconceived interpretation of survey research which, itself, did not ask the

questions which would appropriately elicit information as to the likely

responses of motorists to the changes wrought by this Scheme. Messrs

Turl and McKay, for their part, affirm a preference for a signage strategy

which is at odds with all of the observations made by Professor Pickup as

to human behaviour and decision making. That signage strategy is,

moreover, contrary to what would be prescribed if one assumed, for the

purposes of strategy and modelling, that individuals are rational and have

perfect information. The signage strategy avowed by Messrs Turl and

McKay is advanced, it is submitted, to set up the Scheme as a straw man

and to make good the question in the Harris Interactive survey about the

length of round trips to access the Services. The evidence adduced by

Roadchef is thus misconceived in a number of respects and their avowed

preference for signing via junction 23 contradicts Mr Whittaker and Mr

Bussell’s model of individual behavior as well as that advanced by

Professor Pickup. As their evidence is unconvincing it is perhaps

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unsurprising that so much reliance is placed in closing upon what the Road

Safety Audit says in respect of problem 95. The inquiry has not, of course,

heard from the authors of the Road Safety Audit. While there is no doubt as

to their expertise it is submitted that if their reasoning was unimpeachable

Roadchef would have adduced evidence replicating and making good that

reasoning. That evidence has not been adduced because, notwithstanding

the standing of the authors of the Road Safety Audit, the reasoning therein

is, in significant respects, fallacious. We will analyse what is said in the

Audit to make good this claim. First, however, it is useful to look in more

detail at the evidence adduced by Roadchef to make good what is said

herein about it being misconceived.

The survey

199. Harris Interactive conducted a survey in 2016 of customers visiting

Roadchef. The survey was conducted over two distinct periods, one to

assess holiday season traffic the other to survey a typical month. Question

21a asked:

“If stopping at this Motorway Service in future required a round trip

from the M4 of just over 2 miles passing through two junctions, how

likely would you be stopping here?”

200. Question 21b is in identical terms save that the round trip is 4.5 miles

instead of 2 miles. When Mr Turl and Dr McKay adduced their first proofs of

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evidence the WG had not added the EB off-slip to the scheme. Absent the

EB off slip, EB traffic would have to travel to junction 23 and then carry out

a round trip between junctions 23 and 23A to get to and from the Services.

In respect of that journey question 21 was broadly fair. An EB motorist

would have to pass through junction 23 twice in order to access the

Services as well as passing through junction 23A itself (the latter of course

is always a feature of any off-line MSA). The round trip was also broadly 4

miles151. It was also a round trip in the true sense of that phrase i.e. a

journey where one departs from the main-line and then returns to the same

point on the main-line. The question, however, no longer applies to EB

traffic because of the addition of the EB off-slip. It was, moreover, never an

appropriate question in respect of WB traffic. That is because ingress and

egress WB will be more or less the same under the Scheme as it is now.

Ingress will differ only insofar as motorists have to take the free-flow

connection from the main M4 to the trunk road dual-carriageway between

junctions 23 and 23A. Roadchef do not complain about the ingress and it is

submitted that the free-flow junction WB at junction 23 can be disregarded

in terms of the attractiveness of the Services. Thereafter, the egress which

a rational agent would follow is via the reclassified M4. That much is

apparent from Table 4 of the SoCG. In round terms the additional time

occasioned by a WB visitor to the MSA is 4 minutes if one goes via the

reclassified M4, 5 minutes via the SAR and Glan Llyn junction, and 6

minutes if one goes via junction 23. The egress advocated by Roadchef is

therefore the slowest. Furthermore, it is the only option which involves a

151 From Table 2 of the SoCG the round trip is 3.9 miles. The round trip under the status quo is 0.1 miles. So the additional round trip is 3.8 miles.

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‘round trip’. From the point of view of the rational motorist, therefore, the

egress will always be via the reclassified M4. This does not involve any

round trip, additional to the one of 0.3 miles which is already

experienced152. So any question about travel WB which implies a round trip

is wrong if motorists are rational agents. Furthermore, the additional

distance occasioned by a visit to the Services is 2 miles; 1.7 miles because

the reclassified road is longer than the Scheme and 0.3 miles which is

simply the distance along the slip roads and gyratory as per the status quo.

The net additional distance is thus 1.7 miles.

201. The question then becomes whether the question is fair and appropriate if

one rejects Mr Whittaker and Mr Bussell’s rational agent model of human

behaviour in favour of some conception based on Professor Pickup’s letter.

To that end it is useful to identify and list those insights drawn from the field

of behavioural economics which impact upon the desirable or likely

egress153. These are his insights154:

i. Travel speed was a better variable at predicting driver choice than

travel time (para 9);

ii. Maintaining a slower but constant speed is perceived as better than

stop start driving even if the latter takes less time (para 10);

iii. Humans tend to minimize cognitive effort (para 11);

152 The WB round trip is 0.3 miles rather than 0.1 miles EB because the motorist has to travel further around the roundabout. 153 As Mr Bussell notes in his rebuttal of the Supplementary Evidence of Mr Axon and Dr McKay none of this is new and, ironically, the paper by Unal et al cited by Pickup concludes that “as far as transport planning goes, we tend to agree with de Moraes Ramosa et al that it currently still provides the best framework for travel demand simulation and forecasting” – see para 3.1.9 of Mr Bussell’s rebuttal. 154 The paragraphs of Professor Pickup’s letter are not numbered. Numbers have been added to identify the paragraph where the proposition/insight is to be found.

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iv. Humans tend to satisfice rather than optimize and take shortcuts in

their decision making (para 12);

v. A generalized cost approach disregards the salience and influence

of ‘perceived effort’ or ‘hassle’ on a journey. For instance, an

increased number of junctions to navigate will be salient to that

decision making (para13);

vi. Drivers are more likely to revert to something they know rather than

travel a new route of which they have no knowledge (para 15);

vii. A further aspect is the perceived and unexpected ‘diversion’ and

‘disruption’ leaving the services…..Where drivers are unfamiliar with

the trip, simplicity to return to the motorway after stopping would be

the preferable option, though not the option that might be

recommend by their navigation system – this will confuse (para 19).

202. The implications of these insights were explored with Roadchef’s

witnesses. For instance, it was put to Mr Turl that in attracting visitors ease

of ingress is more important than ease of egress. Notwithstanding the fact

that even a rational agent will regard ingress as often more important than

egress155 Mr Turl refused to acknowledge that ingress will usually be a

more important determinant of turn in rates. In that regard, his evidence

was unconvincing. Dr McKay, by contrast, accepted that usually ingress is

more important than egress in terms of attracting custom156. It was put to

Dr McKay that WB egress via the reclassified M4 was not, as he stated in

his main proof of evidence, difficult, tortuous and counter-intuitive. It is

155 For example if a rational agent is hungry or in need of a comfort stop or just tired the ease of access is more important than the egress because s/he is more refreshed on exit than on entry. 156 His concern was that first time users would not return having experienced the egress.

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identical to the current egress. Dr McKay agreed that the adjectives were

inappropriate as a description of WB egress via the reclassified M4 either

now or with the Scheme in place. Professor Pickup’s insight that people

prefer moving to stopping and starting and will avoid junctions if possible all

militate against signing via junction 23 or the SAR and in favour of signing

via the reclassified M4, all points accepted by Dr McKay as general

propositions. The Roadchef preference for signing via junction 23 was set

out in their main proofs which were served in February 2017. Professor

Pickup’s letter post-dated that decision, so it was made without the benefit

of his insights. Dr McKay said that the decision to suggest signing via

junction 23 had been re-confirmed by the Board of Directors. But Professor

Pickup’s letter was not discussed at that Board meeting and the only

directors aware of its contents were Dr McKay and Mr Turl. It is apparent,

therefore, that Roadchef has not heeded the letter which is relied upon.

203. Professor Pickup’s insights relate to the human desire to avoid hassle and

cognitive effort and to make decisions based on rules of thumb. One very

obvious rule of thumb when travelling from A to B is that one should keep

travelling towards B. That is why people don’t like travelling in the opposite

direction to their ultimate destination; it feels wrong. Where going in the

wrong direction is actually the quickest route a person may suffer from

cognitive dissonance – they believe that they should travel towards their

destination but they also believe that they should choose the quickest route

– and the clash of these two beliefs may be uncomfortable. But in this

instance, there is no clash – the quickest egress is also the one which

moves in the direction of the ultimate destination. Similarly, there is no

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conflict between the quickest route and the desire to avoid stop start

conditions and traffic lighted gyratory at junction 23. Finally, the conflict

between satellite navigation directions and the signed route only arises if

one takes the perverse decision to sign via the counter-intuitive and

irrational route i.e. via junction 23.

204. In short, as Mr Whittaker says in his rebuttal, the solution suggested by

traffic modelling and behavioural economics align. Professor Pickup’s

insights can be relevant where the two ways of modelling or assessing

aggregate human behaviour pull in different directions. Where they align -

where the quickest route is the same as the hassle free, familiar, intuitive

route - then the debate is academic. Against all of this Dr McKay relies

upon the proposition that motorists don’t like ‘local roads’. But the

reclassified M4 is not ‘a local road’ in any meaningful sense. It will be a

trunk road, a fast and uncongested dual carriageway not dissimilar to the

dual carriageway between junction 24 and . Dr McKay

acknowledged that he had not one scrap of evidence in support of this

supposed aversion to local roads. It is unevidenced and, moreover, wholly

contrary to the approach set out in Pickup’s letter.

205. After this lengthy diversion into the field of behavioural economics we revert

to whether question 21 is a fair or appropriate question in respect of WB

egress. The answer is that it is not: both the rational and intuitive egress

from the Services is via the reclassified M4. There is not, therefore, any

round trip.

206. Even if there were a round trip of 2 miles (and the additional diversion is 1.7

miles) the percentage who said that they would not stop was 32%. A further

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25% said that they would try not to stop and would only do so if necessary.

It would make no difference to 24% of respondents and 16% would be

dissuaded to some extent. Even on the figures for 4.5 miles and assuming

that there was a round trip one cannot get to the 80% figure posited by

Turl/McKay and adopted by Mr Axon.

207. Roadchef’s case on the proportion of customers travelling along the new

M4 who would be deterred from accessing the Services is, therefore,

wholly misconceived. It relies on a survey which asks the wrong question.

Even if one puts that aside, and we submit that the nature of the question

means that the survey is not persuasive at all, Messrs Turl and McKay

have wholly misconstrued the results. Mr Axon simply adopts their

conclusions without exercising any independent judgment. He pays lip

service to his colleague Professor Pickup’s insights but fails to note that at

least in the context of WB traffic and this Scheme the prescriptions of the

traffic modeller and behavioural economist point in the same direction; the

debate between those two approaches are thus academic and irrelevant.

Both suggest that Roadchef’s preferred signing strategy is a nonsense; the

inference to draw is that it has been adopted with a view to strengthening

the case for the WB off slip.

208. Notwithstanding all of this, WG accept that the absence of a WB off-slip will

deter some customers. It will deter those, however, where the decision to

stop or not is marginal i.e. those who don’t need to stop. Those who need

to stop include those who are tired. There is a similar marginal deterrent

effect in the EB direction. There will always be a time penalty when visiting

an MSA, whether on or off-line. Under Do Minimum the penalty is basically

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1 minute157. With the Scheme in place it increases to 3 minutes EB and to

just over 4 minutes WB158. There is an additional penalty both EB and WB

and the difference between the EB and WB penalty is much smaller than

the difference between the penalty between Do Minimum and Do

Something for EB travel. Roadchef have dropped their alternatives relating

to junction 23 which impact upon EB travel and thus regard that as

acceptable from a safety point of view. It is difficult to see how the extra

minute WB can lead to the conclusion that the Scheme is unacceptable

from a safety point of view in one direction when it is acceptable insofar as

the other direction of travel is concerned.

209. Due to the weaknesses in its own evidence Roadchef rely to a great extent

on the Safety Audit Report. We now turn to that.

Safety Audit Report – problem 95

210. The Summary of the problem reads as follow:

“Change of access to the existing could lead to

collisions on the local road network.”

211. The auditors foresee a potential for collisions on the local road network

because they envisage motorists egressing via the SAR and Glan Llyn

junction:

157 Table 4 of SoCG. It is less than a minute EB, slightly more than a minute WB. 158 Table 4 of SoCG. The exact figures are EB AM 3:17, PM 2:51; WB AM 4:11; PM 4:17

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“However, the exit from the rest area to continue westbound on the

proposed M4 would require users to negotiate seven roundabouts and

re-join at the Glan Llyn junction. This may adversely affect the safety of

the existing local road network as different types of traffic would be

using it.”

212. Neither the WG nor Roadchef are advocating a signing strategy which

directs WB visitors to the Services to return to the new road via the SAR.

That route is not the one which would be recommended by satellite

navigation because it is not the quickest159. It is unlikely, therefore, that WB

motorists leaving the Services would take the SAR. The problem foreseen

by the auditors will not arise and in this respect the point made by the

auditors is a bad one.

213. The auditors note, without comment, the possibility of WB egress via

junction 23 but say nothing about egress via the reclassified M4. They paid

no heed, therefore, to the most obvious and likely mode of egress. That,

too, is a weakness in their reasoning.

214. This error appears to have played a part in at least one of the substantive

conclusions reached by the auditors:

“In addition, the more complex routes to re-join the mainline may

confuse unfamiliar road users and this could lead to nose-to-tail or

side-swipe collisions at junctions with other road users on the local

road network (including NMUs) as they look for confirmation of their

159 See Mr Whittaker’s evidence and table 4 of the SoCG.

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route”

215. WB egress via the reclassified M4 does not involve any complexity over

and above the status quo.

216. As for the attractiveness of the Services the auditors expressly make the

point in respect of EB and WB traffic: “in both directions the journey to the

rest area is likely to be less appealing to the majority of users on the

proposed M4 mainline”. No distinction is drawn by the auditors between

WB and EB traffic. But Roadchef accept that there is no safety objection to

the Scheme with regard to EB traffic. In any event, the auditors’

recommendation is to mitigate the problems which they identify by adopting

a clear signing strategy and it has been confirmed that the Services will

continue to be signed from the motorway and to that end will remain

motorway services.

217. MSAs fulfil a road safety function because they provide motorists with a

place to rest and/or to take a coffee or other stimulating drink. The

Department for Transport’s Road Safety Research Report 57160 looked at

682 crashes of which 181 were considered to be sleep-related crashes

SRCs. They analysed crashes which occurred before and after MSAs to

see whether there were reductions after MSAs. The results are set out in

paragraph 3 of the Executive Summary:

“Within these 16 km sections, a total for 355 RTCs were prior to

the MSAs, and 304 were afterwards. This 14% reduction was

160 Appendix A of Ben Sibert’s Roadchef rebuttal

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not statistically significant. When these RTCs were sub-divided

into SRCs and non-SRCs, there were 108 SRCs prior to MSAs

and 84 afterwards. This 22% decrease was statistically

significant (p<0.05), indicating that MSAs were associated with

some crash reduction, but only with this type of RTC as all other

non-SRCs showed a non-significant 11% drop. Moreover, there

were large differences between MSAs in all these respects, with

about half the MSAs seeming to have little or no beneficial effect

on RTCs or SRCs”

218. There is therefore an association between MSAs and the reduction of SRC

but the evidence is not compelling with half of the MSAs having little or no

beneficial effect. As for distance between MSAs:

“The distance between adjacent MSAs in relation to this having

an effect on the incidence of crashes showed no clear

relationship (e.g. SRCs did not necessarily increase with

distance apart)161”

219. SRCs are a problem on motorways because, as noted by an earlier DfT

report, Road Safety Research Report 52, sleep related crashes tend to

occur under monotonous driving. Mr Sibert has assessed the motorway on

either side of Magor. He states:

161 Para 5 of the Executive Summary

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“For a significant distance either side of Magor, I would describe

the M4 motorway as far from monotonous. From junction 18 for

the A46 to Bath through to junction 33 for the A4232 to Cardiff

West (49 miles) the M4 motorway with the Scheme has

numerous features to keep drivers interested and alert such as

changes in level, varying topography, curving alignments, vistas,

major interchanges, major bridges, cities and numerous (13 with

the proposed Scheme) junctions”

220. There is a contrast with the section of the M4 east of junction 18

whereupon the conditions become monotonous until Reading.

221. Mr Sibert’s qualitative assessment of the nature of the road either side of

Magor is corroborated by his quantitative analysis of the historic accidents

along this road:

“3.2.12 I have reviewed the accident data contained within the

M4CaN Traffic and Collisions Report 2016 (Doc. 6.2.16) which

shows that over a period of 11 years, 13 accidents are reported

where sleep was recorded as at least one factor of causation. Of

these accidents, 12 are recorded as slight and one serious with

none recorded as fatal. This 13 in number represents 2% of the

total 658 personal injury collisions recorded. The one serious

crash represents 8%, noting that it is a very small data set.

3.2.13 Compared to the conclusions presented in RSRR 52

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which reports that SRCs account for overall 17% of road traffic

crashes (RTCs) with a range of 3% to 30% this data for the M4

around Newport is at the very bottom end of the range of SRCs

as a proportion of RTCs”

222. The Scheme will change the nature of the route between Magor and the

next Services at Cardiff Gate and that must be borne in mind when looking

at historic data. The road will have a better alignment and while this is

generally beneficial in terms of RTCs it can be a disadvantage in terms of

SRCs because a straight road, absent other factors, is monotonous. But as

Mr Sibert pointed out there will be views of Newport and of the large and

illuminated Usk bridge. The travel time between Magor Services and

Cardiff Gate will, moreover, be reduced as the Scheme road is both shorter

and quicker. Furthermore, as pointed out during cross examination of Mr

Axon, it is only in respect of this stretch of the road that there could be any

additional risk of accidents.

223. As Mr Sibert pointed out while there is statistical evidence of there being a

positive relationship between MSAs and reducing SRCs there is no

evidence whatsoever in respect of distances between MSAs or the relative

attractiveness of MSAs, however that may be defined.

224. Roadchef rely upon English guidance expressing a preference for on-line

rather than off-line MSAs, Circular 2/2013. This, however, does not

advance Roadchef’s case for a number of reasons. First, it does not apply

in Wales and as Dr McKay agreed there has never been a policy in Wales

in support of on-line MSAs. Secondly, as a matter of fact, none of the

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MSAs in Wales are on-line. Thirdly, Magor is already an off-line MSA and

thus the Scheme does not change its nature. Fourthly, there is no statistical

evidence to support the proposition that on-line MSAs do more for reducing

SRCs than off-line MSAs. Fifthly, the evidence adduced by Roadchef as to

the greater turn in rates for on-line MSAs is unconvincing for a number of

reasons. Mr Bussell has shown that an on-line MSA can have very

convoluted access arrangements but still maintain very high turn in rates

e.g. Norton Canes. Mr Bussell’s analysis of the distance which customers

are required to travel shows that there is no reliable correlation between

ease of access and turn-in rates. There is also a high degree of variability

in turn in rates within each category i.e. some online services have very low

turn in rates. Finally, Mr Bussell points out that until the 1980s the vast

majority of MSAs built were on-line services; from 1980 onwards the vast

majority have been off-line services. Consequently, the on-line services are

likely to enjoy better locations with higher levels of passing long distance

traffic, whilst off-line services also tend to face more competition. These

factors are the likely explanation for the higher turn in rates for on-line

services. In short, Roadchef’s case confuses correlation with causation.

225. WG’s witnesses have looked at the detail of the access arrangements in

the WB direction and also assessed the nature of the road either side of

Magor. On the basis of that assessment they have concluded that the

access arrangements are appropriate. As compared to EB access there is

just an additional 1 minute penalty for taking a detour to the MSA. In other

respects, the position WB is better than EB: there is no need to negotiate a

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signalized gyratory in order to rejoin the mainline162 and the next MSA,

Cardiff Gate, is much closer than the next MSA in the EB direction, Leigh

Delamere. Overall, it is submitted that there is little difference between WB

access and EB access. The latter is acceptable and so, it is submitted, is

the former. The Roadchef case depends on there being a need for WB

customers to have to undertake an U-turn to egress via junction 23. Few

motorists, it is submitted, would take that route for reasons already

outlined. Furthermore, while WG would clearly consult Roadchef in terms of

the final signage strategy the obvious strategy is to inform motorists of the

quickest egress via the reclassified M4. Reliance is placed by Roadchef on

the Road Safety Audit. The auditors, however, assumed that WB egress

would take place via the SAR and Glan Llyn junction. That will not be the

signage strategy and the observations made by the auditors as to conflict

with local traffic do not therefore apply. The auditors did say that the

Services would be rendered less attractive to motorists. But that

observation was made in respect of traffic in both directions and the

recommendation was to mitigate this factor by way of a clear signage

strategy.

226. In short, it is submitted that the WB access arrangements are, like the EB

access arrangements, acceptable having regard to the Services’ safety

role. To the extent that the access arrangements render the Services less

attractive then those customers who will be dissuaded are likely to be

discretionary visitors and not those who need to stop due to fatigue. There

is the additional point that there is very little time penalty in terms of ingress

162 Significant in terms of people’s preferences for moving over stop start

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and that is a further reason for concluding that there is no unacceptable

safety risk.

227. During the course of the inquiry reference has been made to the decision of

the Secretary of State for Transport and the Secretary of State for

Communities and Local Government of 18 December 2008 in respect of

the A46 Newark to Winderpool Improvement. In that case the inspector

recommended confirmation of the orders but suggested at least 4

modifications which would require re-designing the scheme and making

supplementary orders. The decision letter states163 that the Secretaries of

State accept the recommendation that further consideration should be

given to the design of the road in these four areas and directs the

Highways Agency to re-consider the design in these areas. The decision

letter acknowledges, however, that the statutory processes in respect of

any Supplementary Orders could not be pre-judged. Indeed, the decision

letter acknowledges that the outcome of the Highways Agency’s further

design work could not be foreseen. It must be the case, therefore, that the

A46 decision is based on the proposition that the existing design was

acceptable but that it would be prudent to further investigate the inspector’s

concerns to see if an acceptable design could be improved. Had the

decision makers taken the view that the existing design was unacceptable

then it would not have been appropriate to confirm the orders as there

cannot be a compelling case in the public interest to take anyone’s land if

the purpose for taking that land is to build an unacceptable road.

163 Paragraph 25 of the decision letter

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228. As stated at the outset the WB on-slip is a supplement to the Scheme and

not an alternative in the conventional sense. The issue for the inquiry is

whether the arguments advanced by Roadchef are such that the inquiry

should conclude that the Scheme does not satisfy the statutory tests

because the design in respect of the Services is unacceptable. That issue

should be resolved decisively in the Scheme’s favour; the access

arrangements for the Services are appropriate. If, contrary to these

submissions, it is concluded that the design is unacceptable then, as set

out in the Advice to Inspectors at 2.50 “it would not be logical to

recommend the making or confirmation of the orders”. As the WB on-slip is

a potential supplement to the Scheme the level of use of the Services and

any safety implications consequent upon that could be kept under review

by WG once the Scheme is operational. It is a matter for the inspectors as

to whether any recommendations or observations are made as to

advisability of keeping this supplement under review. The primary issue,

however, is whether Roadchef have met the demanding test of showing

that the access arrangements to the Services mean that the Orders are

incapable of passing the statutory tests. This is a binary question and for

the reasons set out above we submit that Roadchef’s case falls

considerably short of meeting the test.

Mrs Picton’s Tunnel, Alternative 26

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229. A tunnel between junctions 23 and 29 which follows broadly the line of the

Scheme164 was assessed quantitatively as alternative 20. The cost of

alternative 20 was assessed at just under £10 billion; its PVB is £1,177

million which is substantially lower than the Scheme’s PVB, largely

because it has no intermediate junctions and thus provides reduced

accessibility to Newport. The BCR of alternative 20 is 0.16. Mrs Picton’s

tunnel, alternative 26, is shorter and is on a different alignment and

bypasses junctions 24 to 26. The cost has been assessed at just under £5

billion. Due to the late stage at which it was submitted there is no

quantitative BCR for this tunnel. It is, however, very expensive and the user

benefits which it would deliver would be below those of alternative 20 as it

does not provide any additional capacity east of junction 23A or west of

junction 27. Junction 28-29 is currently the most trafficked section of the

existing M4 while the eastern section will become much more heavily

trafficked as a result of the abolition of the tolls. The evidence with regard

to the potential for congestion between junctions 23 and 23A has already

been addressed when looking at the Green Route. The Green Route has

more capacity than the Do Minimum through junction 23A and thus the

congestion is likely to be worse along that section of the M4 under the

tunnel alternative than it is with the Green Route. Though there is no

quantified BCR this tunnel has been assessed as providing very poor value

for money, an assessment which is robust.

230. The tunnel would avoid any impact upon the Gwent Levels which is its

main, perhaps only, advantage. It is hugely unaffordable and constitutes

164 The tunnel is straighter and therefore shorter.

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very poor value for money. It is untenable as a possible solution and does

not merit further consideration.

Mr Waller’s package of measures, Alternative 28

231. Mr Waller advocates a package of public transport measures, the closure

of some junctions of the M4 to deter its use by local traffic and some on-line

widening of the M4. It is not a criticism of Mr Waller to say that the package

has evolved and that there isn’t a specific and definitive package of

measures to assess. WG has responded to this alternative in PIQs 156,

156a, 156b and this week in PIQ 156c. WG has attempted to assess the

range of measures which might be advanced e.g. a range involving some

limited improvements to Newport roads and widening limited to the Tunnels

to a package including the full Blue Route and online widening in

accordance with Alternative 19. The alternative was advanced a long time

after the start of the inquiry and there is no quantified BCR for it. In any

event, as there is a considerable element of public transport investment

which is neither specified nor costed the M4CaN model could not be used

to reach a definitive BCR.

232. The inquiry heard evidence on this alternative on 20 March 2018 and it is

not proposed to reiterate in detail the contents of PIQs 156 – 156c. In terms

of the public transport measures the primary difficulty with Mr Waller’s

package is that one cannot simply invest a certain sum of money in order to

achieve a set amount of modal shift. Mr Whittaker has assessed an

ambitious package of measures in ID 73 and the level of abstraction of

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traffic from the M4 is 3.2% - 5.9% in the PM peak depending on the lower

and upper bound assumptions. Though Mr Waller does not accept the

point165 the inquiry is invited to conclude that the measures which have

been assessed are those which have the best potential for extracting traffic

from the M4. Certainly, it has not been suggested by any objector that Mr

Whittaker should have assessed alternative measures instead of those

encompassed within his assessment. Thus, while there may be other

potential forms of public transport investment the ones which have been

assessed by WG are the better ones.

233. We refer to the earlier passage dealing with public transport and modal

shift, paragraphs 169 to 171. The low-lying fruit is contained in the Metro

package. Further efforts to abstract more traffic from the M4 will be

increasingly difficult. Whilst it is appreciated that Mr Waller does not have

the resource to formulate his own public transport package a team of

transport professionals have assessed the scope for modal shift as part of

the M4CaN Scheme. Furthermore, a team of professionals also assessed

the potential for modal shift as part of the solution to M4 congestion during

the M4 CEM process. In both instances, it was concluded that the scope for

modal shift along the east-west corridor was modest. Mr Waller’s statement

that public transport measures would extract 12% of traffic from the M4 is

mere assertion. There is every reason to suppose that achieving greater

abstraction than the figures envisaged in ID 73 will become increasingly

expensive and ineffective.

165 See his response to PIQ 156b at para 6 e.

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234. As for junction closures, that will largely shift motorists to other junctions on

the M4 and/or lead to more congested local roads. The disbenefits of

junction closure have been assessed in the Alternatives Report as

Alternative 22. Those junction closures actually resulted in more traffic on

the M4 because motorists had to travel further on the M4 in order to access

Newport. Junction closure is thus positively harmful.

235. In terms of online widening Alternative 19 involves increasing capacity

between junction 25 and junction 29, including the Tunnels. The benefits of

that are very modest in comparison to the cost with a BCR in the no tolls

scenario of 0.15. The benefits fall as a result of the abolition of the tolls

because the road becomes congested east of junction 25. PIQ 156b sets

out the journey times in 2037 under Alternative 19. They are much slower

than current journey times and the Do Minimum journey times in 2022. Mr

Waller accepts that there is a current problem which needs to be

addressed, albeit he says that it is exaggerated. Congestion under

Alternative 19 in the design year would be significantly worse than it is at

the moment. Mr Waller asked Mr Whittaker about the fact that during the

peak PM levels of traffic along the M4 west of junction 24 drop slightly in

2037 under Do Minimum as a result of the abolition of the tolls166. Mr

Whittaker explained that there was an element of redistribution i.e. more

people travelling over the bridges rather than towards Cardiff, that

congestion east of the Tunnels means that motorists were reassigning on

to local roads and that slow traffic resulted in a smaller flow through the

Tunnels. He explained that there are thousands of links in the model and

166 See tables at ID 248.

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that tables cannot be produced for all of those links. He was clear,

however, that abolition of the tolls increased the need for extra road

capacity. The point Mr Waller seeks to draw, however, from the tables at ID

248 is that abolition of the tolls decreases congestion on the most heavily

trafficked sections of the M4. For the reasons provided by Mr Whittaker that

is not a proper inference. Motorists reassign due to the fact that the queues

start sooner further east. This was explored in greater detail when

discussing the Green Route. Journey times in the Do Minimum increase

due to the abolition of the tolls167 and online widening, of whatever variety,

is insufficient to stop congestion from getting worse by the design year. Mr

Waller says, of course, that he is not committed to Alternative 19. Indeed,

west of junction 25 he favours increasing the capacity of the Tunnels and

employing a . The benefits of such measures cannot be

greater than the benefits of Alternative 19 and are likely to smaller.

236. Of the individual components of Mr Waller’s package one is positively

harmful (junction closing), one provides very poor value for money (online

widening) and the third is incapable of achieving the substantial reduction

of traffic on the M4 which is required (public transport investment). In PIQs

156a and 156b it is explained that these elements will compete to an extent

against each other. However significant or insignificant that effect may be, it

is not the case that the whole is greater than the sum of the parts. There

are other significant weaknesses to Mr Waller’s package; for instance, it will

not provide the resilience and reliability provided by the Scheme nor the fall

in tailpipe emissions provided by the new road. Accordingly, despite the

167 See BW WG 1.2.7 tables 6 and 7

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many thoughtful points made by Mr Waller during the course of this inquiry

his alternative is not worthy of further consideration. WG is already

committed to Metro and those elements will be progressed but they do not

remove the need for the Scheme and do not therefore constitute an

alternative to it.

The economic need for the Scheme

237. The inquiry heard evidence from the CBI, the Chambers of Commerce of

South Wales, the WG’s chief economist Mr Jonathan Price, Mr Tim Gent

on behalf of the developer of the Glan Llyn project and Mr Eddie English in

support of the Scheme on economic grounds. Many others submitted their

support in writing168. The CBI and the Chambers of Commerce had

consulted their members; a clear majority were in favour of the Scheme.

The survey conducted by the Chambers of Commerce distinguished

between the responses of its members from different parts of South Wales.

Interestingly, the strongest support for the Scheme came from the

Swansea Bay Region. The Chambers of Commerce stated that the

congestion around Newport was a bigger impediment to trade and

business growth than the tolls because of the element of unpredictability

and unreliability. The lack of reliability and resilience had adverse impacts

on a whole host of businesses: haulage and distribution; hotels, stadia and

168 The WRU referred to the recurring frustration of visitors to the Principality Stadium as a result of M4 congestion in the Newport area. Network Rail SUP0206 stated: “I am fully supportive of the WG’s proposals for the proposed M4 Corridor around Newport. I believe the project will deliver significant benefits to people, communities and business; ensuring this key transport corridor is able to serve the needs to the twenty-first century Wales”. Other significant transport supporters include Cardiff Airport and the Port of Milford Haven.

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others concerned with convening events; tourism; while all sorts of

businesses stated that people tried to avoid holding meetings in Wales

because of the Brynglas Tunnels. The witnesses from the CBI were also

keen to show that the support for the Scheme came from their members

throughout Wales and not just those in the South East. The CBI made the

point that the impediment was not only a problem in terms of the transfer of

goods and gave the example of the semi-conductor business located east

of the Tunnels which suffered because many of its employees were based

in Cardiff and were caught by the congestion. This is important evidence. It

illustrates that the Welsh economy is already suffering as a result of

congestion, incidents and unreliability along the current road. The

congestion damages the perception of Wales as place in which to do

business; it can also deter new investment from existing domestic

businesses as well as from inward investment. While Mr Bussell’s

evidence reflects these points it is important to note that they are largely

not quantified within the Adjusted BCR169. The Adjusted BCR does not,

therefore, capture all of the likely economic benefits of the Scheme.

238. The Initial and Adjusted BCR of the Scheme is based on the traffic model.

The Initial BCR is based only on the direct transport benefits of the

Scheme. The Adjusted BCR takes into account wider economic benefits.

While the quantification of wider benefits is subject to a greater degree of

uncertainty the Initial BCR fails to capture a range of important economic

benefits. Accordingly, the Adjusted BCR provides the more realistic

measure of overall value for money. Mr Bussell has used the traffic model

169 See Mr Bussell’s proof WG1.3.1 page 13/3.28 and the discussion of non-quantifiable economic consequences paragraphs 5.74 to 5.89.

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results and the costs of the Scheme in order to calculate figures for the

BCR. He states that he has complied with the guidance in WebTAG. No

specific criticism has been sustained that Mr Bussell has made any error in

applying the guidance specified in WebTAG and/or the Green Book. One of

the experts called by objectors, Professor Whitelegg, professed to a

detailed knowledge of WebTAG and he did not criticise the application of

the methodology170.

239. Economic evidence has been adduced in opposition to the Scheme by four

witnesses with relevant expertise – Professor Whitelegg, Professor Jones,

Professor Cole and Dr Melia. Mr Waller also advanced a critique based on

the value of time which Professor Jones also referred to. The inquiry is

referred to the detailed rebuttal statements adduced by Mr Bussell in

response to the GWT and Cycling UK cases.

240. In terms of costs the methodology adopted by Mr Bussell was criticised as

follows. First, it was said that he had not taken proper account of

construction inflation, which was said to exceed the general rate of inflation.

Secondly, it was said that the costs should have included the VAT payable

in respect of Scheme. Thirdly, it was said that large projects typically

exceed their budgets and that the true costs were likely to be significantly

higher than those included in the BCR calculations. These points were all

made by Professor Jones who was the first of the economists to be cross-

examined. As for construction inflation it was apparent that he had simply

adopted a figure provided by Professor Cole. He agreed that he had no

expertise either in terms of national, regional or construction sector inflation

170 Professor Whitelegg did question whether enough options had been investigated at the outset. But he had not participated in M4 CEM and in any event this criticism had nothing to do with the assessment of the BCR.

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and had no challenge to what Mr Bussell said about construction inflation in

his rebuttal. In effect, the first criticism was abandoned.

241. As for VAT, Professor Jones sustained his objection. He said that the VAT

would be paid to the UK government. Professor Jones took a Welsh

perspective in this regard. But when addressing the fact that the Scheme

might cause investment to move from England to Wales he took an UK

perspective and said that such locational impacts did not confer any real

economic benefit. His position was wholly inconsistent. Others have,

however, made the same point with regard to VAT so it needs to be

addressed. The argument is fundamentally flawed. Not only is the inclusion

of VAT contrary to the applicable guidance; it is also illogical when regard is

had to the fact that the BCR is a measure of social or economic welfare.

From a national welfare perspective the payment of VAT is not a true cost:

it is a transfer from the developer of the road to central government. If VAT

were included it would result in inconsistent and arbitrary appraisals: the

value for money of a particular road project would depend on whether it

was being promoted by local, Welsh or UK government. BCRs are used as

a ranking tool and it would be irrational for the same road to be appraised

more highly only when it was promoted by the UK government.

242. It was not entirely clear whether the third criticism was abandoned by

Professor Jones. It was clear, however, that the evidential foundations of

the critique could not be sustained. Professor Jones was not aware of the

fact that the contract was an early contractor involvement (ECI) contract.

Nor did he appreciate that the research which he cited pre-dated the

common adoption of ECI contracts.

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243. The updated position in terms of Scheme cost and the budget allocation for

risk and optimism bias is set out in ID 184. The cost of the Scheme at Q4

2015 prices inclusive of risk and optimism bias allowance is £1,320.8

million.

244. In terms of the calculation of benefits the inclusion of monetised wider

benefits is prescribed by WebTAG. Furthermore, there is no evidential

basis for concluding that Mr Bussell has done anything other than apply the

guidance properly. That, in one sense, is an end of the argument insofar as

the productivity/agglomeration benefits are concerned. These issues,

however, go beyond the calculation of the BCR and therefore will be

addressed. It was Professors Jones and Whitelegg and, to a lesser extent,

Dr Melia who took issue with the proposition that the Scheme would lead to

agglomeration benefits. The relationship between transport investment and

the economy has been addressed comprehensively in the Eddington

Report171 published in 2006 and more recently in the Venables report

published in 2014172. Both were commissioned by government. Neither

Professor Jones nor Professor Whitelegg referred to either report in the

proofs. Professor Jones was not aware of either report when he wrote his

proof of evidence. Professor Whitelegg said that he was familiar with them,

or at least the Venables report but his guiding light was SACTRA 1999. Dr

Melia cited Eddington but only read parts of Venables because Mr Bussell

referred to it in his rebuttal.

245. The evidence of Professors Jones and Whitelegg was deeply

unimpressive. The former said that agglomeration effects did exist but that

171 The Eddington Transport Study. The case for action: Sir Rod Eddington’s advice to government (WG 6.3.2) 172 Transport Investment and Economic Performance 2014 Venables et al (WG 6.1.23)

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they were not applicable in South Wales. He said that the Scheme did not

increase the size of Cardiff or Bristol and therefore there were no

productivity effects. He also said that Metro would not increase productivity.

Finally, he said that Cardiff was a government town and that he could not

think of a recent start-up in Cardiff. These comments were all unsupported

by any research or reference to the economic literature. They also failed to

understand the relationship between transport and economic mass. A

better road or rail link does not literally increase the size of a city but by

making travel easier and quicker it allows a greater number of workers to

congregate thereby enhancing economic density and increasing

productivity. Professor Whitelegg averred that, as a geographer, he was

obsessed with economic density but stated that roads could not lead to

greater economic density. He observed that he was fed up with attending

meetings at business parks which were the antithesis of business density.

Professor Whitelegg simply failed to engage with the literature at all. He

insisted that a paper which he had written was scientific but refused to

apply the same description to the Eddington and Venables reports. Dr

Melia was asked about the detail of the Venables report. The Venables

report is unambiguous about the reality of user benefits and productivity

benefits consequent upon increases in economic density. It is with respect

to the third causal relationship – between transport and investment and

employment – that the Venables report says that “the topic is quite

complex, potentially ambiguous, and lacking a good evidence base”173.

These investment and employment effects are not included in the Adjusted

173 Top of page 3 in the Executive Summary (WG 6.1.23).

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BCR. For reasons which are difficult to fathom Dr Melia was reluctant to

accept that the evidence for the relationship between transport and

economic density/productivity was robust and he appeared to conflate

productivity effects and investment effects. Be that as it may, Dr Melia

agreed that, unlike the authors of the Venables report, he was not an

economist174. Similarly, it was apparent that Professors Jones and

Whitelegg did not have appropriate expertise to comment on the economic

effects of transport investment; their lack of familiarity with the leading

research was merely a symptom of a more fundamental problem.

246. The other major area of dispute in terms of the effects of the Scheme

relates to the two- way road argument. This is the proposition that an area

may lose out economically as a result of better transportation links with a

more prosperous area. It was mentioned by many but the main proponent

was Professor Cole and the inquiry is referred to Mr Bussell’s detailed

rebuttal of his evidence.

247. A number of preliminary matters ought to be noted with regard to the two-

way road argument. First, it does not simply apply to roads. Trains, boats,

cycles and even pedestrians travel in two directions. It is an argument,

therefore, against ease of transport or certainly ease of transport over long

distances. If it is correct, it applies to the electrification of GWR as much as

it does to the Scheme. Secondly, it is a protectionist argument. Thirdly, it is

contrary to WG policy which is to encourage trade and economic

interaction with the rest of the UK, Europe and the wider world. Fourthly, it

is inconsistent with the recent UK policy decision and the long standing WG

174 His university has an economics department and he is not a member of it; he is a member of the Geography and Environmental Management department.

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policy aspiration to remove the tolls on the Severn Crossings: as one of the

witnesses for the CBI observed, the logic of the two-way road argument is

not just to keep the tolls, it is to demolish the crossings. Fifthly, it is

profoundly pessimistic about the ability of the Welsh economy to compete.

Sixthly, it fails to acknowledge that trade is not a zero-sum game.

Collectively, trade between two regions will increase economic welfare.

Seventhly, it ignores the interests of consumers; if consumers move their

custom from a local firm to one in an adjacent region as a result of a road

scheme then the consumers are better off. Eighthly, even if the two-way

road argument is correct, it would have to outweigh the consumer benefits

as well as the productivity benefits consequent upon better intra region

economic mass in order for there to be a net economic cost as a result of

the Scheme. Finally, the Welsh business community, who may be

assumed to have their own interests at the forefront of their minds and not

those of Welsh consumers, are in favour of the Scheme. Either they are

deluded or the two-way road argument is incorrect.

248. These points were put to Professor Cole in cross examination. He was

asked, in particular, whether he agreed with the separate points identified

by Mr Bussell as features of the two-way road argument at paragraphs

3.4.4 to 3.4.10 of his rebuttal statement. Despite some ambiguity he agreed

with most of them. Importantly, he conceded that the argument was

contrary to long-standing and unambiguous WG policy. It was put to him

that there was clear evidence that the Severn Crossings had been a good

thing for the Welsh economy. There was a certain lack of clarity as to

Professor Cole’s response but the upshot was that he was not positively

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disagreeing with Mr Bussell’s assessment that the Crossings had been

positive for the Welsh economy; an assessment based on the studies cited

by Mr Bussell in his rebuttal. It is submitted that the inquiry should dismiss

the two-way road argument. The experts who advanced the argument did

so with little conviction or robust evidence. Mr Bussell, by contrast, looked

at it in detail, both in terms of empirical studies and in terms of economic

theory. The better view is that improved connectivity is a force for

convergence rather than divergence – see the research by Venables and

Rosewell in respect of HS2175. But in any event the two-way road argument

is clearly contrary to policy and contrary even to the stance of those who

advocate for better public transport.

249. The Adjusted BCR is 2.29. A number of objectors have said that the

Scheme is a low or medium value scheme. These remarks are made on

the basis of the categorisation of value employed by the Department for

Transport. The categorisation has no status or applicability in Wales.

Nevertheless, Mr Bussell explains in his rebuttal to Cycling UK that the

value for money categories are based on the Adjusted BCR and can, in

appropriate cases, take into account non-monetised wider impacts. It is

clear, therefore, that if this Scheme were in England it would be

categorised as a High value project176.

250. The Adjusted BCR is based on the traffic model. The traffic model deals

with normal conditions and cannot be used to replicate the incidents which

lead to extraordinary queues and the gridlocking of the wider road network

in Newport. Nor does it deal with the disadvantages of a lack of journey

175 Cited by Mr Bussell at paragraph 3.4.5 of his rebuttal of Cycling UK’s evidence. 176 Steve Bussell rebuttal of Cycling UK, paragraphs 3.2.6 to 3.2.8

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time reliability i.e. the need for motorists to assume a worse case and thus

to leave too early resulting in dead waiting time. In PIQ 164 Mr Bussell has

considered the likely scale of these additional benefits. There is a degree of

uncertainty given the lack of an established methodology. If the Adjusted

BCR is revised to take into account these resilience and reliability benefits

it increases to 2.63. There is a spurious precision to the figure but it gives a

flavour of the significance of these additional benefits.

251. In conclusion, the current problems on the existing M4 impose a penalty on

the Welsh economy. The Scheme will increase productivity within the study

area and boost trade within Wales and between Wales and the wider world.

These productivity and competition effects will be enjoyed even by those

who do not travel along the corridor. The two-way road argument is wrong,

a counsel of despair and, in any event, contrary to policy. The argument

advanced by Mr Waller and Professor Jones as to the need for local values

of time is also contrary to policy and caught, thereby, by the Bushell

principle. But it also wholly contrary to the FG Act as the adoption of local

values of time would favour investment in prosperous areas at the expense

of those which are deprived, often partly as a result of poor transport links.

The WG does not pretend that a new road is a panacea. But good and

reliable transport links is an essential part of the policy mix required in order

to grow the Welsh economy. The M4 is the gateway to two thirds of the

Welsh economy. It has been a recognised problem for some 25 years. The

economic case for the Scheme is, it is submitted, compelling.

Carbon

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252. The WG is subject to duties in respect of tackling climate change and

reducing greenhouse gas emissions under Part 2 of the Environment

(Wales) Act 2016 and under the Future Generations Act 2015. The WG

have conducted a detailed and comprehensive assessment of the carbon

implications of the Scheme. That has been led by Mr Tim Chapman who

has also presented the evidence to the inquiry. Mr Chapman is singularly

qualified to address this topic, having an established track record and

expertise in promoting low carbon construction. He states that the Scheme

is essentially carbon neutral. That, he says, is quite unique for a new road.

In essence, it is because the road is a bypass of a pre-existing bypass

which is longer and suffers from congestion. Traffic which therefore

reassigns from the existing road to the new road will inevitably emit less

carbon. The new road will, however, induce more traffic but this has been

modelled and the savings generated by the shorter and more economical

journey along the new road will more than compensate for the additional

vehicle kms. Mr Chapman has calculated the capital carbon cost of all the

construction work, and revised upwards that estimate to take account of the

works at Newport Docks. He has done so by assessing the carbon cost of

each element of the construction.

253. The user carbon has been calculated by reference to VISSIM which is able

to take into account the carbon implications of accelerations and

decelerations and is not limited to an assessment based on average

speeds. Due to the modelling complexity the VISSIM analysis has been

limited to the existing M4 and the new road. That renders the assessment a

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conservative one. The new road attracts traffic not just from the old M4 but

also from the local road network. Equally, the reclassified M4, which will be

less congested,177 will also attract journeys from the local network. As is

apparent from PIQ 37 the SATURN modelling suggests that there will be

carbon savings on the wider network. These savings, however, have not

been included in the carbon neutrality calculation. Another conservative

feature of the assessment relates to the fact that the VISSIM analysis is

based on normal driving conditions. It does not, therefore, take account of

the adverse carbon implications of extraordinary congestion which results

from incidents and accidents. As confirmed by Mr Whittaker the existing

road is blighted by such incidents whose effects are aggravated by the

absence of a continuous hard shoulder. It is reasonable to expect that the

Scheme and the reclassified road will be less likely, in aggregate, to suffer

from these incidents. Furthermore, when these incidents do occur the

network will have much greater resilience: traffic will reassign from the

impeded road to the incident free road and while congestion could be

expected it will be much less significant than the congestion which afflicts

Newport when there is an incident under the Do Minimum.

254. Following Mr Chapman’s evidence in chief and primary cross examination

by GWT and others there have been three developments which have an

impact on the carbon assessment. First, the UK government decided to

abolish the tolls. Secondly, the UK government announced that the sale of

new petrol and diesel cars would be prohibited from 2040. Thirdly, the

agreement between ABP and WG resulted in a delay in the opening year to

177 And more accessible due to the reopening of a junction

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2024 and a commitment to carry out substantive works at Newport Docks

which would impact on capital carbon. Mr Chapman has dealt with these

matters in two updated proofs issued in December 2017 and in his rebuttal

of Cycling UK’s revised evidence in March 2018. He has assessed

qualitatively the abolition of the tolls; it is likely to increase the tail pipe

emissions savings occasioned by the Scheme. He has also qualitatively

assessed the government’s announcement with regard to electric cars; it is

likely to decrease the tail pipe emissions savings occasioned by the

Scheme thereby postponing carbon neutrality. In terms of achieving the

carbon targets under the 2016 Act quicker de-carbonisation of private

vehicles is a good thing. The delay in opening year will not make any real

difference: it will postpone the carbon neutrality year by 2 years but only to

reflect the delay in the commencement of the user carbon savings. Finally,

the capital carbon of the works in Newport Docks has been assessed at

57,000 tonnes. That will postpone carbon neutrality by 4 to 5 years. In Mr

Chapman’s judgment the revised carbon neutrality date of 2078 remains

conservative.

255. It was suggested during the inquiry by some objectors that the fact that

carbon neutrality would be reached beyond 2050 was inconsistent with the

duty under the 2016 Act to cut emissions by 80% by 2050. GWT make a

related point in their closing speech where it is said that incurring either half

a million tonnes or a million tonnes of capital carbon will not help the WG

reduce carbon emissions by 80% by 2050178. Both criticisms betray a

fundamental misunderstanding of the 2016 Act and indeed the UK’s

178 Page 12 of GWT’s closing

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Climate Change Act 2008. The 2050 target relates to emissions in that

year. The capital carbon associated with the Scheme will be incurred by

2024. It will not, therefore, have any bearing on the 2050 target. The

Scheme itself will make a positive contribution towards the 2050 target and

all interim targets and carbon budgets post-dating 2024 because user

carbon is lower under Do Something than it is under Do Minimum.

256. GWT adduced evidence from Professors Whitelegg, Whitmarsh and

Anderson. Professor Whitelegg took issue with Mr Chapman’s analysis in

terms of capital carbon and user carbon. In respect of the former he applied

a top down estimate based on the correlation between capital expenditure

and capital carbon. He cited a paper dated May 2015 from four academics

a Leeds University at Annex 1 of his proof. On the penultimate page of that

paper it is said:

“Bottom-up estimates of embodied emissions are often preferred

owing to their greater specificity and reduced dependence on

monetary proxies. However, two principal barriers prevent a

bottom-up estimate in this instance: the lack of emissions data

for certain infrastructure categories; and the presence of

aggregated/unspecified expenditure data in the NIP”

257. This passage was put to Professor Whitelegg. The Leeds University paper

was concerned with calculating the capital carbon of all planned national

infrastructure projects in the UK. In that context, a top down approach was

understandable given the barriers to undertaking a bottom up estimate

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identified in the quoted passage. But it is quite clear that in assessing a

single project a bottom up estimate is preferable. Professor Whitelegg

would not, however, accept that Mr Chapman’s assessment of capital

carbon was more likely to be correct. He stuck to his guns as he did with

the claim that the new road would quickly become congested. He said that

he would like to discuss the matter with Mr Chapman and that it was not a

matter for cross examination. It is submitted that Mr Chapman’s

methodology is the correct one; expenditure is only a rough guide to capital

carbon and top down assessments are only appropriate where there is

paucity of detailed information. Insofar as user carbon is concerned

Professor Whitelegg was reluctant to acknowledge the advantages of the

Scheme insofar as user carbon was concerned; namely, that it was short

and would alleviate congestion.

258. Ironically, Professor Anderson also gave an estimate for the capital carbon

of the Scheme. He too criticized Mr Chapman for the methodology and

suggested that it was insufficiently rigorous. However, his estimate was in

the region of a quarter of Mr Chapman’s assessment and one eighth of

Professor Whitelegg’s. Clearly it is not possible for Professor Whitelegg

and Professor Anderson to be correct. We submit that both are wrong.

They employed high level estimates and came to radically different figures.

Mr Chapman, by contrast, undertook a detailed and bottom up estimate

which takes account of the particular characteristics of the Scheme. We

invite you to accept his evidence as to capital carbon and user carbon in its

entirety.

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259. The main thrust of Professor Anderson’s evidence was that carbon

emissions had to decrease by 12 to 16% per annum if the objectives of the

Paris Agreement were to be met. He agreed that reductions at that rate

would mean that Welsh emissions of carbon would fall way below the 2050

target of 20% of 1990 levels. He also agreed that the 2016 Act was

enacted after the Paris Agreement. The relevant policy and legislation is

therefore the targets and budgets set under the Environment (Wales) Act.

To the extent that the Paris Agreement as construed by Professor

Anderson mandates much greater reductions in carbon emissions then it is

the targets under the 2016 Act which prevail. In short, Professor

Anderson’s advocacy of rapid decarbonisation beyond that required by the

2016 Act is not a matter for the inquiry as it offends the Bushell principle.

260. Professor Whitmarsh’s evidence did not descend into the quantification of

effects. She said, however, that the Scheme was inconsistent with the

obligations on WG under the FG Act to promote a low carbon economy.

She also claimed that there was no evidence of the integrated thinking

required to abide by the sustainable development principle. It became

apparent, however, that though based in , the Professor

had little knowledge of the Scheme and was unaware of the junction

strategy which had been informed by the desire to promote modal change

at Glan Llyn and at Junction. While she expressed the view

that park & ride schemes could have perverse consequences she did

welcome the facilitation of the use of park & ride and conceded that there

was evidence of the kind of integrated thinking which she advocated. Her

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evidence did nothing to undermine Mr Chapman’s evidence or, indeed, that

of Mr Davies MBE.

261. In conclusion, we submit that the Scheme is effectively carbon neutral. In

that sense it is rare, if not unique, in terms of road building projects. It is

wholly consistent with WG’s duties under the 2015 and 2016 Acts.

Design / Land take

262. Mr Sibert demonstrated by means of detailed plans the need for each

individual plot in the CPOs in order to construct the Scheme and the

mitigation works in the Docks.

263. Dr Ireland, supported by other members of WG’s ecology team, Mr Graham

on water quality and Mr Rowson on landscape, demonstrated, by means of

the detailed Environmental Mitigation Plans (“EMPs”) which land was

included in the CPOs for such purposes and justified the need for it. As

noted above, they explained how the line of the road had been kept low in

the landscape to minimise visual impact and located as far north in the

Levels as possible to minimise SSSI land take and avoid the LOHI, in

compliance with duties under s.28G Wildlife and Countryside Act 1981

(“WCA 1981”), EWA 2016 and the FGA. Minimising land take is also

relevant in terms of the proportionality considerations arising under the

CPO circular.

264. As recalled above, Mr Rowson used the ‘flythrough’ video simulation as a

visual aid. Mr Matthew Jones explained that this innovative resource was

developed for use in the public consultation process and it included the

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facility for members of the public to zoom in on their own homes or areas of

particular interest, to understand in 3D how the Scheme would affect them;

this was one of the techniques used to help members of the public to

understand the project and the implications for them and their property.

265. There is no objection to the need for or design of the bridge resilience

measures in the Docks which are to be enabled by the Supplementary

CPOs. Messrs Sibert and Finlay (deputising for Mr Woodman) explained

how the protection measures would be constructed, using a marine jack up

platform to drive sheet piles. The platform could be brought in by sea via

South Lock and Dock.

266. The land taken from ABP and its tenants beneath the proposed bridge deck

would be offered back in the form of lesser interests / rights, on terms

consistent with ensuring safety of the motorway and proper access for the

WG’s highway maintenance teams. Mr Sibert’s evidence was supported by

fire risk assessments carried out by specialists in the field. The approach

has therefore been to minimise the degree of interference with property

interests and with business operations.

267. Mr Sibert also explained the proposals for a swing bridge to meet the

severance point raised by ABP and several of their tenants. Inclusion of

this feature would facilitate a perimeter access route around South Dock,

along with a new Private Means of Access, also provided for within

Supplementary CPO No.3. The bridge would be capable of accommodating

ABP’s mobile cranes, thus reducing the need otherwise to provide extra

cranes by way of mitigation. There is a local precedent for such a swing

bridge operating successfully at .

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268. There was no real challenge to Mr Sibert on these points, but he explained

the details to Mrs Picton MBE when she understandably sought

clarification.179

269. Remaining objections from tenants180 must be considered in the light of the

fact that WG’s agreement with ABP requires it to use best endeavours to

achieve a relocation of most significantly affected tenants to the south of

South Dock or alternatively to make minor alterations to premises,

especially those located alongside the proposed Docks Way link. The

exception is the business of Jewsons Limited and St Gobain Limited who

will remain in situ in North Dock. They will be provided with alternative

areas of land during construction in order to mitigate impacts and land will

be returned with lesser rights in order to enable them to use land

underneath the motorway bridge for storage of timber. A mechanism

therefore exists for meeting the tenants’ practical requirements by means of

suitable relocation, all parties having a clear incentive to do so. In the

event that accommodation cannot be reached, then the tenants would be

compensated on normal statutory principles. Given the overriding need for

the Scheme, this clear mechanism for seeking to achieve, with their

consent, practical reinstatement and the availability of statutory

compensation in the last resort, the proposed land take is justified and

proportionate.

270. Island Steel are also located adjacent to North Dock and are supporters of

the scheme.181

179 Inquiry 28.02.2018 supplemented by PIQ/166 180 The identities of whom are set out in Annexes 1 and 2 181 SUP0220

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Air Quality and Noise

271. The inquiry has heard evidence from Dr Michael Bull in respect of air

quality and Mr Philip Evans in respect of noise. These two fields are

matters for expert evidence and none of the objectors have adduced their

own expert evidence. Both witnesses gave their evidence in a

straightforward and knowledgeable manner. Their evidence is

unchallenged and you are invited to accept it in its entirety.

272. The Scheme provides net benefits in terms of noise and air quality. That is

because the Scheme reduces the traffic on the existing M4 by about one

half (and around three quarters for the heavier polluting HGVs). The

existing M4 passes along and in some sections through the north of

Newport. The Scheme, by contrast, passes through a predominantly rural

and lightly populated area.

273. In terms of noise, Mr Evans concludes that while there are some who suffer

a noise detriment, much greater numbers enjoy a benefit. On the whole, he

concludes that there is a clear net benefit in terms of noise with the

Scheme. The average decrease is -1.2 dB per property across the 20,708

properties in the opening year. Put another way, there is approximately a

57,500 ‘dB people’ improvement as a result of the Scheme in the opening

year182. There will be adverse impacts during the construction phase but

these can be mitigated to acceptable levels. Most of the detriment occurs in

the Gwent Levels which generally enjoys lower levels of noise though it

does not, in Mr Evans’s judgment, qualify as a tranquil area. It is

acknowledged and accepted, of course, that benefits to others will be scant

182 See paragraph 2.4 of WG 1.14.5

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consolation to those who will suffer a detriment, including for example the

Llandevenney Residents, who gave evidence to the inquiry. Mitigation

measures such as noise barriers where practicable, expedient and

appropriate having regard to landscape and visual amenity considerations

will be employed, but Mr Evans gave evidence to the effect that they would

not be considered in that location. Furthermore, whilst the new road will be

built with a thin road surface system which is relatively low noise, there will

be residual impacts on some properties. That is an inevitable result of a

road scheme of this nature and the detriments must be weighed against the

significant benefits of the scheme.

274. The picture is much the same in respect of air quality. Air quality would

generally improve in the more populated areas reducing overall exposure

to air pollutants but inevitably deteriorate in areas alongside the proposed

new section of motorway. However, no exceedance of air quality standards

would be expected and air quality would particularly improve in the areas

that are currently the most polluted including the Air Quality Management

Areas. These AQMAs are adjacent to the existing M4. In terms of human

health, therefore, the Scheme has an overall beneficial impact.

275. It must be acknowledged that there will, however, be detriments to some

properties. The changes in traffic flows from the removal of tolls results in

predicted NOx concentrations being above 30μg/cubic metre at the two

receptors located closest to the proposed M4 in the Gwent Levels - St

Brides SSSI. As compliance cannot be assessed within 5 km of a

motorway, this does not represent an exceedance of the air quality limit

value. The critical loads for nitrogen deposition are not exceeded at any

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receptor modelled within the Gwent Levels - St Brides SSSI (or on the

Caldicot Levels SSSIs). There is, therefore, no unacceptable ecological

impact and overall the effects of the Scheme in terms of air quality and

noise are beneficial. Where there are detriments, these must be weighed

against the significant benefits of the Scheme.

Delivery of National and Local Policy Objectives

276. The review of planning policy and national strategy above and, in particular,

the evidence of Messrs John Davies MBE, Mr Matthew Jones and

consideration through the CEM process and examination of alternatives at

this inquiry, substantiate the need for the Scheme in order to give effect to

national policy as set out in the Programme for Government. Supporters of

the Scheme give voice, in practical terms, to the need from the perspective

of those living, working, running businesses, services and organisations in

South Wales.

277. WRU state that “we attract a significant spectator base when hosting

significant events at the Principality Stadium and it is currently a recurring

frustration of our visitors to deal with the M4 congestion that occurs in the

Newport area. We believe that only the Black Route can provide the

solution that is required” 183.

183 SUP0214

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278. The WG Chief Economist Jonathan Price said, “a new, more efficient M4

would have the potential to greatly improve transport efficiency and provide

a significant boost to the ”.184

279. Cardiff Airport states, “the proposed improvements to the M4 motorway

would be a significant benefit to Cardiff Airport. It is well documented that

improving surface access to an airport can encourage growth and improves

the opportunity for the region in which the airport provides services, to

better compete in a global market”. 185

280. CBI state, “only the Black Route can provide what is required, i.e. a safe

and resilient primary route around the bottleneck that is the Brynglas

Tunnels”.186

281. ICE Wales offer full support for the Welsh Government’s proposals as

published. 187

282. South Wales Chamber of Commerce state, “it will make inter-regional and

international trade easier for businesses throughout South

Wales…ensuring that Wales has an effective transport infrastructure will

raise the international profile of Wales as a whole as an accessible and

well-connected place in which to work and live”. 188

283. Port of Milford Haven say, “Improvements to this route could potentially

open up new markets for port development, stimulate further investment

and create opportunities for additional trade from this area to the rest of

Europe”.189

184 SUP001 185 SUP0194 186 SUP0167 187 SUP0005 188 SUP0132 189 SUP0031

C:5493828v1 160

284. The Welsh Government’s proposals to ease congestion on this part of the

M4, the main transport artery to South Wales, is broadly welcomed by Tata

Steel.190

285. The list of incidents reported in the Press191 goes a long way to explaining

these reactions to the current situation and to the prospect of the Scheme.

INTERFERENCE WITH HUMAN RIGHTS

286. Relevant Human Rights are contained in Article 8 and Article 1 to the First

Protocol. Article 8 provides as follows:

“Right to respect for private and family life

1 Everyone has the right to respect for his private and family life, his home and his correspondence. 2 There shall be no interference by a public authority with the exercise of this right except such as is in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.” (emphasis added)

287. This right is engaged in relation to those in respect of whom the Scheme,

Highways Orders and/or CPO impinge physically upon their homes.

288. Article 1 to the First Protocol provides as follows:

" (1) Every natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law.

(2) The preceding provisions shall not, however, in

190 SUP0138 191 ID 136

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any way impair the right of a state to enforce such laws as it deems necessary to control the use of property in accordance with the general interest or to secure the payment of taxes or other contributions or penalties.” (emphasis added)

289. This right is in engaged in relation to all owners of property, whether

domestic or business premises. Annex 2 to these submissions lists all

statutory objectors whose human rights under these two provisions are

engaged.

290. Both rights are qualified. In each case, WG submits that the very strong

need which it has demonstrated for the new road in terms of the economic

well-being of Wales (Art.8) and the general interest (Art.1 to First Protocol)

is sufficient to justify the inference. The interventions are proposed under

clear, known legal provisions within a statutory process which ensures a

“fair and public hearing within a reasonable time by an independent and

impartial tribunal established by law” in accordance with Article 6 and

makes provision for compensation on known principles, as confirmed by

the House of Lords in Alconbury, a case which considered, amongst

others, compulsory purchase under highways schemes and orders. The

Inquiry has provided a forum for statutory objectors to challenge the WG

evidence and the Scheme has survived intense scrutiny.

291. WG’s evidence shows how steps have been taken to minimise land take

and to work with farmers, businesses and other landowners to minimise

interference with their interests. Details in respect of each individual

objector are available in Annex 2 and matters are dealt with more generally

in these submissions. In short, WG’s submission is that there is an

overriding need for the Scheme and CPO with all attendant Orders. The

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required interference with property rights and, in some instances, homes,

are justified for the good of wider society.192

292. Some objectors have seen the positions and resources of the WG and

themselves as ill matched, raising, more or less obliquely, the question of

equality of arms.193 The clearest articulations of this point came in Mr

Hall’s written submission and Cllr Frances Taylor’s appearance at the

inquiry on behalf of Magor and Undy Community Council. However, in

considering these points, it must be remembered that equality of arms

under Art 6 applies, if at all, to the Public Inquiry and not to the consultation

process.

293. Mr Hall is a resident of Redwick but not a statutory objector because none

of his land or property is the subject of the Orders. He said:

“it seems unreasonable that so much money and professional Public

Relations expertise has been put into the events supporting the

plans when similar resources have not been made available to

groups such as the GWT who see the proposed road as

unnecessary and disastrously damaging to the environment. This is

totally unfair, especially as such an imbalance is likely to be

repeated at any Public Inquiry.” This extract apparently raises two

points about balance: balance at the consultation stage and in the

Public Inquiry.

192 See. OBJs 227 and 231 193 Mrs Ann Picton MBE (OBJ0203-007a Inquiry Proof “THE IMPORTANCE OF THE INQUIRY”, “INTRODUCTORY STATEMENT para 02”; OBJ 0132 Mike Hall, first para.; Cllr Frances Taylor on behalf of Magor with Undy Community Council; Mr Byrne on behalf of GWT and Dr Lindstrum on behalf of CALM made similar comments in passing during their oral presentations

C:5493828v1 163

294. Dealing with consultation first, Mr Matthew Jones, in his written evidence

and on more than one occasion in answer to objectors at the inquiry,

responded to criticisms of the public engagement process in relation to the

Plan and the Scheme. For example, County Councillor Frances Taylor

(Magor and Undy Community Council) raised concerns regarding the

quality and availability of information, including at the Public Exhibitions.

WG’s response to the evidence of County Councillor Frances Taylor194

explains that engagement on the problems, objectives and possible

solutions to the M4 around Newport has been ongoing since the early

1990s. Significant efforts were made to help people with an interest in the

proposals to understand the available information and have any queries

addressed appropriately. As was recorded in the 2015 Public Information

Exhibitions Report195, an evaluation survey of attendees showed 90%

‘tended to agree’ or ‘strongly agreed’ that the exhibitions helped them to

understand the proposals. Furthermore, 92% selected ‘YES’ on a

touchscreen computer which asked “Have you found all the information you

wanted today? YES / NO”. In addition, a designated Public Liaison Officer

aims to help people contact the project team to help address any concerns

or queries where possible. As explained to the Inquiry and Future

Generations Commissioner in the WG response 196, engagement as part of

the development of the draft Plan was cited by Climate Change Wales as

an exemplar engagement exercise 197. As part of the draft Orders

exhibitions, it was recognised by the project team that the public often have

194 WG/REB/OBJ150 195 http://gov.wales/docs/det/publications/170117-m4-corridor-aroundnewport-en.zip 196 WG/RS/ISU0024 197 PIQ-78: Climate Change Commission in Wales 2012 - Position Paper for Transport and Climate Change for Wales

C:5493828v1 164

difficulty in visualising projects particularly in relation to their own concerns

- ‘what will this proposed development look like from my home?’ In

response to this, an innovative 3D computer model with ‘postcode finder’

tool was developed. This used video game technology alongside

engineering modelling in order to provide bespoke visualisation for

thousands of people. This is one of the first times that the combination of

gaming technology and engineering modelling has been employed in the

UK. The noise specialists also produced a noise assessment tool

searchable by postcode. This innovative approach enabled people to

engage with the Scheme proposals and understand what the likely impacts

on their properties and local communities would be if it went ahead.

295. It must also be remembered that the Plan was the subject of an

unsuccessful judicial review by the professionally represented FoE Cymru

based, amongst other things, upon the Blue Route proposal which was

worked up by Professor Cole, who is a transport planner and transport

economist.

296. Turning now to the Public Inquiry, there has been some consideration by

the courts of Equality of Arms in public inquiries in the context of Art 6 of

the Convention. R v The Secretary of State for the Environment Transport

and the Regions ex p. Challenger CO/2048/2000 was an application for

permission to appeal against the refusal of leave to bring a judicial review

claim arising out of the public inquiry into Thameslink 2000. Mr Challenger

was the tenant of a property where he lived and worked, which was

proposed for acquisition, so he was a statutory objector to the CPO and his

human rights under Art.8 and Art. 1 to the First Protocol were engaged. He

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also sought to bring proceedings in the name of a residents’ association of

which he was a member. The association was promoting an alternative.

Leading counsel on their behalf submitted at the Pre Inquiry Meeting that,

unless they were given assistance in presenting their case, there would not

be equality of arms between them and the promoters, Railtrack, since the

issues were substantial, complex and highly technical and, accordingly,

there would be a breach of Mr Challenger’s Art 6 right to a fair hearing. The

submission was that either Railtrack or the Secretary of State should fund

representation or that counsel to the inquiry should be appointed. The

inspector rejected the submission, saying, amongst other things, that he

and the programme officer would “go out of their way to assist those who

are unfamiliar with the process, or who are not represented to the same

degree as the principal parties.” He also referred to the possibility of

seeking Legal Aid. Railtrack which was represented by leading and two

junior counsel, refused to fund them, as did the Legal Services

Commission. Permission was refused on the basis that the Human Rights

Act 1988 was not yet in force, but the Judge considered the substantive

point and made some useful observations. Firstly, he said that the question

under Art 6 must be determined by reference to the particular facts and

circumstances of the individual case. He regarded as significant the facts

that Legal Aid had been sought and rejected, that other parties who were

represented would be taking similar points at the inquiry and, in particular,

promoting the alternative and he said that there was scope for the

applicants to join forces with or liaise with other objectors. He alluded to the

impressive material produced by them for the Court case with the aid of pro

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bono assistance and said that he also relied upon the inspector to give

such assistance as he could, consistent with his impartial role, in the event

that pro bono professional help ceased. He therefore considered that their

access to the tribunal would be “practical and effective, not theoretical or

illusory”, tests drawn from the European jurisprudence in other types of

case.

297. The next case is Pascoe v. First Secretary of State [2007] 1 WLR 885. It

concerned a CPO made in respect of Ms Pascoe’s residential property.

Article 8 and Article 1 of the First Protocol to the Convention were therefore

engaged. She claimed that she had been deprived of the right to a fair

hearing under Art 6 because she had been denied Legal Aid for the inquiry.

The claim succeeded on other, substantive grounds, but the Judge

considered the Art 6 point as well. The promoters of the CPO were

represented at the inquiry by leading and junior counsel and a large and

well resourced firm of solicitors. As in Challenger, Legal Aid was sought

and refused and a similar application for funding from the promoter was

made at the Pre Inquiry Meeting. The inspector rejected that application

and suggested that an approach be made to the Secretary of State. The

Judge noted that the absence of any express provision in Art 6 requiring

the provision of legal aid in civil cases meant that any implied obligation will

be less extensive than the express right to such assistance in criminal

cases. In these circumstances, the relevant State has a free choice as to

how to ensure an effective right of access. He said: “it is relevant that the

tribunal conducting a hearing takes steps to ensure that the individual is not

disadvantaged in presenting his or her case effectively and goes into

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matters in care and detail to ensure that the case in understood. This will

be particularly relevant as a factor in the context of an inquisitorial

procedure such as applies in a planning inquiry, in which the task of the

inspector is to get to the real facts and form his own judgment in the light of

his own inquiry”198… “I accept that inquiry procedures are designed to be

more user-friendly and les complex than those found in the courtroom.

Individuals are enabled to present their own cases, and inspectors will

normally adjust the inquiry timetable to facilitate matters for those seeking

to put her case”.199

298. The Judge also had regard to the fact that Ms Pascoe had benefited from a

considerable amount of pro bono legal assistance and other support from

witnesses and experts. Summarising his conclusions, he said that he was

satisfied that Ms Pascoe had, in fact, been given “a reasonable opportunity

to present her case which is the essence of the requirement of ‘equality of

arms.’” He based this view on the following facts:

i. The claimant received the benefit of assistance from the

inspector and a solicitor in the period before the inquiry. The

claimant’s solicitor, a leading expert in compulsory purchase

law, drafted a letter of objection in response to the agency’s

statement of reasons. Counsel for the claimant drafted for her

the application for pre-emptive costs that was submitted at the

pre-inquiry meeting on 22 July 2005.

ii. During the inquiry itself, the claimant had at various times the

assistance of two barristers, acting pro bono, who attended the

198 Para 102 199 Para 108

C:5493828v1 168

inquiry for three days, cross-examined some of the agency’s

witnesses and submitted opening and closing submissions to

the inquiry.

iii. The claimant had a diploma in architecture and a degree in

environmental science. She would therefore have had a much

better grasp of the issues at the inquiry than would the ordinary

lay objector.

iv. Another statutory objector, Mr Gwynne, who assisted the

claimant at the inquiry and cross-examined a number of the

agency’s witnesses, held professional qualifications in

architecture. The claimant clearly benefitted from his expertise

during the inquiry.

v. Despite her limited resources, the claimant was able to obtain

evidence and/or appearances from many witnesses, including

several high-calibre public interest groups, academics and local

politicians.

vi. Eversheds, the solicitors acting for the agency, provided

substantial administrative and technical support to the claimant

before, during and even after the inquiry. This was done free of

charge. It is clear that the claimant received very considerable

assistance in this way (estimated at approximately 75 hours in

all).

vii. Although additional evidence was served by the agency on the

penultimate day of the inquiry, the claimant did not seek an

adjournment and, in the event, the claimant’s witnesses

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successfully responded to the evidence by e-mail to Eversheds

on the last day of the inquiry. Further it is clear that the inspector

for the claimant had the benefit of seeing the evidence served

by the agency on 26 October 2005 before drafting the closing

submissions on the claimant’s behalf.

299. Drawing these matters together, it is noticeable:

i. that both these claims concerned public inquiries similar to this

one;

ii. that both these claims failed;

iii. that the clear approach of the Courts is to assess whether

relevant people, whose Art 6 right is engaged, have had a

reasonable opportunity to present their cases on a case by case

basis;

iv. that the inquisitorial and relatively flexible nature of a public

inquiry, as opposed to Court proceedings, is highly relevant,

including an assessment of the way in which inspectors have

facilitated unrepresented persons to make their cases;

v. that it is relevant to take account of any professional support /

assistance received, both from legally qualified and other

relevant professionals, as well as any relevant skills possessed

by the applicants themselves.

300. Mr Hall is not a statutory objector. He chose not to make oral

representations to the inquiry. Dr Lindstrum is not a statutory objector, but

has made oral representations, both in her own right as a local resident and

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on behalf of the umbrella organisation CALM. Mrs Picton MBE is not a

statutory objector by virtue of any interference with her property or home.

She has appeared. Their human rights are not engaged. Art 6 therefore

does not apply in their cases.

301. Cllr Frances Taylor is not a statutory objector in the sense of any of her

property being the subject of the CPO. She appeared by virtue of her role

as the ward member for Magor on MCC and as a member of the Magor

and Undy Community Council speaking on behalf of local residents. Her

human rights are not engaged. Some of her constituents are statutory

objectors by virtue of their property interests being in the CPO, some of

which concern their homes, but Cllr Taylor did not claim to be speaking on

behalf of any individual resident/s in particular. No submissions about any

individual’s human rights generally or Art 6 compliance in particular were

made. Nor was any request made to the inspectors for funding or other

assistance.

302. GWT is a statutory objector by virtue of its ownership of Magor Marsh. Art 1

of the First Protocol is therefore engaged in GWT’s case and, parasitic

upon it, Art 6.

303. No application has been made by anyone to the inspectors for a direction in

respect of either funding or appointment of counsel to the inquiry.

304. GWT have been ably assisted and represented by an impressive team of

counsel who have volunteered their services. The fact that those barristers

have been working pro bono (like Mr Challenger’s barrister) has not

diminished the quality of their contributions. Mr Byrne, who is an employed

officer of GWT holds relevant qualifications, with degrees in Geography

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and Biology and a Masters in rural Environmental Management. Mr Byrne

is also a Chartered member of, and Assessor for, the Chartered Institute of

Ecology and Environmental Management and has wide relevant

experience. On occasions, he engaged in advocacy on behalf of GWT, but

chose not to give oral evidence although he submitted several detailed

written statements in his own name. GWT have been able to present

evidence from a number of academics and professionals in relevant fields

of expertise, several of whom have appeared to present evidence, called

and re-examined by counsel, who have, when so instructed, also cross

examined WG’s witnesses. GWT have liaised with other objectors, taking

on an umbrella role and drawing upon the contributions of other

organisations. RSPB’s expert employed officers have been involved in

many discussions with WG. CPRW and the Woodland Trust were both

represented at the inquiry by employed officers with relevant qualifications,

who gave evidence, called and re-examined by counsel. On occasions,

GWT have been allowed further opportunities to cross examine WG

witnesses in separate sessions by Mr Byrne. Dr Lindstrum, whilst not an

expert in highway modelling, is a highly educated woman with an expertise

in what she referred to as “narrative.” GWT have produced a large amount

of written material in response to WG’s evidence, often from expert

witnesses, right up to the end of the inquiry.

305. Mrs Picton MBE deserves special mention and tribute. She is also a highly

educated person – a retired school teacher, she has a degree and a PGCE

qualification. She has come to occupy a central role in the inquiry, having

attended almost every session. She has prepared herself by reading

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relevant material in advance and come with questions in mind, often written

down in her notebook. Her questions have been thoughtfully put to

witnesses, and she has received assistance from the inspectors on

occasions to refine them so as to get to the heart of the points which have

interested her. As well as the inspectors, members of the WG team have

gone out of their way to answer queries and provide her with documentary

and other material to assist her in putting forward her case. She has

graciously acknowledged this assistance on more than one occasion.

When it came to her own evidence, however, she said very clearly, in

writing200 and orally, that she wanted to give a different type of evidence

from that given by experts in the various technical disciplines – her

perspective on things. This she ably did and, having answered a few

questions of clarification, was, quite properly, not cross examined on

matters so close to her heart.201

306. In conclusion, this is a public inquiry which has involved a large amount of

technical evidence but one where people have also been able to present

their cases in their own ways, assisted by the understanding of the

inspectors. There has been flexibility and consideration in terms of timing

appearances given by the programme officer and inspectors, to ensure that

everyone who wanted to speak had the chance to do so in an atmosphere

of order but not of undue formality. The Public Inquiry forum has therefore

been accessible to all of those who might wish to participate.

Marshalls

200 Mrs Picton MBE is OBJ0203 and her closing statement is ID255 201 After her presentation, Mrs Picton MBE thanked leading counsel for WG for her understanding and gave her a hug

C:5493828v1 173

307. Marshalls Mono own and operate a site on the eastern bank of the Usk

which is required for the construction of the road and the Usk Crossing. It is

accepted that they would not be able to operate from this site as a result of

the Scheme. The operation would have to be re-located. The company is a

significant employer and both it and WG would wish it to find an alternative

site locally in Wales. To that end WG has offered Marshalls a site owned by

it, known as Queensway Meadows.

308. On 19 June 2017 Marshalls appeared at the inquiry. Their position at that

time was that the Queensway Meadows site was not suitable unless it was

combined with an adjacent site to the North not owned by WG, known as

the Freshwater site. At that time, the main thrust of Marshalls’ case was

that WG had not engaged with it properly pursuant to the approach

recommended at paragraphs 22 and 23 of Circular 14/2004. That was, and

is, denied and negotiations and discussions have continued between WG

and Marshalls. Be that as it may, it was suggested by Marshalls during the

course of that appearance that WG had the power, should it be so minded,

to acquire the Freshwater site by compulsion pursuant to section 246(1) of

the Highways Act 1980. That provides as follows:

“246 (1)……a highway authority may acquire land for the purpose of mitigating any adverse effect which the existence or use of a highway constructed or improved by them, or proposed to be constructed or improved by them, has or will have on the surroundings of the highway”

309. The Guidance provided in Circular 14/2004 as to this power is as follows:

C:5493828v1 174

“Section 246(1) provides that highway authorities may acquire land compulsorily for the purpose of mitigating any adverse effect which the existence or use of a highway constructed or improved by them (or proposed to be constructed or improved by them) has or will have on its surroundings. This power enables the acquisition of land needed to maintain or improve the environment of areas adjacent to the road”

310. Marshalls set out their legal submissions that WG had the power to

purchase the Freshwater site by compulsion in ID 169.

311. Marshalls are correct that the gloss put on a statute in guidance is not

determinative. It is, however, persuasive – see R v Tameside Metropolitan

Borough Council ex p J [2000] 1 FLR 942, 951G where it was said that

statutory guidance is:

“a helpful aid to the way the legislation is intended to be implemented, and it should not be departed from without good reason”

312. The purpose of acquisition under s 246(1) must be to ‘mitigate any adverse

effect which the highway has or will have on the surroundings of the

highway’. The land to be acquired in this instance is an industrial site.

Accordingly, it has no intrinsic ecological, environmental or public amenity

value. The highway has an adverse effect on the owner and occupier of the

land and the balance of the site which is not to be acquired i.e. Marshalls

but that will always be the case when highway land is in some use or

occupation or is owned and has a market value. There is, in short, an

important distinction to be drawn between the adverse effect of a highway

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on its surroundings and the adverse effect which the highway has on the

landowner/occupier of the land acquired for the purposes of the highway.

313. On the construction favoured by Marshalls the scope of section 246 would

be very wide, if not all-pervasive. It would give an acquiring authority the

scope to consider dispossessing a landowner unaffected by a highway so

as to accommodate or mitigate the loss of a landowner whose land was

needed to build the highway. Such a power would put authorities in an

unenviable position in having to choose between the landowner whose land

is required for a highway and the almost infinite number of landowners

whose land may be suitable for the dispossessed landowner.

314. There is a further point which is that the Freshwater site does nothing to

mitigate the adverse effects of the Scheme on the balance of the existing

Marshalls site: it is not an addition to that site. Rather, it is replacement for

it and a mere coincidence that it happens to be nearby a different part of a

highway.

315. The narrower construction set out by the Circular makes the power under s

246(1) more workable and compatible with human rights and the general

proposition that powers of compulsion should be limited to that which is

necessary in the public interest. Accordingly, if a highway has no adverse

impact on its surroundings, because those surroundings are simply an

industrial site with no redeeming ecological or public space amenity

features, then the power simply does not arise.

316. In short, while it is conceded that the Circular is not determinative, the

interpretation of section 246 contained within it is sound. The breadth of the

C:5493828v1 176

power on the Marshalls construction is too great and cannot sensibly have

been intended by Parliament.

317. In conclusion, WG maintains its position that the exercise of the power as

suggested by Marshalls is outwith the terms of section 246(1). There are,

however, other points to be made as well.

318. If, contrary to WG’s primary case, the compulsory purchase of the

Freshwater site could come within the scope of s 246(1), there remains the

question of whether it would be appropriate to exercise the power. To this

end the Circular would still be relevant. There is a public interest in

discretionary powers being exercised consistently. The Circular suggests

circumstances in which it would be sensible to exercise the statutory

discretion.

319. Consideration of the exercise of the power to dispossess a third party

landowner whenever another landowner loses his or her land as a result of

a highway would lead to administrative chaos and injustice. Farmers, for

example, who lose land might lobby WG to dispossess unaffected

neighbouring farmers on the basis that they are better and more

conscientious farmers than their neighbour and that thus it would be in the

public interest to acquire their neighbour’s land.

320. In short, if the power exists then WG were correct not to exercise the same.

We will not repeat the contents of IDs 84, 161, 216 and 216A. The upshot

is that WG has engaged properly and in good faith with Marshalls and have

abided by both the letter and spirit of paragraphs 22 and 23 of the Circular.

The Queensway Meadows site is suitable as a replacement and, with some

potential minor peripheral tweaks of the Scheme land-take, there appears

C:5493828v1 177

to be emerging acknowledgment of that by Marshalls in Mr Glover’s letter

of 23/03/2018 (PID/216A). The suitability of an alternative site which can be

provided without dispossessing a third party landowner by compulsion is

yet another basis for concluding that it would not have been appropriate to

consider the compulsory acquisition of the Freshwater site even if, contrary

to WG’s case, such a power existed and could, in an appropriate case, be

exercised.

321. As part of its discussions with Marshalls Mono, WG will endeavour to find a

means of avoiding or minimising any impact on production. There remains

a possibility, of course, that there will be disruption to or cessation of

production pending the establishment of a new site. That possibility has to

be balanced against all the significant benefits of the Scheme and any

losses sustained by Marshalls will be a matter for compensation which is

not for this inquiry. The objection by Marshalls is not, we submit, any basis

for an adverse recommendation.

PIQ 157

322. Some of the legal points noted in PIQ 157 are addressed elsewhere. In this

section we will address the points raised on days 17, 26 and 44.

323. On day 17, 29 March 2017, Mr Alasdair Henderson of counsel called

Professors Jones and Whitelegg who were also cross examined. The

topics under discussion were carbon, traffic and economics. Mr Henderson

was representing GWT. WG have no note or recollection of a legal

submission being made by Mr Henderson on that date or, indeed, on any

other occasion relating to scientific doubt or sliding scales of confidence in

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respect of proposed mitigation measures. There is no discrete legal point of

that nature raised either in GWT’s closing submissions. We deal elsewhere

with the nature of WG’s obligations under the FG Act 2015, the

Environment (Wales) Act 2016 and the Wildlife and Countryside Act 1981.

[Note: during the delivery of this part of the closing submissions it became

apparent that the point referred to was raised by Mr Charles Streeten on

behalf of GWT and not Mr Alasdair Henderson. The argument raised by

Charles Streeten is addressed in the legal note at Annex 3.]

324. As to the submission made on day 26 by Cycling UK that the Scheme

would breach the Active Travel Act 2013 we rely on the evidence of Mrs

Tindale at paragraphs 7.42 to 7.52 of WG 1.10.1. The 2013 Act places an

obligation on WG, pursuant to section 1 (e) and section 9 (1), when

exercising its functions under the Highways Act 1980 to take reasonable

steps to enhance the provision made for walkers and cyclists, in so far as

that is practicable.

325. As is apparent from Mrs Tindale’s evidence all but one of the public rights

of way which cross the path of the Scheme will be diverted. The path which

is lost is only l34 metres long and is a dead end. All the other public rights

of way which are affected will be diverted. In addition to diverting existing

paths the Scheme will create six new public rights of way totalling 3.14 km

and a shared-use path of approximately 1 km. Accordingly, we submit that

reasonable steps have been taken to enhance provision for walkers and

cyclists in so far as that is practicable and, moreover, that the Scheme

results in greater and better provision for walkers and cyclists. In short, the

C:5493828v1 179

allegation that there has been a breach of the Active Travel Act 2013 is

without merit.

326. On day 44 points were made as to the appropriate compensation payable

to objectors 227 and objectors 231. Matters of compensation are not for the

inquiry. The primary form of compensation is based on the market value of

the land acquired. Further claims can be made for disturbance and, where

the landowner retains land, for injurious affection and severance where the

value of the retained land is diminished. These heads of claim may be

relevant to the to objectors 227 and 231. It is not appropriate, however, to

make any detailed observations with regard to these matters.

DELIVERY, CLEAR PLAN, RESOURCES AND NO LIKELY IMPEDIMENT TO

IMPLEMENTATION

327. As noted above, the delivery of a relief road for the M4 round Newport is

part of the Programme for Government, Taking Wales Forward 2016-

2021202. The broader based Prosperity for All, published in September

2017, identifies the delivery of a significant improvement to the M4 around

Newport” amongst other national road schemes as part of its United and

Connected theme and well being Objective 11: Deliver modern and

connected infrastructure. Matthew Jones described the appointment of

Costain/Vinci Joint Venture under an Early Contractor Involvement (“”ECI”)

contract. This is a delivery model which has been used successfully on

other road schemes. A vast amount of detailed work has been undertaken

202 Doc. 5.1.11

C:5493828v1 180

already on this project, in recognition of its importance, sensitivities and

complexities.

328. The M4 CaN Scheme has been long in the planning and preparation. This

means that it has the advantage of being at an advanced level of design

relative to its stage in the statutory process.203 Joint working in this way

has generated a good level of knowledge about the detail and cost of

implementation as demonstrated in the evidence of Messrs Sibert and

Woodman.

329. An important outcome of this joint working is the Buildability Report. This

document looks in considerable detail at every practical aspect of the

Scheme. Mr Woodman led a comprehensive presentation of one of the

most complex elements contained in the Report – the construction and

connection of new reens. That was, in turn, informed and complemented

by the intricate and innovative drainage/water quality design which was

explained by Mr Graham, and the ecology team’s response to NRW’s

advice about what has and has not worked well in previous reen creation

projects. NRW were given a similar demonstration in November 2016.

Significantly, on neither occasion did they take issue with the method set

out in the Buildability Report. Indeed, nobody has challenged204 this or any

other aspect of the Buildability Report at the Inquiry.

330. Turning to funding, there is provision for the Scheme through a combination

of UK Government borrowing and Welsh Government Transport

budgets.205 The M4 relief road is included in the National Transport Plan

203 Mr John Davies MBE explained the relationship of the project in terms of the revised WelTag stages – ID/205 and WG1.23.7 204Though some, e.g.. Mr Lowe, asked questions of clarification 205 Matt Jones proof WG 1.1.1 para 22.37

C:5493828v1 181

2010206 National Transport Finance Plan 2015 and its 2017 update207. Mr

Matthew Jones described the cost increases as a result of the mitigation

measures for the Docks, explaining how the costs are accounted for, in part

by reductions in allowances for Project Risk and Optimism Bias, in part by

means of a contribution from WG’s Economic Development Fund. The

Fund’s contribution reflects the consequential benefits which would accrue

to the Welsh economy from the proposed measures in the Docks. 208

331. Steps have been taken to clear possible regulatory impediments to

implementation. The need for LBC has been recognised and is addressed

under the “Planning Requirements” section of these submissions.

332. The works of mitigation and relocation at the Docks would be implemented

by ABP under their statutory powers and the GPDO. 209 The land in

question is allocated in the LDP for dock related employment development

(B1, B2, B8) and the remit of the LPA is limited under the prior approval

process. Such applications are screened for EIA and where appropriate,

SIAA. WG has undertaken EIA and SIAA for the proposed arrangements

on the basis of current knowledge of an in principle proposal. If

assessments need to be carried out further in the light of detailed

proposals, they can be. Assessment thus far has not indicated any likely

impediments to delivery in due course. 210

333. One tenant, Origin, currently operates under Hazardous Substances

Consent/s (“HSC”) in respect of its fertiliser handling functions. Origin

needs to move as a result of introducing the bridge over the Docks and the

206 CD 6.1.5, Intervention Ref 91 207 CD 5.1.7, Scheme ref R8 208 See Matthew Jones’ Scheme Evidence Update Doc WG 1.1.8, Section 3.4 209 See ABP’s statement (PID 196) submitted on 15.02.2018 (dated 20th February 2018) 210 PID236

C:5493828v1 182

plan is to relocate them further south.211 HSC in respect of the projected

move has now been secured.212

334. ABP hold an explosives licence to allow explosives to be handled in

Newport docks. Following consultation with the HSE who would require the

amount of explosives to be reduced as a result of the Scheme’s

construction, the MOD have stated in a letter dated 10 January 2017 that a

reduced handling capacity at Newport Docks would not significantly affect

the MOD’s ability to import or export munitions. 213

335. ABP have withdrawn their objections/s.16 representations. Furthermore,

objections on the part of the Newport Harbour Commissioners have been

resolved. NRW’s objections to the Scheme do not concern obstruction or

impedance of any of their functions due to the proposed bridge. There is

therefore now no possibility of Special Assembly Procedure being triggered

under s.107(4) HA 1980 on the basis of objections by relevant bodies

concerning the reasonable requirements of navigation. This absence of

objection on navigational grounds means that the Inspectors can and

should report, in discharge of their duty under s.107(1) HA 1980, that the

reasonable requirements of navigation over the waters affected by the

Scheme would be satisfactorily accommodated. Jonathan Vine

summarised the position in terms of ship access to North Dock in his

Scheme Evidence Update214. The relevant section, we now know, is the

one dealing with a 13.5m channel. His Table 5-17, which was not

challenged, gave the breakdown as follows:

211 See port relocation plan and submissions above as to WG and ABP’s contractual obligations in relation to Port tenants 212 PID /232 ; PID/ 227 HSC ; PID / 206 – plans for zones 213 Set out in Matthew Jones’ Main Proof – section 19.6 page 88 - 89 214 Doc WG 1.22.5 p.31.

C:5493828v1 183

336. He then presented a detailed capacity analysis of the Docks with the

addition of the proposed new wharfage, concluding that with that, ABP

would be able, with some operational modifications, to maintain the current

number of vessel visits to the Docks.215 This conclusion was also

unchallenged. Having regard to the withdrawal of objections by ABP and

Newport Harbour Commissioners, Mr Vine’s evidence and that of Messrs

Sibert and Finlay reviewed above,216 there is therefore ample evidential

basis for advising the Ministers that the reasonable requirements of

navigation over the waters affected would be satisfactorily accommodated.

337. For both bridge protection measures and the creation of a new quay in

South Dock, a marine licence will be required to authorise construction and

dredging activities within the marine environment pursuant to the Marine

and Coastal Access Act 2009. The process is administered by NRW. Dr

215 Op cit Section 6 and para.7.1. 216 At para. 5.4.5

C:5493828v1 184

Ireland explained217 that WG have engaged in pre-application discussions

with the relevant team and the August 2017 ESS (No.5) reflects their

requirements. Neither NRW nor anyone else has raised objection to the

proposed Dock works in this respect and there is no reason to think that

this issue presents an impediment to delivery.

338. European Protected Species (“EPS”) licences would or might be required in

respect of the Scheme for a number of species: bats, dormice, great

crested newts (“GCN”) and possibly otters. NRW is the licensing body.

339. The relevant statutory provisions concerning European protected Sites and

species are now contained in the Conservation of Habitats and Species

Regulations 2017 (“2017 Regulations”).

340. Regulation 9(1) provides as follows:

“The appropriate authority, the nature conservation bodies and, in relation to the marine area, a competent authority must exercise their functions which are relevant to nature conservation, including marine conservation, so as to secure compliance with the requirements of the Directives.”

341. By Regulations 3(1) and 7(1), the “appropriate authority” and the

“competent authority” include the Welsh Ministers. The “nature

conservation bodies” include NRW.

342. Assessment of plans and projects is dealt with in Part 6 of the 2017

Regulations. The provisions of this Part are expressly applied to the

construction of new highways by Regulation 87(1)(a) and to planning

permissions granted by the GPDO by Regulations 75 and 77.

217 In his Scheme Evidence Update Doc.WG 1.7.5, paras. 3.3.78-9

C:5493828v1 185

343. The relevant European Sites are: River Usk SAC; Severn Estuary SAC;

Severn Estuary SPA; Severn Estuary Ramsar Site; and and

Forest of Dean Bat Sites.

344. As noted above, NRW agree, in relation to the Scheme and the proposed

works in the Docks, that there are likely to be no impacts which would

adversely affect the integrity of any European Site. The SOCG goes on to

state at paragraphs 2.1.30 and 2.1.31 that whilst NRW cannot pre-judge its

opinion of the likely significant effects of the proposals on otter for the

purposes of Regulation 76 of the 2017 Regulations, NRW is satisfied that

the appropriate mechanism for consideration and determination of these

matters relating to ABP exercising permitted development rights under the

GPDO will be through the protective statutory processes by Part 6 of the

2017 Regulations described above. WG acknowledge and agree with that

position.

345. GWT’s objection in this respect is considered below but it should be noted

here that a decision maker discharging its duties under Part 6 of the 2017

Regulations should give the views of a statutory consultee considerable

weight: Ashdown Forest Economic Development LLP v. SSCLG, Wealden

DC [2014] EWHC 406 Admin. The recent decision of Jay J in Wealden DC

v SoSCLG, Lewes DC, South Downs National Park and Natural England

[2017] EWHC 351 (Admin), which Inspector McCooey drew to the Inquiry’s

attention, considers in – combination effects at the screening stage of the

process in the context of DMRB. WG considered in – combination at both

the screening and Statement to inform Appropriate Assessment (“SIAA”)

stages in this case, so the recent Wealden case is not on all fours.

C:5493828v1 186

346. Conservation of European protected species is dealt with in Part 3 of the

Regulations.

Regulation 42 - European Protected Species of Animals provides for

those species of animal listed in Annex IV(a) to the Habitats Directive

to be listed in Schedule 2 to the Regulations and references to a

“European protected species” of animals are to any of those species.

Regulation 43(1) Protection of certain Wild Animals: Offences makes it

a criminal offence deliberately to capture, injure, kill or disturb any wild

animal of a EPS or deliberately to take or destroy such an animal’s

eggs. It is also an offence to damage or destroy a breeding site or

resting place of such an animal. Paragraph (2) provides that for these

purposes, disturbance of animals includes in particular any disturbance

which is likely –

(a) to impair their ability -

(i) to survive, to breed or reproduce, or to rear or nurture their young; or

(ii) in the case of animals of a hibernating or migratory species, to

hibernate or migrate; or

(b) to affect significantly the local distribution or abundance of the

species to which they belong.

Paragraph (9) provides that guidance as to the application of the

offences in relation to particular species of animals or particular

activities may be published by –

(a) the appropriate authority; or

C:5493828v1 187

(b) the appropriate nature conservation body, with the approval of the

appropriate authority and such guidance may be taken into account by

the criminal court.

347. These criminal provisions do not apply to any acts done pursuant to a

licence issued under Regulation 55, which provides as follows:

55.— Licences for certain activities relating to animals or plants

(1) Subject to the provisions of this regulation, the relevant licensing body

may grant a licence for the purposes specified in paragraph (2).

(2) The purposes are—

(a) scientific or educational purposes;

(b) ringing or marking, or examining any ring or mark on, wild animals;

(c) conserving wild animals or wild plants or introducing them to particular

areas;

(d) protecting any zoological or botanical collection;

(e) preserving public health or public safety or other imperative reasons of

overriding public interest, including those of a social or economic nature

and beneficial consequences of primary importance for the environment;

(f) preventing the spread of disease; or

(g) preventing serious damage to livestock, foodstuffs for livestock, crops,

vegetables, fruit, growing timber or any other form of property or to

fisheries.

(3) Regulations 43 (protection of certain wild animals: offences), 45

(prohibition of certain methods of capturing or killing wild animals) and 47

(protection of certain wild plants: offences) do not apply to anything done

C:5493828v1 188

under and in accordance with the terms of a licence granted under

paragraph (1).

(4) Subject to the provisions of this regulation, the relevant licensing body

may grant a licence to permit the taking or the possession or control of

certain specimens of any of the species or subspecies listed in Annex II(b)

(other than any bryophyte) or Annex IV to the Habitats Directive

notwithstanding that the licence is for a purpose not specified in paragraph

(2).

(5) Regulations 43 , 45 and 47 do not apply to anything done under and in

accordance with the terms of a licence granted under paragraph (4).

(6) A licence under paragraph (4) may be granted only to such persons as

are named in the licence.

(7) The relevant licensing body may grant a licence under paragraph (4)

only if it is satisfied that the grant of the licence would be consistent with

the restrictions in Article 16(1)(e) of the Habitats Directive (namely “under

strictly supervised conditions, on a selective basis and to a limited extent”

and “in limited numbers”).

(8) A licence under paragraph (4) must specify—

(a) the species or subspecies of animal or plant to which the licence

relates;

(b) the maximum number of specimens which may be taken or be in the

possession or control of the person authorised by the licence, or which

particular specimens may be taken or be in the possession or control of

that person; and

C:5493828v1 189

(c) the conditions subject to which the action authorised by the licence may

be taken and in particular—

(i) the methods, means or arrangements by which specimens may be taken

or be in the possession or control of the person authorised by the licence;

(ii) when or over what period the action authorised by the licence may be

taken; and

(iii) where the licence authorises any person to take specimens, the area

from which they may be taken.

(9) The relevant licensing body must not grant a licence under this

regulation unless it is satisfied—

(a) that there is no satisfactory alternative; and

(b) that the action authorised will not be detrimental to the maintenance of

the population of the species concerned at a favourable conservation

status in their natural range.

(10) A licence under this regulation which authorises any person to kill wild

animals must specify the area within which and the methods by which the

wild animals may be killed and must not be granted for a period of more

than two years.

(11) Where the appropriate authority exercises any functions under this

regulation (see regulation 58(3)), the appropriate authority must from time

to time consult the appropriate nature conservation body as to the exercise

of those functions, and must not grant a licence of any description unless

the appropriate nature conservation body has advised as to the

circumstances in which, in its opinion, licences of that description should be

granted.

C:5493828v1 190

(12) Where the Marine Management Organisation exercises any functions

under this regulation (see regulation 58(2)(a)), it must from time to time

consult Natural England as to the exercise of those functions, and must not

grant a licence of any description unless Natural England has advised as to

the circumstances in which, in its opinion, licences of that description

should be granted.

(13) It is a defence in proceedings for an offence under section 8(b) of the

Protection of Animals Act 1911 (which restricts the placing on land of

poison and poisonous substances) to show that—

(a) the act alleged to constitute the offence was done under and in

accordance with the terms of a licence granted under this regulation; and

(b) any conditions specified in the licence were complied with.

(14) In paragraph (2)(g) “livestock” includes any animal which is kept—

(a) for the provision of food, skins or fur;

(b) for the purpose of its use in the carrying on of any agricultural activity; or

(c) for the provision or improvement of shooting or fishing.

348. There is no material difference between the 2010 Regulations and the 2017

Regulations with regard to European Sites or EPS. The 2017 SOCGs

between WG and NRW are framed in terms of the 2010 Regulations

applicable at that time, but their substantive content is unaffected by the

change in legislation.218

349. In R (Morge) v Hampshire County Council 2011 UKSC 2 the Supreme

Court considered the duty, under planning legislation, to “have regard” to

the Habitats Directive. It had been held in earlier case law that the effect of

218 Richard Wald agreed these propositions on behalf of NRW: Doc PID244 P.4 fn.1

C:5493828v1 191

this provision was that the decision maker must satisfy itself that the

statutory tests for granting a protected species licence under the

predecessor to Part 3 of the Regulations were satisfied at the stage of the

planning determination. The Supreme Court decided that this was too

demanding a test.

350. The principle established in Morge should either be treated as applying to

the decision to be made in relation to the HA 1980 Schemes and Orders, to

the extent that the decision might be said to be “relevant to nature

conservation”, and/or needs to be taken into account when considering

whether or not there are any likely impediments to implementation under

the CPO Circular.

351. NRW, as the licensing body, does not say that it is unlikely to grant a

licence in respect of any of the relevant species219. It has reached that

position following extremely thorough scrutiny of the WG proposals. WG’s

ecology team worked hard to respond to NRW’s concerns by a combination

of supplying information and/or working up mitigation strategies in respect

of the species concerned.

352. Most particularly, with regard to dormice, WG have worked extensively with

NRW to produce a detailed Mitigation Strategy in draft. All of the relevant

documents will be supplemented by further detailed information at the

licensing stage, should the Scheme go ahead, reflecting, for example,

ongoing survey work on dormice, otters and bats But in the case of dormice

in particular, NRW considered that a high level of detail was required

because of the declining conservation status of the species in the UK. The

219 See SOCGs ID 104 (bats) paras 2.1.11, 2.1.24 ; ID 105 (GCN para, 2.1.12; otter paras. 2.1.13 – 2.1.16); PID 236 re Docks and Otters; ID 154 (dormice) para.2.1.7; ID 233, NRW letter to Mr Martin Bates 16.3.18

C:5493828v1 192

draft document, therefore, sets out in considerable detail mature proposals

for ensuring that the statutory tests will be capable of being met. It is an

inherently flexible strategy which comprises early habitat enhancement

work and several different approaches ranging from encouragement to

colonise enhanced areas in the vicinity of their current habitat through to

translocation to Coed Mawr. Mr Jon Davies, whose company Arcadis, have

experience of a substantial dormouse mitigation exercise in connection with

the Ryder Cup Project at Celtic Manor, sees the project here as a real

opportunity to strengthen and extend the creature’s colonisation in this part

of South Wales.

353. GWT’s Mr Byrne challenged Mr Jon Davies on his opinion but the group led

no evidence to contradict it or to demonstrate that NRW’s judgment was

flawed. Suggestions in GWT’s Closing that Mr Jon Davies’ evidence should

be given reduced weight because of Dr Keith Jones’ indisposition are

unwarranted. Mr Jon Davies always gave his evidence in such a way as to

put his ecological expertise beyond serious contention. He was repeatedly

cross examined by GWT, to much less effect than inaccurately claimed by

them in their Closing. He plainly always did his best to – and did – assist

the Inquiry.

354. NRW have not required such a detailed approach in relation to GCN nor is

any objector suggesting that there is an outstanding issue.

355. With regard to Dormouse and GCN, therefore, there is no reason to

suppose that licences under the Habitats Regulations will not be

forthcoming. Richard Wald confirmed this in closing on behalf of NRW.

C:5493828v1 193

356. Turning to Otter, there is once again, agreement with NRW220, the licensing

body, that there is adequate information before them and the Inquiry such

that the Inspectors and Ministers should not conclude that any necessary

licences would be unlikely to be forthcoming. This was confirmed by

counsel in his closing.221

357. GWT’s case on Otter concentrated, as well as seeking to undermine that

position on licensing, additionally on another point under the Habitats

Regulations, the effect upon the River Usk SAC. That matter will be dealt

with separately.

358. Lastly, we must consider Bats. There are outstanding objections in respect

of effects on Bats on the part of NRW. GWT also object on that ground.

The scope of their respective objections, however, differs.

359. GWT argue, on the basis of Prof Altringham’s evidence, that licences would

or should not be forthcoming. That case is predicated on a novel

interpretation of the Habitats Regulations which WG submit is wrong for the

detailed reasons set out in Annex 3 of these submissions.

360. GWT/Prof Altringham’s interpretation of the Regulations is not shared by

NRW. They do not suggest that relevant licences would not be forthcoming.

NRW submitted a proof of evidence from Jean Matthews. Although they

maintain concerns about the impacts of the Scheme on bats, this point is

separate from the issue of licensing. Their evidence did not state that

NRW’s objection meant that they would be unlikely to grant a licence and

220 Covered in the signed Internationally Designated Sites SOCG; paras 2.1.39 and 2.1.31 being the most relevant. 221 PID244 p.5 para.13

C:5493828v1 194

this position, as noted above, has been confirmed in a SOCG222. Richard

Wald closed NRW’s case on this basis.223

361. In conclusion, the licensing body, having carefully scrutinised WG’s

proposals and sought reasoned justifications in all relevant respects, has

concluded that there is no basis for suggesting that future consents under

the Habitats Regulations would not be forthcoming in respect of the

Scheme itself and the works in the Docks. GWT disagrees but it is not the

statutory body with responsibility for licensing.

362. Similarly, NRW, having carefully considered the SIAA work undertaken in

respect of the Scheme and the proposals in the Docks and required further

information, now considers that the level of assessment, in the context of

the implications for the European Sites, in view of their conservation

objectives, is appropriate. Furthermore, NRW agrees with the conclusion of

the SIAA in respect of each of the Sites, namely that no adverse effect on

Site integrity is predicted because of the M4CaN either alone or in

combination with other plans and projects and taking account of relevant

mitigation as embedded into the Scheme or as set out as commitments

within the Commitments Register224. We have derived the expression of

this point from NRW’s Closing Submissions, which were clearly crafted with

care on this important matter. Therefore the inspectors can and should

advise Ministers that there are no likely impediments to the Scheme being

progressed on the basis of European protected species or Sites.

This exhaustive review of potential obstacles to implementation of the

Scheme and the Docks works demonstrates that all potential impediments

222 PID 104 paras.2.1.11 - 2.1.24 223 PID 244 P.5 para. 12 224 Richard Wald Closing Doc PID 244 pp.7-8, para.18

C:5493828v1 195

have been considered and, where necessary, steps have been taken to

scope out future regulatory and other risk. If the Schemes and Orders are

confirmed, there is no evidential basis for concluding that they could not be

implemented.

WELL-BEING OF FUTURE GENERATIONS (WALES) ACT 2015 (“FGA 2015”)

363. We set out in Opening our submissions as to the interpretation and

application of the FGA 2015. Those submissions stand because nothing

has happened during the Inquiry to cause them to change. This document

will, therefore, focus on responding to particular points which have been

made by objectors.

364. For convenience, the key sections are reproduced below:

"2 Sustainable development In this Act, “sustainable development” means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle (see section 5), aimed at achieving the well-being goals (see section 4). 3 Well-being duty on public bodies (1) Each public body must carry out sustainable development. (2) The action a public body takes in carrying out sustainable development must include— (a) setting and publishing objectives (“well-being objectives”) that are designed to maximise its contribution to achieving each of the well-being goals, and (b) taking all reasonable steps (in exercising its functions) to meet those objectives. (3) A public body that exercises functions in relation to the whole of Wales may set objectives relating to Wales or any part of Wales. (4) A public body that exercises functions in relation only to a part of Wales may set objectives relating to that part or any part of it.

C:5493828v1 196

4 The well-being goals The well-being goals are listed and described in Table 1— TABLE 1

Goal Description of the goal

A prosperous An innovative, productive and low Wales. carbon society which recognises the limits of the global environment and therefore uses resources efficiently and proportionately (including acting on climate change); and which develops a skilled and well-educated population in an economy which generates wealth and provides employment opportunities, allowing people to take advantage of the wealth generated through securing decent work.

A resilient A nation which maintains and Wales. enhances a biodiverse natural environment with healthy functioning ecosystems that support social, economic and ecological resilience and the capacity to adapt to change (for example climate change).

A healthier A society in which people's physical Wales. and mental well-being is maximised and in which choices and behaviours that benefit future health are understood.

A more equal A society that enables people to fulfil Wales. their potential no matter what their background or circumstances (including their socio economic background and circumstances).

A Wales of Attractive, viable, safe and well- cohesive connected communities. communities.

A Wales of A society that promotes and protects vibrant culture culture, heritage and the Welsh and thriving language, and which encourages . people to participate in the arts, and sports and recreation.

C:5493828v1 197

A globally A nation which, when doing anything responsible to improve the economic, social, Wales. environmental and cultural well-being of Wales, takes account of whether doing such a thing may make a positive contribution to global well- being.

5 The sustainable development principle (1) In this Act, any reference to a public body doing something “in accordance with the sustainable development principle” means that the body must act in a manner which seeks to ensure that the needs of the present are met without compromising the ability of future generations to meet their own needs. (2) In order to act in that manner, a public body must take account of the following things— (a) the importance of balancing short term needs with the need to safeguard the ability to meet long term needs, especially where things done to meet short term needs may have detrimental long term effect; (b) the need to take an integrated approach, by considering how— (i) the body's well-being objectives may impact upon each of the well-being goals; (ii) the body's well-being objectives impact upon each other or upon other public bodies' objectives, in particular where steps taken by the body may contribute to meeting one objective but may be detrimental to meeting another; (c) the importance of involving other persons with an interest in achieving the well-being goals and of ensuring those persons reflect the diversity of the population of⁠ — (i) Wales (where the body exercises functions in relation to the whole of Wales), or (ii) the part of Wales in relation to which the body exercises functions; (d) how acting in collaboration with any other person (or how different parts of the body acting together) could assist the body to meet its well-being

C:5493828v1 198

objectives, or assist another body to meet its objectives; (e) how deploying resources to prevent problems occurring or getting worse may contribute to meeting the body's well-being objectives, or another body's objectives.”

365. It is obvious, from the Act’s definition of “sustainable development” that the

required actions involve the weighing and balancing of different

considerations. This proposition has been disputed by some objectors.

The RSPB and GWT, in their letter of 26th May 2017 to the Cabinet

Secretary for Economy and Infrastructure and Mr Byrne, cross examining

Mr Matthew Jones on behalf of GWT, both suggested that the only scope

for balance in the Act is the importance to be placed, pursuant to s.5(2)(a),

on the balancing of short term needs with the need to safeguard the ability

to meet long term needs, especially where things done to meet short term

needs may have detrimental long term effect. The RSPB / GWT letter also

refers to the Sustainable Development Principle requiring integration, with

the apparent implication that integration is in some way inconsistent with

the balancing of well-being considerations. The Future Generations

Commissioner (“FGC”) made similar points in her letter to the inspectors of

13 September 2017.

366. With respect, this approach over simplifies the intricacies and subtleties of

the statutory drafting and is inconsistent with PPW225, which has been

updated specifically to reflect the new legislation; whilst policy is neither law

nor the authoritative interpretation of the law, it is telling that the notion of

225 See, e.g.. paras. 5.5.1 – 2, referred to by John Davies MBE in his Rebuttal to Mr Barnes for the Woodland Trust (WG/REB/OBJ271- Barnes) and para.7.2.2, referred to above.

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balance, so familiar in the planning sphere, remains in national policy

notwithstanding the new enactments. The RSPB approach also appears to

presuppose that the transport and related needs to which the Scheme is

directed are short term needs and that meeting such needs will or may

have long term detrimental effects.

367. To deal, firstly, with the presuppositions, WG’s evidence powerfully

demonstrates that the needs which the Scheme addresses are anything

but short term. They are longstanding problems which are projected to

continue into the future and, in some respects worsen in the absence of the

Scheme. GWT’s witnesses and many other objectors had failed to inform

themselves adequately of the evidence in support of the Scheme. Many

favoured other approaches which they regarded as coming at less

environmental cost, but had not drilled down into the detail. WG’s

witnesses have cogently explained in detail why the Scheme is necessary

and alternatives, such as packages of non-road based measures or the

Blue Route, alone or in combination with other measures, simply will not do

the job.

368. The Scheme is a long term solution to long term needs. It is the only such

solution to have emerged from years of careful analysis and collaborative

endeavour, recently reviewed afresh and independently by Mr John Davies

MBE in the context of the Act. Suggestions by the Future Generations

Commissioner (“FGC”) in her letter of 13 September 2017 that the WG

M4CaN inquiry team had not properly considered and applied the new

legislation were and are wholly unwarranted. One can only assume that the

FGC did not have Mr John Davies MBE’s painstakingly careful assessment

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of the Scheme in the context of the FGA 2015 drawn to her attention before

sending her letter.

369. Interestingly, Mr Barnes of the Woodland Trust asked rhetorically how long

compensation measures can be expected to last, in the light of the fact that

some of the 1960s/70s planting along the existing M4 is to be lost to the

Scheme.226 The current M4 exemplifies what happens when infrastructure

is not future- proofed; the long term results are less sustainable than where

needs are faced up to and long term solutions applied. The M4CaN

Scheme is designed to meet the pressing needs of the present whilst

properly addressing the long term as part of an integrated transport

strategy. Not one of the Alternatives put forward at the Inquiry, on the other

hand, has shown itself to be up to the task.

370. Turning to long term detrimental effects, it is necessary, once again, to

make an accurate assessment. WG has done so and Mr John Davies

MBE drew on this work to reach conclusions on the FGA 2015 questions,

both in his original Proof of Evidence, and in his concluding Scheme

Evidence Updates227, which reflect the developments which have occurred

as the Inquiry has unfolded. No other witness attempted this exercise.

Whilst it cannot substitute for the judgment of the inspectors or the ultimate

decision maker, and is not intended to do so, it is a thorough, evidence-

based assessment. The process enjoined by the Act on the public bodies

requires this kind of careful exercise. The improvement sought by s.2 is

real, not speculative, improvement. The Sustainability Goals in s.4 are

226 Proof for Woodland Trust (OBJ0271) para.4.31 227 WG 1.23.5 and 7

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concepts which require judgments to be made, but, to be meaningful, they

must be based on evidence, rather than assertion.

371. The contention that the only form of balancing required or, allegedly,

permitted under the Act, is the balancing of short term needs and long term

detrimental effects is untenable. This is a generic duty laid upon public

bodies, all of whom operate within an existing statutory framework, and

many of whom are democratically accountable. The list of matters which

must be taken into account in order to act in accordance with the

sustainable development principle is not exhaustive (s.5(2)), nor could it

sensibly be. The s.4 goals, like the s.2 definition, involve some elements

which are, potentially, in tension and which require the application of

informed judgment to resolve. In reaching such resolution – in other words,

in striking the balance – the decision making body looks for an integrated

solution, seeks to ensure that the needs of the present are met – which

may be its statutory or democratic duty – without compromising the ability

of future generations to meet their needs, taking account of the required

matters and adopting the ways of working required in s.5(2). This is

complex territory, especially when taking a decision about major

infrastructure which will give rise to a vast collection of effects across the

economic, social, environmental and cultural spheres. Whilst the Act

requires new processes to be undertaken and gives more detailed

expression to the pre-existing statutory concept of “sustainable

development”, it does not prescribe answers or outcomes. It does not say

that environmental concerns must always trump economic and/or social

ones, or vice versa. The Act calls, instead, for smart decision making and

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action, which achieves improvement in all fourareas. The evidence amply

demonstrates that this Scheme would achieve such improvement. The

nature of this improvement, its precise outworkings in the four statutory

fields of endeavour, may not take the form which objectors would choose,

but that is not to say that the Act prevents the Minister from reaching such

a conclusion.

372. Detailed responses have been made in written and oral evidence to the

FGA 2015 points raised against the Scheme228. This includes a full rebuttal

of the further submissions made by the Future Generations Commissioner

(“FGC”)229.

373. The role of FGC is a statutory one, set up and defined by Part 3 of the Act.

S.18 provides that the FGC’s general duty is:

“(a) to promote the sustainable development principle, in particular to— (i) act as a guardian of the ability of future generations to meet their needs, and (ii) encourage public bodies to take greater account of the long-term impact of the things that they do, and (b) for that purpose to monitor and assess the extent to which well-being objectives set by public bodies are being met.”

374. It is interesting to note that the particular part of the sustainable

development principle with which the FGC is to concern herself is the long

term. This particular statutory emphasis must be borne in mind. WG/WMs,

of course, are subject to the duty to carry out sustainable development,

228 See John Davies MBE’s original Proof WG 1.23.1 paras. 35-44 229 FGC – WG/REB/ISU0024 and ISU0024-2

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which includes ensuring that the needs of the present are met. The FGC,

in her representation, suggests that WG have not comprehensively

considered alternative options for addressing the problems of the M4,

favours a package of measures, and refers to the objective of reducing

greenhouse gas emissions. These points are developed in a variety of

ways.

375. WG’s Rebuttal230 deals comprehensively with these points. We do not

repeat the detailed points of rebuttal here. In respect of most of the points,

the opportunity has been taken to assist both the FGC and the Inspectors

by pointing out where, in the extensive evidence base, all these points have

been considered.

376. One suggestion made by the FGC and others is that Mr John Davies

MBE’s appraisal is merely a retrofit, the implication apparently being that

his assessment is, by definition, inconsistent with the Act. The Act contains

no transitional provisions. There is no suggestion that, exceptionally, its

effect is retrospective. The relevant parts came into effect on 1 April 2016.

Given the stage which the project had reached by then, it would have been

absurd and, indeed, unsustainable to have stopped it in its tracks and gone

back to inception. The Act imposes no such requirement. Therefore

criticism of Mr John Davies MBE’s work is unjustified. It is a far more

thorough and well-informed assessment than the FGC’s representation. As

Mr Matthew Jones explained,231 the FGC had one meeting with WG shortly

before the deadline for submission of her representations when she and

her team were fairly new in post. Therefore the opportunity was taken in the

230 WG/REB/ISU0024-2- Howe; 231 During his cross examination by James Byrne

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Rebuttals to reassure the FGC of the extensive and collaborative work

undertaken over the years to assess alternatives, to consider social and

health impacts and to achieve the best fit between meeting present needs

without compromising future generations.

377. A further point of principle addressed in Mr John Davies MBE’s Proof and

Rebuttal is the manner in which individual projects should be assessed

under the Act. The point is a simple one. Not every project is required to

contribute in equal measure to every well-being goal. S.3(2)(a) refers to

the setting of objectives by the public body. This process is important and

is the only activity specified in the Act to be a compulsory sustainable

development action. S.3(2)(a) refers to the setting of objectives by a public

body, which are “designed to maximise its contribution to achieving each of

the well-being goals” (ie. the body’s contribution; emphasis added). The

point is that the actions of the relevant body, taken as a whole, should

contribute across all the goals and objectives; in the case of WG, the

canvas is obviously broad. This interpretation is confirmed by

consideration of s.3(2)(b). Whilst this subsection imposes a duty on the

relevant public body to meet the published objectives that are designed to

maximise the body’s contribution to each of the well-being goals, it does

not make this duty an absolute one. Instead, the obligation is to take all

reasonable steps in exercising its functions to meet the objectives which it

has set. This provision therefore leaves considerable scope for judgment

to the public body as it goes about its work, rather than being prescriptive.

Moreover, s.3(4) provides that a public body which exercises functions in

relation to the whole of Wales may set objectives relating to Wales as a

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whole or any part of Wales and a similar degree of latitude is granted to

more local bodies within Wales, which is not consistent with a reading

which requires equal contribution across all objectives from all projects of

Government.

378. Interestingly, the FGC, in her recent evidence to the Equality, Local

Government and Communities Committee on 1 March 2018, appears to

recognise the role of balanced judgment in assessing effects under the four

elements of well being under s.2 of the Act and the FGC’s initial submission

and letter of 13 September 2017 must now be read subject to her evidence

in . Replying to a question which apparently referred to Mr John

Davies MBE’s evidence232 she said:

“Well, what the Act says is that public bodies have a duty to undertake

sustainable development, and ‘sustainable development’ is defined as

the process of improving the social, economic, environmental and

cultural well-being of Wales. I’ve also had legal advice, as you can

imagine, and believe that my interpretation of that provision is robust.

There have been some interesting ways of looking at that. I think the

important word is ‘improving’. So, that doesn’t mean that, if you’re

going to undertake a particular project or spend a particular amount of

money, you couldn’t have a situation where the economy massively

benefits and, say, the environment only benefits in a minimal way. In

my view, that sort of decision would be allowed; it wouldn’t be contrary

to the Act. If, however, you have a decision whereby the economy

benefits massively and the environment is massively negatively

232 Incorrectly referred to by John Griffiths AM as WG’s ‘legal representative’

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impacted, so therefore it’s not improved, I think that would be contrary

to the future generations Act. “

379. These submissions demonstrate that, even adopting the FGC’s approach

(which is not admitted to be the right one since it reads words into the

legislation and impermissibly cuts down the discretion of the decision

maker) a decision to confirm the Orders would not be inconsistent with the

FGA 2015. This is because it is not tenable, on a fair and comprehensive

assessment of the environmental evidence, to conclude that the

environment would not be improved, especially when one considers the

long term effects of the ecological mitigation measures on the Levels and at

Coed Mawr, air quality and noise improvements for significant residential

areas of Newport and the regeneration of worn out parts of Newport Docks.

The weight to attach to these improvements as opposed to admitted

environmental disbenefits is, of course, a matter of judgment, as is the

weight to attach to economic and other social benefits, but judgment and

weight are not matters of law.

380. The Welsh Government set 14 well-being objectives and published them in

November 2016, simultaneously with its Programme for Government,

Taking Wales Forward 2016-2021. The Cabinet Secretary flagged up the

fact that there were close links between them. The objectives were revised

and reduced in number to twelve, issued in the Well Being Statement of 19

September 2017. Mr John Davies MBE reassessed the Scheme against

the new objectives in his Update,233 concluding that it delivers benefits in a

233 WG 1.23.5

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cross-cutting way across many of the new objectives as it had done in

respect of the previous ones.

381. To summarise, suggestions to the effect that the Scheme is contrary to the

FGA are ill founded. The Inspectors are free to recommend confirmation

and the WMs are free to confirm the Schemes and Orders if they are

satisfied that to do so would be in accordance with the sustainable

development principle. That judgement is for them, properly assessing the

evidence in the context of the statutory requirements and their own well-

being objectives.

OTHER STATUTORY ENVIRONMENTAL DUTIES

382. A theme of many objections has been the claim that the Scheme is in

conflict with a number of important duties laid upon public bodies by UK

and Welsh legislation. There has also been some criticism of the ES and

Statement to Inform Appropriate Assessment (“SIAA”), which will be

considered after the general duties deriving from domestic UK and Welsh

law.

383. The relevant domestic law duties will be analysed individually in the context

of the evidence. Before embarking on that exercise, however, it is

important to note a fundamental point of difference between WG and

objectors with regard to the scope and operation of the statutory provisions.

384. As briefly outlined in our Opening and repeated during the inquiry, it is the

case that none of the relevant provisions is unqualified. This approach has

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provoked disagreement, even protest.234 Mr Byrne for GWT suggested to

Mr Matthew Jones that the inquiry should concern itself with the intentions

of those, apparently including himself, who had had some involvement in

bringing the FGA 2015 and the EWA 2016 to the statute book. The

question was not answered, in the event, because it proceeded on a false

legal basis. The RSPB / GWT letter to the Minister235, similarly, refers to the

“spirit” of the legislation and to observations apparently made in the

Assembly as the Bills were introduced. Legislation must be interpreted by

objectively construing the words used; this is the route to discerning and

giving effect to the intention of the legislative body. Extraneous (and strictly

circumscribed) material is only to be considered in exceptional

circumstances where the words of the legislation itself are ambiguous or

lead to manifest absurdity.236 That is not to underplay the importance of the

provisions in question here, which are perfectly clear, rather it is to do them

full justice. They cover all the actions of public bodies. In a modern society,

the ambit is, therefore, huge and multifarious. In many instances,

authorities will also be under many, more specific, statutory duties. The

new provisions require certain approaches to decision making, but they

cannot possibly prescribe outcomes in a complex, mature democracy;

properly construed, this is not their effect.

385. Apparently contrary to widespread belief amongst those who have

mobilised and advanced opposition to the Scheme, it does not breach

234 ID / 088 RSPB letter to Ken Skates, Cabinet Secretary for Economy and Infrastructure 26th May 2017, including certain observations of RSPB and GWT representatives on the evidence of NRW. 235 ID / 088 236 Pepper v. Hart [1993] AC 593; moreover, comments by the House of Lords in subsequent cases have suggested that the rule should be applied very restrictively: R v Secretary of State for the Environment, Transport and the Regions ex p. Spath Holme Ltd [2001] 2 AC 349, Wilson and others v Secretary of State for Trade and Industry [2003] UKHL 40, R (Westminster City Council) v National Asylum Support Service [2004], JR

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recent Welsh Environmental legislation. Nor is it in conflict with s.28G

Wildlife and Countryside Act 1981 (“WCA 1981”) or any other relevant

statutory provision. It is important to recall that Friends of the Earth

Cymru’s (“FOEC”) legal challenge to the Plan underlying the Scheme

failed. FOEC argued that, in adopting the Plan, the Minister failed to take

reasonable steps, consistent with the exercise of WG’s functions, to further

the conservation and enhancement of the flora and fauna of the SSSIs over

which the proposed route runs, as required by s.28G. Hickinbottom J

rejected that contention on the basis of his interpretation of s.28G and the

facts which demonstrated how WG had discharged the duty up to Plan

adoption stage. He rightly refused to enter into the merits of the decision to

adopt the Plan as a matter of policy, but it must follow from his decision that

there can be no question of WG’s having acted contrary to s.28G up to the

stage when it adopted the Plan in 2014. Moreover, the recent Welsh

legislation was not in force then and is not retrospective. This is important,

as stated above, because it means that there can be no valid opposition on

legal grounds on the basis of the idea or concept of this road scheme. A

proper decision can only be reached by weighing up all the pros and cons

and reaching a balanced view.

Part 2 of the Wildlife and Countryside Act 1981

386. S.28G WCA 1981 must be considered in context. It sits within a suite of

provisions which were consolidated and expanded by the Countryside and

Rights of Way Act 2000. These provisions form a coherent statutory

scheme for the notification and protection of SSSIs. S.28G undoubtedly

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imposes a duty on WG and all other s.28G authorities, but it is not an

absolute duty and, under the statutory scheme, NRW is not the ultimate

arbiter of the acceptability of relevant works which a s.28G authority

proposes to undertake.

387. S.28E WCA 1981 requires the owner of SSSI land to obtain the consent or

agreement of NRW to do works. There is a right of appeal against refusal

to WG. It is a criminal offence to do such works without consent, subject to

the operations having been authorised by a grant of planning permission or

permitted by a s.28G authority which has consulted NRW under s.28I.

Different rules apply to s.28G authorities carrying out operations. They are

required to notify NRW in advance of proposed works and, if NRW do not

assent, they must notify NRW of their intention of starting operations and

state “how (if at all) it has taken account of any written advice” received

from NRW. It must then do the works in such a way as to cause as little

damage to relevant features as is reasonably practicable in all the

circumstances and restore the site to its former condition, so as far as is

reasonably practicable237.

388. As Ms Poole agreed,238 therefore, the law distinguishes between private

owners/developers on the one hand and public authorities on the other,

since the s.28G authority can, ultimately, go ahead without the approval of

NRW or another body in consultation with NRW. Perhaps oddly, s.28H

(5)(b) even countenances the possibility that NRW’s written advice under

s.28H(1) might not be taken into account. Of course in this case, WG has

237 S.28H(6) WCA 1981 238 Cross examination (ME QC)

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taken NRW’s advice fully into account239. As NRW’s schedule240 and the

SoCgs on Flood Risk, Water Quality, Internationally Designated Sites,

Nationally Designated Sites, Cultural Heritage, Landscape and Visual

Effects, Dormice, Bats and Other Protected Species demonstrate, NRW

have given the Scheme the closest scrutiny in general, including the SSSI

effects in particular, in the course of protracted dialogue with WG and its

advisors on ecology, drainage and water quality. WG have taken their

advice into account, paying it the most careful attention and refining their

proposals as a result. Richard Wald acknowledged the depth of this

dialogue during his Closing Submissions and WG would like to take this

opportunity to pay particular tribute to Ms Poole’s work on this project and

continue to wish her well in her recovery. Following her accident, dialogue

has continued, as her colleagues have picked up matters where she had to

leave them. It is this detailed work which has enabled the position of

substantial agreement recorded in Mr Wald’s Closing to be reached. There

has been no dereliction of duty on the part of either NRW or WG in this

regard, rather, a proper engagement between experts considering matters

objectively.

389. S.28G itself provides as follows:

“Statutory undertakers, etc.: general duty. (1) An authority to which this section applies (referred to in this section and in sections 28H and 28I as “a section 28G authority”) shall have the duty set out in subsection (2) in exercising its functions

239 Criticism of WG by RSPB in their letter of 27th May is, therefore, doubly misplaced. They were apparently surprised to find out what the law actually is and then implied that WG had, in fact, ignored / proposed to ignore the advice of NRW, which contention is plainly untenable, on the basis of NRW’s own evidence, as well as WG’s ecology, water quality, flooding and environmental evidence. 240 ID/063

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so far as their exercise is likely to affect the flora, fauna or geological or physiographical features by reason of which a site of special scientific interest is of special interest. (2) The duty is to take reasonable steps, consistent with the proper exercise of the authority’s functions, to further the conservation and enhancement of the flora, fauna or geological or physiographical features by reason of which the site is of special scientific interest. (3) The following are section 28G authorities— (a) a Minister of the Crown (within the meaning of the Ministers of the Crown Act 1975) or a Government department; (b) the National Assembly for Wales; (c) a local authority; (d) a person holding an office— (i) under the Crown, (ii) created or continued in existence by a public general Act of Parliament, or (iii) the remuneration in respect of which is paid out of money provided by Parliament; (e) a statutory undertaker . . . ; and (f) any other public body of any description. (4) “Statutory undertaker” means a person who is or is deemed to be a statutory undertaker for the purposes of any provision of Part 11 of the Town and Country Planning Act 1990.”

390. Whilst the section imposes the subsection (2) duty, this duty is qualified.

What is required of a relevant authority (including WG/WM) is to take:

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- reasonable steps

- consistent with the proper exercise of the authority’s

functions

to further the specified SSSI objectives. In closing, Richard

Wald summarised NRW’s remaining s.28G case as being “in

a nutshell, NRW is not satisfied that reasonable steps have

been taken.” In WG’s submission, NRW have signally failed

to justify this stance, either by their own evidence or through

cross examination of WG’s witnesses.

391. As Ms Poole recognised in cross examination, Part 2 of the Act, in its

general scheme, and s.28G in particular, gives recognition to the other

public interests involved when considering the implications for SSSIs of

public projects. It is also apparent from the qualified nature of s.28G, as

she went on to agree, that full mitigation of impacts is not required in such

instances. In Closing, counsel for NRW accepted that the nature of the

statutory requirement under s.28G is “not absolute” and put their remaining

points on the basis that they should “weigh against the acceptability of the

M4CaN Scheme.” 241 Whilst WG strongly submits that these impacts do

not outweigh the need for the Scheme, for reasons set out above (flooding)

and below (loss of reens and ditches, bats and landscape/cultural

heritage), we welcome NRW’s recognition that the approach is one of

weighing up pros and cons. It should also be noted that their closing

submissions do not argue that the Scheme should be rejected; instead,

241 DOC PID244 p.9, paras 25, p.16 para 34 and p.28 para 69

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they request that their outstanding objections be “given significant

weight…..in the no doubt further careful consideration of the ..Orders.”

Their adoption of this approach to the question is significant in the light of

the submissions of GWT and others on the relevant environmental

legislation. By the end of the process, NRW properly recognise that

assessment and decision making must proceed on a careful appraisal of

the evidence which is then weighed up in order to reach the right

conclusion in the light of all competing considerations. Whether or not WG

have discharged the duty, on this – correct – analysis, is a question of

judgment. That judgment must, however, be based on evidence and not

mere assertion or feeling.

392. The concessions on approach by Ms Poole and Richard Wald are

significant because initially NRW’s objections242 were predicated on

seeking or requiring full mitigation of impacts on the SSSIs rather than

recognising that the law permits less than that where the steps taken are

reasonable ones, consistent with the proper exercise of the authority’s

functions. Thus, the law permits SSSI interests to yield to other

considerations so long as the steps taken to further conservation and

enhancement of the relevant features are reasonable. Therefore Ms Poole

rightly accepted that NRW’s evidence had not attempted a full

consideration of the s.28G questions, since they had not called evidence

on highways engineering, traffic modelling, economics or the host of other

matters involved in the discharge by WG of its functions as a Highways

Authority and the national Government. The questions on this point were

242 As well as those of others, principally GWT

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entirely fair and her admissions were entirely appropriate. Again,

complaints by RSPB about this passage of the evidence simply served,

with respect, to illustrate an incomplete appreciation of the law on the part

of some who were observing the inquiry at this point. Indeed, as was made

clear at the outset of WG’s cross examination of Ms Poole, part of the

purpose of the questions was to ensure that other organisations and their

representatives might have a full understanding of NRW’s role. To the

extent that the exchanges, which were wholly amicable, have prompted

surprise, they have served this part of their purpose. Neither RSPB nor Mr

Byrne chose to give evidence themselves and it was appropriate, in the

circumstances, to explore these points with NRW’s lead officer.

393. The RSPB letter243 accepts that the new legal duties arising from the Welsh

legislation do “not act as an absolute prohibition on harm” so there really

should be no controversy about the obvious proposition that ecological

interests do not necessarily trump other considerations. The reality, of

course, is that these objectors disagree with the way in which WG has

balanced these considerations, but that is wholly different from a contention

that WG has got the law wrong. It will be for WM, guided by the Inspectors’

report, to weigh the competing considerations in the light of all the material,

including the extensive evidence of steps which WG proposes to take to

maintain, enhance and mitigate impacts upon biodiversity in general and

SSSIs and protected species in particular. The Welsh legislation will be

analysed in detail below, along with the position regarding protected

species.

243 ID / 088

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394. Returning specifically to s.28G, however, there is nothing new or alarming

in WG’s interpretation of the law. Hickinbottom J construed s.28G in the

FOEC case where it was submitted by the Claimant that:

"WG failed properly to understand the nature of its duty under s.28G, which gave the protection and preservation of SSSIs enhanced weight in the decision-making process, such that there is a presumption against any plan that would lead to harm to such sites.”

395. The judge described this as a “bold submission” and he rejected the

analogy which the Claimant sought to draw with s.66 PLBCAA 1990 (the

planning equivalent to the s.16 LBC duty considered above). He said that

s.28G was “in entirely different terms”. It does not impose a general duty

on the decision-maker to have some particular regard to the desirability of

protecting and preserving SSSIs; it imposes an entirely different type of

obligation, namely a duty to ‘take reasonable steps … to further the

conservation and enhancement of the flora, fauna or geological or

physiological features by reason of which the site is of special scientific

interest’.” He therefore went on to hold that the duty “does not seek to

protect SSSIs by weighing the desirability of their protection as against

other factors, but by requiring relevant authorities to take reasonable steps

‘to further the conservation and enhancement of the … features by reason

of which the site is of special scientific interest’.”

396. Turning to the facts to date, the Judge noted the following:

i) “In the early 1990s, the Countryside Council for Wales expressed concerns about potential environmental impact of the proposed M4 relief motorway, routed

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as it was south of Newport and across the Gwent Levels SSSIs. As a result, a further review was carried out, which noted the detrimental environmental effect that any northern route motorway would have, and confirming the southern route was preferred (see paragraph 29 above). ii) For the purpose of the first TR111 notice in 1995, the route was identified to “minimise the potential impacts” on the Gwent Levels SSSIs…….. iii) The route was altered – moving it north – as a result of a review in 2004-6, to reduce the impact on and severance of the Gwent Levels SSSIs. The review specifically and expressly took into account the strengthening of the protection for SSSIs by the 2000 Act and particularly the Welsh Government’s duty under section 28G of the 1981 Act brought into being by the 2000 Act. In announcing the consequent revisions to the preferred route in the 1997 TR111 Notice, the Minster emphasised that the changes “offer a clear benefit to the environment by taking the route northwards and where possible onto land previously of industrial use thereby reducing its impact on the Gwent Levels including the [SSSIs]” ………... iv) The March 2013 WelTAG Appraisal specifically took into account, for each option considered, the comments received from the consultation on the November 2012 Environmental Report ……….. v) The June 2013 WelTAG Appraisal did not deal with environmental matters in any detail, pending the SEA Report. However, it said that all three highway options “result in moderate to large impacts on the environment…”. It also indicated that the main ecological interest of the SSSIs was the reen system………. vi) The 2013 SEA Report expressly took account of the 2000 Act as a relevant statute, and, in detail, assessed the

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significant effects of the draft Plan and the chosen reasonable alternatives, determining the significance of effect as “minor negative” …………. vii) The SEA Post-Adoption Statement set out the potential environmental effects and associated mitigation, in detail, in a similar manner to the SEA report ……..

135. Mr Moffett submitted that the only steps that the Minister could have taken to conserve or enhance the relevant features would have been: i) Not to proceed with any option that involved a highway across the Gwent Levels SSSIs. However, as I have explained, none of the options that did not involve such a highway came anything like achieving the objectives, namely the TPOs or (in short) the relief of the M4 motorway around Newport. The do-minimum scenario was also discounted on, amongst other things, the environmental unacceptability of the status quo. ii) To mitigate the harm necessarily caused by such a highway. Looking at the history, briefly related above, it is simply not maintainable that the Minister was not sensitive to that harm, and to the importance of mitigating and minimising it. Indeed, as Mr Moffett submitted, looked at fairly, the whole process that resulted in the decision challenged was focused on the potential harm to the Gwent Levels SSSIs of a new highway crossing them, and the mitigation of that harm. The Minister clearly paid the SSSIs and the desirability of preserving and protecting them the regard required of her. She did not arguably err in this regard.”

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397. This lengthy quotation from the judgment helpfully summarises the steps

taken up to adoption of the Plan in discharge of the s.28G duty. It is notable

that the Judge dismissed FOEC’s argument as unarguable.244

398. The passage in TAN 5: Nature Conservation, relied on by Richard Wald for

NRW245 in cross examination of John Davies MBE and in closing, to the

effect that the Government expects s.28G authorities “to apply strict tests

when carrying out functions within or affecting SSSIs, to ensure that they

avoid, or at least minimise, adverse effects”, in no way conflicts with the law

as enunciated by Hickinbottom J in the judicial review or as put by WG in

the inquiry. (Emphasis added) The TAN recognises that, even putting itself

under a “strict” test, a s.28G authority may, as a matter of judgment, decide

that adverse effects on SSSIs cannot be avoided, hence the reference to

minimisation. That part of the guidance recognises that the ultimate

judgment about the reasonableness of steps is to be reached in such a way

as to be consistent with the proper exercise of the authority’s functions. Mr

Davies MBE did not shrink from agreeing in cross examination that, as a

matter of practice (as opposed to law) WG should be an exemplar but

added that, in his view, the Scheme is that. This judgment is justified by the

minimisation of SSSI landtake when the decision was taken in 2006 to

move the line northwards and by the detailed work during Scheme

development of the ecological, water quality, contamination and

engineering/construction teams, in consultation with NRW, to design in and

244 The case comprised a so-called “rolled up hearing”, where the Court considers both the threshold (permission stage) question of arguability which arises in a judicial review and the substantive claim. In relation to this ground, the Judge found that it was not even arguable, i.e.. it would not have passed the threshold (permission) test. 245 And RSPB in the letter of 27th May 2017

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develop “reasonable steps” for the protection of SSSI features, as well as

other natural resources, biodiversity and ecosystems.

399. It is also clear, from a proper consideration of s.28G, that mere land-take is

not the issue. NRW’s Closing was inconsistent in this respect. Having

accepted the non absolute nature of the s.28G duty, Richard Wald

inconsistently continued to submit that the SSSI land take was “manifestly

excessive”, evidencing a “breach of s.28G”.

400. This submission was doubly unjustified. It was wrong in law, because

inconsistent with the proper interpretation set out by Hickinbottom J and

accepted elsewhere in the Closing. Moreover, it simply did not reflect the

evidence. Despite the position taken in her proof,246 Ms Poole agreed in

cross examination that scale of loss alone “cannot answer the question” of

acceptability under s.28G or generally. This is for several reasons. Firstly,

in s.28G terms, as Hickinbottom J held, the question is as to the

reasonableness of steps to further the conservation and enhancement of

the features. The law leaves this judgment to the relevant s.28G authority:

at promotion stage, WG; at decision stage, WMs. Unless the decision

maker reaches a judgment which is irrational in the legal sense, it is for him

/ her to evaluate the reasonableness of steps in the light of the statutory

objective that they should be consistent with the proper exercise of the

authority’s functions. Consequently, the judgment about loss cannot be a

mere numbers game, because it will depend on the quality and significance

of what is lost. Richard Wald made this point about significance of

consequences in re-examination of Ms Poole and in closing, but did not

246 Proof para 4.2.8, e.g..

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develop it by reference to the evidence. In fact, the evidence of NRW’s

SSSI feature sheets, disclosed to WG in autumn 2016, clearly

demonstrates that the majority of the land in the SSSIs, far from exhibiting

notification features, is very ordinary and contributes negatively to the

condition of the important features as a result of modern farming practices

and/or industrial pollution.247 As a result, the SSSIs are in unfavourable

condition. Dr Ireland and Mr Jon Davies pointed out more than once that

eutrophication of reens and ditches and agricultural “improvement” of

grazing marsh due to unregulated modern farming practice has caused

many of these features to exhibit less biodiversity than might be expected

of a SSSI of this type. Mr Boyce’s surveys between the years 2009 and

2012 surveys for CCW (NRW’s predecessor) concluded that the figures for

invertebrates in various SSSIs were low compared to grazing marsh

ditches sampled in other parts of southern Britain, such as the Somerset

Levels248 and there is no evidence of improvement in the meantime. The

allegedly “manifestly excessive” SSSI land take is, in fact, less than 2% of

the Levels designations.

401. Similarly, whether or not the scale of land take is “unprecedented” does not

assist in making a judgment about the reasonableness of steps.

Furthermore, as Ms Poole agreed,249 the judgment must be made in

relation to the Scheme itself, rather than earlier developments. This latter

point is important, given the emphasis placed on precedent by many

objectors. Mr John Davies MBE has also explained, more than once, that

the nature of balanced decision making required here means that the

247 ID/049 Appx A to SSSI Mitigation Strategy. 248 Doc. 2.3.2 ES p.10-121, para 10.4.501 249 Cross examination (MEQC)

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Scheme would not create a precedent for further development if approved

because of its unique nature.250 This is the answer to fears about the solar

farm NSIP proposal raised by RSPB, GWT and others.

402. Turning to consider the evidence about the steps taken by WG, Dr Ireland

explained that the multi-disciplinary team worked to minimise impacts on

the SSSI as the design was taken forward from the concept stage

approved in the 2014 Plan. As noted above, the lawfulness of WG’s

approach to selection of the route and adoption of the Plan has been

established by the court.

403. Dr Ireland said that, starting from the establishment of the strategic position

(i.e. arriving at the Plan), the team moved to considering the scope for

reduction. The decision of principle having been made to place the line as

far north as possible, there followed many subsidiary decisions where the

SSSI was taken into account. For example, in response to advice from

NRW, two of the six water treatment areas (“WTAs”) were located to the

north of the road so as to avoid SSSI land take. It was not possible to place

more of them outside the SSSIs because of the low fall of the carriageway,

occasioned by keeping the road as low as possible in the landscape.

Another example of SSSI – led thinking is the detailed consideration given

to reen/ditch continuity and replacement now set out in the Buildability

Report251. Such is the importance of this issue that WG requested a special

multi-disciplinary inquiry session to explain the proposals as had earlier

been undertaken with NRW. On neither occasion did NRW query the

engineering or ecological approach.

250 Wentlooge CC Rebuttal WG/REB/6904 section 3.6 and in the recent rebuttal of Hepworth/CPRW in ID213 section 2.4. 251 2.4.14.12 Appendix SR3.1 of the December 2016 ESS

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404. In closing, despite the allegation of “manifestly excessive” SSSl landtake,

the only example relied upon was the Glan Llyn junction. NRW’s concern

was based on the belief that it would take 12ha of SSSI land, Ms Poole’s

point on this being expressed in terms of NRW’s not being satisfied that

WG had demonstrated strict testing of SSSI loss. However, it was

established during the Inquiry that the SSSI landtake for the junction (as

distinct from the carriageway) was, in fact, c. 4.3ha252 and Ms Poole agreed

in cross examination that her concern was therefore reduced.

405. As Dr Ireland and Mr Jon Davies stated when cross examined on the

mitigation hierarchy, the fact is that WG’s Plan was scrutinised by the Court

for compliance with the s.28G duty and found to be lawful. Subsequent to

that, a host of individual decisions had to be taken as the Scheme

developed. Specifically with regard to Glan Llyn, where the junction was

added in response to a clear need for it articulated by NCC, it was

necessary to look at ways to reduce landtake, which is what WG did. NRW

neither led evidence nor challenged WG’s witnesses to suggest that NCC

and WG were wrong about the strategic need for a junction at this location.

Whether or not the Options and Appraisal Report described it in exactly the

terms that counsel sought in his questions was not the point. Obviously,

scope for the precise siting of the junction was limited in terms of the line of

the route – as far north as possible to minimise effects on the Levels.

Within these constraints, however, landtake had been minimised. Mr Sibert

explained the design development of this element.253. Challenged about the

team’s process of arriving at their Glan Llyn decision, Dr Ireland explained

252 When deducting the carriageway from the total required for carriageway and junction at this point: see PIQ 98 and Peter Ireland’s explanation in chief, which was not challenged 253 Proof WG 1.5.1 paras. 4.34 – 4.40

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that there were other constraints in play when siting the junction – needing

to limit the level of contaminated land for potential removal and the desire

to minimise impacts to the electricity grid.

406. Dr Ireland confirmed:

"the SSSI was always at the fore of our minds – that is, the environmental and design team – JV’s and WG’s thinking. It was looked at in relation to the location’s other factors which were coming to the fore – factors that could cause difficulty in terms of uncertainty of programme, etc. The decision was this was the optimum.”254

WG has amply demonstrated a rigorous process with regard to use of SSSI

land for the Glan Llyn junction.

407. As Mrs Jacob agreed,255 promoting a road scheme is a complicated

business. S.28G – and the environmental duties contained in it and Part 1

of the EWA 2016 – are flexible enough to enable public bodies, be they

promotors or decision makers, to reach judgments in the public interest

about complex matters. Prolonged testing of WG’s approach by NRW,

inside and outside the inquiry, has helped to shape this Scheme and the

steps to further conservation and enhancement of SSSI features.

408. So far, this review of the evidence has focused on route selection and

embedded mitigation by design. It is also very important to consider the

additional mitigation measures proposed in respect of SSSI landtake and

operational impacts.

254 Re-examination (ME QC) 255 Cross-examination (ME QC)

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409. Before turning to the detail of the SSSI mitigation strategy, it is right to

recall that, by the end of the inquiry, there was a substantial measure of

agreement with NRW about effects on SSSI and natural resources,

biodiversity and ecosystems generally. The SSSI SOCG of May 2017

between WG and NRW records the following matters:

(i) Landtake on the SSSIs is accurately described and assessed in the

ES;

(ii) the replacement of infilled and culverted reens and ditches is to take

place at an agreed ratio of approximately 1:1;

(iii) the SSSI mitigation strategy (now agreed in its draft form256, taking

account of NRW’s comments, as anticipated in the SoCg257)

provides for mitigation at three sites. Two of these (Maerdy Farm

and Tatton Farm) are within SSSIs. The third (Caldicot Moor) is on

the Gwent Levels but outside any SSSI, though adjacent to the

Magor and Undy SSSI. In each case, arable land would be

converted to permanent grassland, existing grassland would be

enhanced for biodiversity and former ditches which have been

infilled would be reinstated. It is also agreed that the areas of land

are appropriate in the light of the predicted impacts of the Scheme

on the Gwent Levels SSSIs and essential mitigation. The latter point

is important in terms of demonstrating need to justify compulsory

acquisition of some of the land (at Caldicot Moor). As Dr Ireland

256 Deliberately not in its final form, it needs to be checked against all the more recent draft mitigation strategies (dormouse, bats, protected species) to ensure that all the mitigation strategies are integrated as per Commitment 212. 257

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explained, the other areas were chosen because, as well as having

the necessary potential to fulfil mitigation needs, they are already in

WG ownership; WG thus observed its obligations to use a CPO as a

last resort and chose land which could start to be prepared early,

maximising its mitigatory effect;

(iv) Having regard to the SSSI mitigation and enhancement proposals

would commence in advance of construction and that improvements

in the ecological interest of the grasslands would be expected to be

manifest within a few years, the significance of the land take impact

would be reduced from Moderate or Large in the short term to Slight

or Moderate in the medium to long term;

(v) As a result of the small extent of construction land within the SSSIs,

the agreed SSSI mitigation strategy and the ability for land severed

by the Motorway to continue to be managed as grazing marsh

alongside the road, construction and operation effects would be of

slight or moderate significance in the medium term and of slight

significance in the long term;

(vi) Having regard to severance effects in some areas and the ability for

continued management as grazing marsh, operational effects would

be of slight significance.

410. Ms Poole confirmed258 in her oral evidence that she was satisfied that there

would not be indirect effects on the Rumney and SSSI, the

Magor and Undy SSSI, the Newport Wetlands SSSI or the Magor Marsh

258 Jess Poole evidence in chief. See also RW’s Closing ID

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SSSI. She was able to reach this conclusion because of NRW’s

acceptance that WG’s road drainage proposals would be appropriate in

terms of water quality and quantity. She agreed in cross examination that

this removed one of NRW’s four issues with regard to SSSI impact.

411. One might be forgiven for feeling some surprise at these matters of

agreement given the exaggerated claims made in some quarters about the

effect of the Scheme on the Levels. It is understandable that members of

the public will not be au fait with all the scientific detail, but their

contributions to the inquiry must be considered in the context of these

carefully considered expressions of agreement with basic and important

conclusions of the ES on SSSI effects. The inspectors should give them

very great weight when considering the ecological evidence of other parties

and when carrying out the balancing exercise between SSSI impacts and

the benefits of the Scheme. One particularly important example arises

from Agreement Points (v) and (vi). Prof Sir John Lawton and GWT

generally raised objections in strong terms on the basis of severance. We

deal below with the weight to be given to written evidence of this type and it

is significant, in our submission, that NRW, having carefully considered the

Buildability Report, Mr Richard Graham’s evidence on water quality, the

EMPs and all the other evidence showing how connectivity of reens and

ditches and retention of grazing marsh in active use would be achieved, as

well as the biodiversity benefits of the SSSI mitigation areas, reached the

conclusion that impacts on severance would be slight in the medium / long

term.

C:5493828v1 228

412. It is impossible to overstate the importance of WG’s proposals for road

drainage, safe handling / re-use of contaminated materials and

maintenance of water quality and quantity across the Levels. Many

objectors, not having got up to speed with the detail (some of which is

highly technical), assumed that these matters would not have been

properly addressed and would not be properly managed259. The fact that

NRW / the Internal Drainage District (“IDD”) are satisfied with the

robustness of the designs and proposals, including monitoring and funding

Commitments, is of great evidential significance in terms of considering

both NRW’s residual objections and other objections based, in whole or in

part, upon SSSI impacts.

Water quality

413. Much of the ecological interest and value of the Gwent Levels derives from

the system of reens and ditches. The value and sensitivity of the aquatic

environment has informed the design of the drainage for the Scheme.

Richard Graham gave evidence on these matters on three occasions. On 9

May 2017 he answered questions from Mr Pickup, who has a detailed

knowledge of the Gwent Levels and the water environment, and on 25 May

2017 Mr Graham and Mr Jon Davies were cross examined by GWT’s Mr

Byrne. Mr Graham’s evidence was impressive. Mr Pickup’s concerns were

largely addressed by Mr Graham’s oral evidence and the content of his

259 OBJ0270 Gwent Wildlife Trust including Neil Ward, Lindi Rich, James Byrne, David Boyce, Geoff Liles; OBJ0077 A. R. Pickup; OBJ0266 Louise Davies, OBJ0154 Laurence Lowe, OBJ0203 Ann Picton MBE

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rebuttal. Mr Vaughan, who dealt with flooding, explained why Mr Pickup’s

favoured means of draining run off via the main rivers was not practicable.

414. The drainage system consists of a treatment train with four stages – grass

lined channels, a pollution lagoon, an attenuation lagoon or sediment pond

and finally a reed bed. While none of these stages is and of itself unique or

innovative the combination of all four stages in one drainage system is

unprecedented. The scale of attenuation is also remarkable. Mr Graham

explained that many grass lined channels or swales are in the region of 10

to 20 metres. The lengths in this case are very much greater and the

gradients very flat which means that pollutants will spend much longer in

the grass lined channels thereby greatly enhancing the chances of the

pollutants being removed or degraded whilst in the channels.

415. WG and NRW have reached complete agreement in respect of drainage

and water quality – ID 53. In terms of the baseline:

“2.2.4 Baseline monitoring indicates that with respect to determinands likely to be released by road runoff (i.e. dissolved and suspended metals, hydrocarbons and salt), concentrations in the Gwent Levels are low to very low and well within safe levels.

2.2.5 There were undesirable concentrations of nutrients and other signs of nutrient pressures, but these are not likely to be affected by road runoff”

416. There will be a heightened risk to water quality during the construction

period but that can be managed – SoCG 2.3.

417. The drainage system which has been designed is an exemplar:

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“2.5.2 The large, multi-method design of the proposed Scheme drainage Water Treatment Areas (WTAs) represent a much higher standard of treatment than comparable road schemes in Wales and would treat run off from the motorway to higher standards than is usually required for trunk roads. This is necessary given that all of the Scheme water discharged by WTAs flows into the SSSIs and the sensitivity of the Gwent Levels SSSIs to water quality impacts”

418. The methodology employed for designing the treatment of run-off and

assessing its likely efficacy – HAWRAT – is the best available, SoCG 2.5.9.

But due to uncertainty relating to HAWRAT’s limitations “a number of

precautionary assumptions have been made in relation to flow and

treatment train performance” - SoCG 2.5.10.

419. Appropriate commitments have been made on the Register of

Environmental Commitments relating to monitoring, taking remedial action

and maintaining the different legs of the treatment train – SoCG 2.5.14,

2.5.15, 2.6.2 and 2.6.3.

420. With regard to protection of the Gwent Levels from potential spills on the

new section of motorway, the proposed drainage system provides a high

initial storage volume within the nearly flat and impervious grass lined

channels in addition to a penstock controllable pollution control lagoon at

every WTA. This provides opportunities to retard and capture potential

major spills on the carriageway and prevent release of such spills to reens -

SoCG 2.5.12.

421. To ensure longer term functionality of the drainage system and to further

protect the Gwent Levels from potential declining performance as a

consequence of silt build up, a WTA maintenance schedule has been

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proposed in keeping with DMRB standards. This maintenance programme,

coupled with a comprehensive monitoring regime at every proposed WTA

discharge for a minimum of five years, will provide a robust body of

evidence on the compliance status of the drainage system with NRW water

quality criteria for the SSSIs. In this way, any adverse deviations from

expected performance can be identified, investigated and corrected for in a

timely manner - SoCG 2.5.14-15.

422. It is also agreed that the settlement lagoons and the reedbed systems have

potential biodiversity benefits and commitments are included to promote

these benefits and to guard against colonization by invasive species –

SoCG 2.5.16. Both Mr Graham and Mr Jon Davies observed that the Tata

lagoons had become a haven for wildlife and that the level of pollutant in

those water bodies was significantly greater than the pollution which will be

present in the settlements lagoons and reedbeds serving the Scheme.

423. The water within the reens and ditches are not in good condition. This,

however, is due to elevated levels of nutrients. Road run-off will not contain

nutrients and the levels of pollutants likely to be released by road runoff in

the Gwent levels are low or very low and well within the safe levels. Allied

to the very high level of treatment provided we submit that water quality will

be preserved in this sensitive and valuable environment.

424. NRW’s remaining issues were:

- extent of loss, which has been addressed above and in respect of

which the steps taken to mitigate, both through the three mitigation

areas and reen/ditch replacement must be taken into account;

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- connectivity/design of the proposed reen and ditch network and

inequality of mitigation across SSSIs; and

- security of long term funding for management of reens, ditches and the

mitigation areas.

425. The long term funding issue has now been resolved to NRW’s satisfaction

by means of Commitments 195, 196 and 197, which provide for funding of

extra management functions incurred as a result of the Scheme and for

complying with the Environmental Commitments. Resolution of this point is

highly significant because it means that the inspectors can approach their

assessment of the effects of the Scheme upon the SSSIs and biodiversity

generally on the basis that mitigation measures will be properly funded in

perpetuity. Where NRW would be involved in that work, they will be

reimbursed for any extra costs occasioned by the M4CaN. This important

fact should be borne in mind when evaluating NRW’s (and others’)

remaining SSSI points about the effectiveness of mitigation.

426. The Nationally Designated Sites SOCG sets out the position with regard to

reen and ditch design as at 17 May 2017, but Ms Poole updated and

clarified matters in her oral evidence. She stated that, in her opinion, WG

had done everything possible and that “the proposals are the best they

could possibly be”. Given the s.28G duty to take “reasonable steps,” this

statement is highly significant. Ms Poole said this because, in response to

NRW’s PIQ’s and the Appendix to her proof, WG had confirmed that reens

and ditches could be designed in an ecologically sensitive way, with

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sinuous routes, variable widths, berms and grazing areas on banks.260 All

of these features would support biodiversity by allowing for variation and

different micro-habitats to be available. Ms Poole expressed NRW’s

satisfaction with the proposed construction method, which would maintain

connectivity and involve the transfer of organic material from old to new

reens. She was also pleased with WG’s commitment to monitoring and

where necessary, remedial action.261 NRW’s only remaining concerns at

the stage when she gave evidence related to the time that it might take to

support SSSI features, inequality of provision across different SSSIs and

the mechanics of WG’s funding commitment.

427. As we have seen, the funding question is now resolved.

428. The timescale point was related, in part, to the timing for construction

works. Ms Poole said that her concern was that if works were done during

the summer, algal bloom was likely to form, which would compete with

species of interest in terms of SSSI features/biodiversity. Dr Ireland

explained that the movement of material from old to new reens would “give

a headstart to establish vegetation”. Whilst that would not totally prevent

algal bloom, it would inhibit its development. In the event of real problems,

there are natural remedial measures available. The three year construction

and five year aftercare periods for monitoring would be useful in this

respect. Whilst WG could not make a commitment to avoid summer

working, because of the need to maintain the construction programme, the

situation could be monitored and, where necessary, addressed.

260 See PIQ /94 amplified by Dr Ireland in chief 261 See Commitments 62 and 130, which are acceptable to NRW.

C:5493828v1 234

429. Dr Ireland was able to confirm that works could/would start on the

mitigation strategy at Tatton Farm early.

430. In conclusion, NRW substantially recognised that the mitigation measures

proposed were appropriate and feasible. Their remaining point on timing

was fully answered by Dr Ireland whose detailed evidence should be

preferred to the generalised complaint. Mr Jon Davies stated, on several

occasions during the inquiry,262 his belief that, given time, the proposed

SSSI mitigation areas, including their restored reens and ditches, would

make a substantial contribution to biodiversity and that Caldicot Moor would

develop in such a way as to justify SSSI status in due course; he likened

WG’s vision for the three mitigation areas to the Magor Marsh reserve,

where one can see the benefits of the Levels landscape where it is

managed for nature conservation, rather than commercial agriculture.

431. Unlike NRW, GWT and other objectors263 have, apparently, disregarded or

downplayed WG’s well conceived mitigation proposals. But they have been

unable to demonstrate that Mr Jon Davies’ assessment is false. He has

repeatedly explained, in chief and under cross examination, that the

mitigation tasks and methods in issue are not unduly complex or risky. He

pointed to Magor Marsh as local proof, as well as published studies from

other parts of the country with similar habitats and ecosystems264. GWT

called no live witnesses to substantiate their repeated general critiques of

262 Eg. in response to GWT’s Invertebrates and Water vole objections and when presenting evidence on Ecosystems Services 263 See eg. summary of GWT’s position in Mr Byrne’s Supplemental Written Statement presented in ID/217 (pp.7-9). Also Mr Byrne’s and Prof Sir John Lawton’s “Statements of Evidence” dated February 2017 264 See response by Jon Davies op. cit. pp.8-9 and Responses to James Byrne WG/REB/OBJo270.16 pp.12-20 and Appx A- Norfolk, Somerset,Oxon, Powys and to Prof Sir John Lawton WG/REB/OBJo270.12 – GWT/Lawton

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the WG team’s work – and critiques is what they were, not independent

surveys or assessments. The inquiry cannot know, therefore, how much

Prof Sir John Lawton, Prof Maltby or, indeed, Mr Byrne had actually read in

relation to WG’s proposals, let alone form an understanding of the detailed

basis – if any – for their generalised criticisms. Mr Jon Davies, on the other

hand, was prepared to be cross examined, showing himself to be an

experienced, responsible, knowledgeable and visionary ecologist whose

evidence should be afforded great weight. He was ably supported by Dr

Ireland with his vast experience of the environmental design, assessment

and management of road schemes. Part of the point of a public inquiry is to

enable evidence to be rigorously tested. In WG’s case, this was done,

repeatedly. No fundamental flaws in the approach to mitigation were

discovered and full weight should be given to the proposals, both as

mitigation and as a legacy of enhancements in a number of areas.

432. Turning to NRW’s quantitative issue, Ms Poole acknowledged that NRW’s

concern about inequality of reprovision was raised late in the day. She

clearly did not regard it as a strong point. WG originally proposed to

replace reens and ditches at a ratio of 2.76 for reens and 1.26 for ditches.

NRW/IDD were concerned that this overprovision would, potentially, make

it difficult to maintain sufficient depth of water across the Levels and

responded that the ratio should simply be 1:1. This advice was given early

in the process of Key Stage 3 design, before the Scheme and associated

Orders and ES were made or published. No quantitative issue was raised

in NRW’s comprehensive letter of May 2016. In September 2016, Ms

Poole realised that reprovision would be greater in the Wentlooge Levels

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than in the Caldicot Levels and therefore unequal as between individual

SSSIs. This was discussed with WG at that time and the team responded

with a proposal to restore Ellen’s Reen in the Nash and Goldcliffe SSSI, to

the south of Tata Steel, which Ms Poole acknowledged went some way to

addressing the point. Taking this addition into account, the resultant figures

are:

The total replacement reen length is 2826m (from RMS) + 610m (from Ellen Reen diversion) = 3436m

The total field ditch loss is 9373m (from RMS) + 610m (converted to reen for Ellen Reen diversion) = 9983m loss

The total replacement field ditch does not change from RMS = 10594m

433. Against this background, Ms Poole voiced NRW’s concern somewhat

tentatively in her oral evidence and readily acknowledged, then and in

writing, that the subdivision of the Levels into a number of different SSSIs

was, in part, for administrative convenience at the notification stage.

Nevertheless, there are subtle differences between them and the concern

is to maintain biodiversity across each. Dr Ireland further responded to the

residual concern with the suggestion that existing ditches could be cleaned

out and widened to facilitate reen characteristics and managed to enhance

their biodiversity. The point here is that, whilst reens are managed by NRW

wearing their IDD hat, ditches are not under their management, being,

instead, the responsibility of their owners. This, indeed is part of the reason

for the SSSIs being in unfavourable condition, as noted above. Dr Ireland’s

proposal would address the concern about providing adequate mitigation

for the impacts to biodiversity in the Caldicot SSSIs whilst not leading to

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difficulties with regard to drainage management. Possibly because of Ms

Poole’s indisposition, Dr Ireland’s idea, to which she was receptive at the

inquiry, was not taken any further by NRW. No further light was shed on the

concern in NRW’s Closing. In the absence of any coherent ecological

explanation, this cannot be treated as an objection of real significance.

434. To conclude on NRW’s case in relation to SSSI impacts/s.28G WCA 1981,

their remaining concerns are limited. These concerns must be assessed in

the context of law and guidance and weighed against the need for and

benefits of the Scheme, as they recognised in evidence and in closing.

435. NRW’s objection on scale of loss proceeded on an inaccurate premise with

regard to Glan Llyn junction, which was the only example which was

advanced. WG has given a full explanation of its efforts to minimise

landtake, having regard to the proper exercise of its functions as Highways

Authority and Government concerned to promote the nation’s economy.

Coupled with Ms Poole’s satisfaction that the reen design and monitoring

proposals are the best they could be, in NRW’s agreement, it is clear that

the statutory duties have been discharged by WG and that the Inspectors

and WMs should approach their own assessments on this basis. The law

does not require an absence of impact or total certainty or immediacy of full

mitigation. Reasonable steps have been taken and are proposed for the

future to further the conservation and enhancement of SSSI features and to

promote the resilience of ecosystems, in each case, consistent with the

proper exercise of WG’s functions.

436. Many other objectors have claimed that WG is in breach of s.28G, sections

6 and 7 EWA 2016 and s.4 NERC 2006. Here again, the effect of the law

C:5493828v1 238

has been overstated, for reasons set out in detail above. Species-specific

objections are considered in the next section.

Environment (Wales) Act 2016, Specific Species and Habitats

437. The purpose of Part 1 of the Act is “to promote sustainable management of

natural resources”, the latter being defined to include “animals, plants and

other organisms; air, water and soil, minerals; geological features and

processes; physiographical features; and climatic features and

processes”.265

438. S.3 provides:

“Sustainable management of natural resources (1) In this Part, “sustainable management of natural resources” means— (a) using natural resources in a way and at a rate that promotes achievement of the objective in subsection (2), (b) taking other action that promotes achievement of that objective, and (c) not taking action that hinders achievement of that objective. (2) The objective is to maintain and enhance the resilience of ecosystems and the benefits they provide and, in so doing— (a) meet the needs of present generations of people without compromising the ability of future generations to meet their needs, and (b) contribute to the achievement of the well-being goals in section 4 of the Well- being of Future Generations (Wales) Act 2015 (anaw 2).”

265 SS.1 and 2 Environment (Wales) Act 2016

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439. S.4 sets out the “principles of sustainable management of natural

resources” as follows:

“In this Part, the “principles of sustainable management of natural resources” are— (a) manage adaptively, by planning, monitoring, reviewing and, where appropriate, changing action; (b) consider the appropriate spatial scale for action; (c) promote and engage in collaboration and co-operation; (d) make appropriate arrangements for public participation in decision-making; (e) take account of all relevant evidence and gather evidence in respect of uncertainties; (f) take account of the benefits and intrinsic value of natural resources and ecosystems; (g) take account of the short, medium and long term consequences of actions; (h) take action to prevent significant damage to ecosystems; (i) take account of the resilience of ecosystems, in particular the following aspects— (i) diversity between and within ecosystems; (ii) the connections between and within ecosystems; (iii) the scale of ecosystems; (iv) the condition of ecosystems (including their structure and functioning); (v) the adaptability of ecosystems.”

C:5493828v1 240

440. Section 6 imposes duties on WG, the WMs and the Inspectors266 in respect

of biodiversity and eco-systems. It provides as follows (so far as relevant):

“(1) A public authority must seek to maintain and enhance biodiversity in the exercise of functions in relation to Wales, and in so doing promote the resilience of ecosystems, so far as consistent with the proper exercise of those functions. (2) In complying with subsection (1), a public authority must take account of the resilience of ecosystems, in particular the following aspects— (a) diversity between and within ecosystems; (b) the connections between and within ecosystems; (c) the scale of ecosystems; (d) the condition of ecosystems (including their structure and functioning); (e) the adaptability of ecosystems. ...

(4) In complying with subsection (1)— (a) the Welsh Ministers, the First Minister for Wales, the Counsel General to the Welsh Government, a Minister of the Crown and a government department must have regard to the United Nations Environmental Programme Convention on Biological Diversity of 1992, and (b) any other public authority must have regard to any guidance given to it by the Welsh Ministers.

(5) In complying with subsection (1), a public authority other than a Minister of the

266 As persons holding office under the Crown upon relevant terms: s.6(9)(f)

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Crown or government department must have regard to— (a) the list published under section 7; (b) the state of natural resources report published under section 8; (c) any area statement published under section 11 for an area that includes all or part of an area in relation to which the authority exercises functions. …

(9) In this section— “Minister of the Crown” (“Gweinidog y Goron”) has the same meaning as in the Ministers of the Crown Act 1975 (c. 26); “public authority” (“awdurdod cyhoeddus”) means— (a) the Welsh Ministers; (b) the First Minister for Wales; (c) the Counsel General to the Welsh Government; (d) a Minister of the Crown; (e) a public body (including a government department, a local authority, a local planning authority and a strategic planning panel); (f) a person holding an office— (i) under the Crown, (ii) created or continued in existence by a public general Act of the National Assembly for Wales or of Parliament, or (iii) the remuneration in respect of which is paid out of money provided by the National Assembly for Wales or Parliament; (g) a statutory undertaker.”

441. The references in s.6 to the report under section 8 is to the State of the

Natural Resources Report (“SoNR). This Report was addressed in WG

response to the Final Response of RSPB.

442. The first thing to note about s.6(1) is that it does not create an absolute

duty; the authority is to seek to maintain and enhance biodiversity in the

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exercise of its functions and promote the resilience of ecosystems “so far

as consistent with the proper exercise of those functions”. Subsection (2)

is framed in terms of taking certain matters into account, rather than setting

out any statutory weighting. Of course, these duties must be discharged in

the context of the S.1 purpose, but none of these provisions requires either

a total absence of harm on the one hand or enhancement on the other.

Indeed, the scope of natural resources and the principles of sustainable

management are so broad that it is impossible to conceive of any major

infrastructure project which could achieve positives across all of them.

443. The statutory sustainable management of natural resources concept is

expressly linked to meeting the needs of present and future generations of

people and contributing to the achievement of the FGA’s well-being goals.

444. Account is to be taken of the condition of ecosystems and, logically, this will

form a starting point. Although the line of the new road passes through

SSSIs and designated historic landscape, it also traverses urban areas and

produces indirect impacts upon other areas, specifically the corridor of the

existing M4. As set out above, the SSSIs are in unfavourable condition.

The suggestions by RSPB267 and GWT268 that one should assume

favourable condition as the base-line for assessment are not founded in

law or guidance and are plainly illogical and unscientific. Proper

assessment, design and mitigation must respond to the situation on the

ground and the inspectors/Ministers cannot proceed on the basis of an

assumed reality which does not exist. Whilst the effects of the new road

would be negative in the short term, mitigation in line with principles of

267 ID220 268 See e.g. James Byrne on Ecosystems Services Assessment ID217 paras 54 and 55

C:5493828v1 243

sustainable management of natural resources would reduce many effects

to slight or, at the most, moderate significance in the long term. These are

effects which are agreed with NRW and were assessed in the ES on a

precautionary basis.

445. Mr Jon Davies said269 that, in his opinion the s.4 principles of sustainable

management permit consideration of short, medium and long term

consequences of actions. There is no doubt that WG is seeking to

maintain and enhance biodiversity as it exercises its functions.

446. Turning to consider “natural resources” in the broad statutory sense, the

net effects of the Scheme on air quality are positive. With mitigation, water

quality and quantity in the SSSIs would be maintained. In some cases, they

would be enhanced because currently unmanaged ditches would be

brought under management and the SSSI mitigation areas would offer

opportunities to restore lost reens and ditches and manage grazing marsh

to improve biodiversity, replacing the current, unhelpful agricultural regimes

on that land. Elsewhere, contaminated soils would be treated and utilised

wherever possible in road construction, thus sustainably removing

contamination and avoiding use of other imported and natural materials.

447. Climate features and processes have been taken fully into account, as

explained above. After 2025, M4 CaN would make no difference in respect

of tidal flooding potential. In the short period between implementation and

2025 at the latest, there would be different effects. On balance, they would

be marginally better with than without M4 CaN. In these respects, the

statutory purpose would be served.

269 Cross examined by Mr Byrne

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448. Animals, plants and other organisms in general fall within the definition of

“natural resources” and thus within the statutory purpose. Clearly they also

form the subject matter of the s.6 biodiversity/ecosystems duty.

449. S.7 EWA 2016 provides as follows:

7 Biodiversity lists and duty to take steps to maintain and

enhance biodiversity

(1) The Welsh Ministers must prepare and publish a list of the living

organisms and types of habitat which in their opinion are of principal

importance for the purpose of maintaining and enhancing biodiversity

in relation to Wales.

(2) Before publishing a list under this section the Welsh Ministers must

consult the Natural Resources Body for Wales (“NRW”) as to the living

organisms or types of habitat to be included in the list.

(3) Without prejudice to section 6, the Welsh Ministers must—

(a) take all reasonable steps to maintain and enhance the living

organisms and types of habitat included in any list published under this

section, and

(b) encourage others to take such steps.

(4) The Welsh Ministers must, in consultation with NRW—

(a) keep under review any list published by them under this section,

(b) make such revisions of any such list as appear to them appropriate,

and

(c) publish any list so revised as soon as is reasonably practicable after

revising it.

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(5) In exercising their functions under this section, the Welsh Ministers

must apply the principles of sustainable management of natural

resources.

450. Clearly, there are connections between sections 6 and 7. The legislation

recognises this by imposing the duty in s.7(3), “without prejudice to s.6”.

451. By s.6(5), the Inspectors, additionally, are to have regard to the s.7 list and

the SoNR.

452. Both sections, however, are qualified. The s.6(1) is a duty to “seek” to

maintain and enhance biodiversity, “so far as consistent with the proper

exercise of … [its].. functions.” The s.7 duty is to take “all reasonable

steps”. These statutory qualifications are important. They mean that

causing a negative effect to biodiversity or to a s.7 species or habitat is not,

in itself, a breach of statute. What the law requires is consideration of the

protected elements and a conscientious effort, taking all reasonable steps,

to seek to maintain and enhance them while exercising the functions of, in

this case, the national Government and Highways Authority.

453. For reasons set out above, it is clear that these duties have been

discharged with regard to the Levels SSSI ecosystems.

454. A particular feature of the evidence before the inquiry has been the

comprehensive, systematic assessment of the effects of the Scheme upon

ecosystems. The ESA was undertaken in response to a number of

objections made by GWT and CPRW. Whilst it is not a requirement of

statute or Weltag to carry out such an exercise, the ESA was undertaken

and reported to the Inquiry to assist the Inspectors in evaluating the

Scheme’s effects upon ecosystems and the services they provide. This

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piece of work can assist in assessing claims by objectors that the Scheme

conflicts with the FGA 2015 and EWA 2016 and/or that WG has not

complied with its duties under that legislation. In particular, as set out

above, s.3(2) EWA 2016 defines the central statutory concept of

“sustainable management of natural resources” in terms of promotion to

achievement of the objective “to maintain and enhance the resilience of

ecosystems and the benefits they provide ...”, in line with the sustainable

development principle. S.4 EWA 2016, in setting out the “principles of

sustainable management of natural resources” includes: “take account of

the benefits and intrinsic value of natural resources and ecosystems”; “take

account of the resilience of ecosystems ...” (emphasis added); and many

other principles involving the use or collation of evidence and taking

account of short medium and long term consequences of actions.

455. The ESA stands alongside the long established assessment tools and

processes comprised in EIA, SIAA and Weltag, as well as the professional

evidence of expert witnesses. By considering net impacts and values over

a 100 year period, the ESA contributes to the assessment of long term

consequences in a robust way.

456. It is important to bear in mind, when considering the ESA and the criticisms

levelled at it by GWT, that such an assessment is not a requirement of

statute, policy or practice. It is quite a new appraisal technique and there is

no set methodology. The ESA for M4CaN comprises both a quantitative,

monetised assessment, where feasible, and a qualitative assessment. All

agreed that it is not possible to place a monetary value on all the elements

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in question. That is why the ESA must be considered in parallel with the

other environmental and economic assessments referred to above.

457. The ESA identifies and describes the services provided by the four

ecosystem habitat types that would be affected by the scheme – the Gwent

Levels SSSIs, farmland and woodland outside the SSSI and Brownfield

land within Newport Docks and Tata Steelworks. Then it assesses the

change in provision with the scheme.

458. The ESA shows that the total area of land within the SSSIs affected by the

Scheme would be 212.31 ha; this includes 76.4 ha at Tatton and Maerdy

Farms, two of the three SSSI Mitigation Areas, plus a further 30.21 ha for

mitigation planting. The actual permanent loss would be the 85.66 ha within

the footprint of the new section of motorway. The total area provided in

mitigation, including land reinstated, enhanced and provided as SSSI

mitigation, would amount to 169.6 ha. There would hence be a net increase

of 41.87 ha of land performing SSSI functions.

459. In the Farmland habitat outside the SSSIs, 257.16 ha would be affected,

which includes 55.24 ha at Caldicot Moor, the third SSSI Mitigation Area.

Whilst all the land temporarily affected would be restored to its previous

use, 139.6 ha of arable and other farmland would be lost due to the land

take for the Scheme (82.74 ha) and mitigation planting (56.86 ha); those

areas of arable and improved grassland due to be ‘de-intensified’ (such as

Caldicot Moor) would remain as farmland. The Report points out that

should the Scheme proceed there would be a net loss in ecosystem

services associated with food production. However, there would be benefits

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to biodiversity from the species-rich grassland and woodland provided in

the landscaped areas and the Caldicot Moor SSSI Mitigation Area; 26.1 ha

of additional species-rich grassland would be created. Other benefits would

include food for insects on the species-rich grassland; improved water

quality through reduction in pesticides and fertiliser; and benefits to human

health and well-being through increased access to woodland areas.

460. In the Woodland habitat outside the SSSIs, 56.99 ha would be affected.

The main adverse impacts would be the loss of a relatively small area of

1.04 ha of ancient woodland at Berryhill Farm and the time lag to recreate

woodland habitat. There would also be an impact on soil and some

decrease in carbon sequestration. However, this would be offset in the

longer term by the replacement of woodland at a rate of 2:1; the actual loss

would be 49.35 ha with 119.73 ha provided, including shelter belts, scrub

and replanted woodland. Replacement woodland would provide greater

opportunities for outdoor recreation and education. Clearly ancient

woodland cannot be replaced but the amount lost would be small and the

amount of replacement woodland and the management proposals at Coed

Mawr would in the longer term benefit biodiversity.

461. With regard to the fourth habitat type, Brownfield land, 168.52 ha would be

affected. The main adverse impact would be loss of biodiversity since these

areas are of nature conservation value due to the presence of

invertebrates, reptiles and birds; there would be a net loss of 63.17 ha.

There would also be a minor loss of heritage value due to the demolition of

industrial buildings at Newport Docks. These impacts would be balanced to

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an extent by the provision of species-rich grassland, which would exceed

the loss of flower-rich habitat, and by the slight improvement in human

health following the remediation of contaminated land, especially at Tata

Steel.270

462. Monetising existing and projected services where possible, the ESA

estimates the value of ecosystems services lost at just over £6.02m

(discounted and capitalised over a 100 year period) and, on the same

basis, estimates total benefits to be provided by mitigation areas at £7.73m.

The same monetary values were applied for losses and benefits, therefore

the net change is independent of the monetary values used. These figures

were also put forward with a proper degree of caution, unlike Mr Byrne’s

£67m figure for the entire Gwent Levels which was unexplained. Whilst the

resultant net figure of £1.71m over 100 years would make no difference if

applied to the BCR, this exercise in quantitative and qualitative appraisal

usefully demonstrates that the M4CaN project, taken in the round, is not

the environmental disaster which GWT and certain other objectors have

claimed, rather, it will, over time, make positive contributions to ecosystems

services. The findings of the ESA should also be taken into account also

when considering the FGC’s representations and her latest evidence to

Senedd on the application of the FGA 2015.

463. GWT’s Prof Maltby and Mr Byrne made a number of detailed criticisms of

methodology, but did not conduct their own assessment or come up with

alternative, transparently justified monetary figures. Prof Maltby was not

called to give evidence and Mr Byrne, though present at the relevant

270 WG 1.23.7 paragraphs 3.60 – 3.62

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inquiry session, elected not to give evidence. Counsel’s cross-examination

point comparing Prof Maltby’s expertise with that of Mr Jon Davies was

therefore somewhat hollow. Mr Davies did make himself available for

cross-examination and was not flawed on any point. His evidence, for all

these reasons, should be given more weight than GWT’s. As he made

clear, he had worked on the ESA alongside members of his company who

are qualified and experienced in environmental economics and, specifically,

the evaluation of ecosystem services.

464. GWT’s late retorts271 to Mr Jon Davies’ oral evidence should also be

treated with caution for all the reasons stated above. Moreover, read

carefully, it is clear that they are contingent or caveated: specifically, Prof

Maltby states, (not having heard Mr Jon Davies give evidence) that he

“stands by” his opinion that the use of benefits transfer “may” be “quite”

unsafe. Neither he nor Prof Morris responds to Mr Jon Davies’ evidence of

being unable to find any project ESA which does anything else. The

highest Prof Morris is prepared to put the point is that:

"a judgment needs to be made whether the potential impacts of road development through the Gwent Levels are such that a site specific assessment is deemed appropriate.”

465. The M4CaN ESA team has made that judgment. Mr Jon Davies was

cross-examined on it and amply justified the approach. Prof Morris does

not hazard his own opinion, unsurprisingly, since he clearly has nothing like

Mr Davies’ understanding of the Scheme, only just having been asked to

271 GWT comments on WG’s Rebuttal of Prof Maltby and James Byrne Evidence, 23.03.18.

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comment, without hearing any of the evidence on this or other matters. All

the rest of his comments, including those concerning archaeology, are

similarly inconclusive.

466. The particular points which appear, from the GWT “Comments” document,

to be in contention relate to:

(i) the value of coastal and floodplain grazing marsh – but the

“Comments” fail to engage with Mr Jon Davies’ evidence to the

effect that the ESA took a precautionary approach in two ways:

firstly, by valuing all the relevant land as coastal wetlands, which

attract a higher monetised value than inland wetlands,

notwithstanding that the Gwent Levels are more inland in

character; secondly, by attributing the full value to all the SSI

areas to be lost, despite the well documented problems caused

by modern farming of the grass, meaning that biodiversity value

is principally located in the reens and ditches, themselves

subject to eutrophication due to the agricultural “improvements”

to the fields.

(ii) Ramsar Convention – it is accepted that the Convention applies

generally in relation to wetlands including the Gwent Levels; the

fundamental issue between the parties on this point is GWT’s

refusal to recognise the deliverability or value of WG’s proposed

mitigation, a point which has been considered above and which

Mr Jon Davies, once more, convincingly dealt with in cross-

examination at the ESA session.

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Bats

467. As noted above, these are the only species in respect of which NRW have

an unresolved objection. It is based on the impacts associated with

severance – fragmentation of habitats and increased mortality through

collisions, leading to a reduction in bat abundance and species diversity in

the vicinity of the Scheme (as summarised in Counsel’s Closing). NRW

submitted written evidence, but did not call a witness on this issue. Hence,

as Mr Wald added, the case set out in writing “has not narrowed during the

course of the inquiry”. This is unfortunate because, as he recognised, WG

have provided further information during the inquiry, particularly a Bat

Mitigation Strategy (“BMS”), which has, itself, been improved272. We do not

rehearse its contents here, but it is a detailed document and should be

referred to when considering this review of NRW’s and GWT’s contentions.

468. Notwithstanding the terms of NRW’s original objection,273 it is now agreed

that the ES did conclude that the landtake would have significant effects in

the short and medium term, construction would have significant effects in

the short and medium term and that there would be long term effects as a

result of the operation of the Scheme.274

469. The SOCG further records agreement:

i. that baseline data is sufficient for the purpose of EIA;

272 Latest version is ID/56a 273 “unable to agree with the conclusions of the March 2016 ES that adverse effects on the ... bats ... can be avoided.” 274 ID/104, Bats SOCG, p.2, para 1.1.15

C:5493828v1 253

ii. that further bat surveys would be required for a

licence application under Part 6 of the 2017

Regulations;

iii. that the draft BMS275 takes account to NRW’s

comments and would, informed by further surveys

prior to the licence application, support that

application;

iv. there is no objection to the Listed Building application

on the basis of bats because adequate mitigation

could be provided;

v. the only licensing requirement for the Scheme and for

the listed building would be in respect of bat roosts;

vi. based on the information provided in the draft BMS,

NRW does not hold the view that the grant of a

licence in respect of bat roosts would be unlikely;

vii. all reasonable steps to mitigate effects have been

taken;

viii. because of the need to keep the road low in the

landscape and minimise SSSI landtake, not all

adverse effects can be prevented and residual

severance effects will remain, assessed as being of

275 ID/56

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moderate adverse significance in the long term, during

operation.

470. Pausing there, it is clear that the inspectors can advise Ministers that there

is agreement about survey effort, assessment of impacts and that all

reasonable steps have been taken to mitigate impacts. All that remains in

issue with NRW is their judgment that the significance of residual impacts

properly founds an objection to the Scheme. Because no bat witness was

called, it was impossible to explore this issue of judgment and weighting.

471. In the light of ss.6 and 7 EWA 2016, the admission that all reasonable

mitigation measures have been taken is highly significant. If the inspectors

accept WG’s case on need and the absence of reasonable alternatives,

then impacts upon bats are inevitable. It was clear from Ms Poole’s

answers to general cross-examination questions about balancing different

considerations that NRW had not attempted to do this. They have not

challenged the need for the road and, in respect of bats, as with all other

European protected species, would deal with a licence application on the

basis of the inspectors’ and Welsh Ministers’ findings on overriding public

interest (“IROPI”) should the Scheme be confirmed.

472. GWT’s Closing Submissions go to great lengths to demonstrate, with

regard to bats (as with other species and habitats) that WG witnesses did

not claim 100% certainty with regard to mitigation proposals. The claimed

cross-examination victories on these points were not the achievements

they were painted to be, because none of the GWT ecologists, including Mr

Green, has claimed such a potential success rate. (As a generality, GWT’s

summary of the evidence should be treated cautiously; for example, in

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some instances, the proposition put by counsel or Mr Byrne to a witness is

given, rather than the actual answer.) For reasons set out above and in

Annex 3, that does not mean, however, that mitigation should be

disregarded. Moreover, as well as GWT’s interpretation of the law relating

to European species licensing is wrong for the reasons detailed in Annex 3,

the attempt in Closing to extend that principle to species which are

protected in domestic legislation alone is one misconception further and

was not the basis of Mr Streeten’s legal submissions made at the Bats

session. His point is based on European caselaw on the Directive

underlying the 2017 Regulations. He did not attempt to extend the point to

the other species / topics with which he dealt (water vole, invertebrates and

general SSSI cross examination). The Closing elides his European point by

apparently drawing it into general submissions about mitigation.

473. Returning to bats, Prof Altringham undertook a critique of WG’s proposed

mitigation measures and initially sought to argue that such measures

should be disregarded on the basis of the Waddenzee276 case unless there

could be 100% confidence at the licensing stage that mitigation measures

would be effective to ensure no adverse impacts on bats at all, and, in

particular, that level of confidence in their ability to use the proposed

culverts.

474. The conventional approach, adopted and confirmed by NRW as their

position in the Bats SOCG, is that they would only require a licence in

respect of disturbance of bat roosts/breeding sites,277 and not in relation to

impacts from land take and operational effects; this is important because of

276 C-127/02 277 As Mr Green explained, this would comprise 8 buildings and 6 trees which have been revealed by the surveys to contain roosts.

C:5493828v1 256

the admitted effects from the latter two causes, not all of which can be

mitigated, as the ES and Mr Green’s evidence accepted. On the other

hand, as we shall see, Mr Green has full confidence in the tried and tested

methods of mitigation for roost disturbance. (That is not to say that he lacks

confidence in the culverts, but he accepted that there is some uncertainty

about their effectiveness and therefore adopted a precautionary

assumption about them and associated mitigation measures, such as

landscaping).

475. Under cross-examination, Prof Altringham downgraded his required

standard of confidence from absolute certainty to “the balance of

probabilities, based on and informed by evidence”. He described his

contention that the Waddenzee principle, which applies to Appropriate

Assessments under Part 3 of the 2017 Regulations, should be extended to

cover Protected Species licensing under Part 6 as “simply his personal

opinion”. So GWT’s point was not, in fact, supported by its witness.

476. Nevertheless, the Legal Note at Annex 3 to these submissions explores

this contention in detail and explains why it is wrong. In short, the

Waddenzee principle applies to different functions under the Directive /

Regulations, not species licensing. Mr Green stated that, in over 100

licence applications, he has never encountered either NRW or Natural

England applying the Waddenzee principle; rather, as set out in the

Commission and Natural England’s guidance, the approach is to seek a

proportionate evidence base, having regard to the particular species and

circumstances. The SOCG supports WG’s position, because NRW there

state that licensing would be limited to roosts and they do not claim that

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such an application would be determined on the Waddenzee standard of

proof.

477. The scope of the licence matters because it was, apparently, agreed by the

Professor that mitigating for roost loss by means of bat boxes and barns is

a tried and tested approach. Mr Green’s opinion, which was not

challenged, was that there would be no adverse effect on favourable

conservation status on the basis of roost disturbance because of the

proposed reprovision. We say “apparently” because Prof Altringham,

unlike Mr Green, had no practical experience of applying for licences or

implementing mitigation for road schemes. Mr Green was able to point to

successful examples of bat mitigation by means of bat barns and culverts

on road schemes elsewhere, most locally on the Heads of the Valleys 2

Scheme but also the Porthmadog Bypass.278

478. There was much discussion of Prof Altringham’s earlier studies showing a

decline in bat activity 1-1.6km either side of the M6 in Cumbria. When

considering how much weight to give these, it is important to bear in mind

the locational and environmental distinctions. The principal areas of

recorded bat activity along the M4CaN route are much closer to human

populations and urban activity, including roads, than the M6 in Cumbria. In

any event, the discussion perhaps generated more heat than light, because

the ES and Mr Green had taken a precautionary approach in their

assessment of land take and operational impacts. Despite “all reasonable

steps”279 having been taken in terms of proposed culverts and associated

features, he had not relied on them when assessing impacts. The ES took

278 PID51

279 As agreed with NRW in the SOCG

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a precautionary approach, based, amongst other things, on Prof

Altringham’s work which had not been ignored, as he claimed.280 Although

his assessment took this approach, Mr Green was able to draw on his and

others’ experience to show the ability of such measures to operate well.

The Professor was disinclined to rely on anything other than academic

research studies, but Mr Green’s experiences are also relevant and should

be given weight, especially given his extensive practical experience.

Moreover, Prof Altringham agreed that, if the Scheme were to go ahead, he

would rather that the measures were included and even said that they

could add to the body of research in due course.

479. In conclusion, there is no legal impediment to confirmation of the Scheme

on the basis of bat impacts. Residual effects should be judged on the basis

of all the evidence and weighed in the balance. The licensing regime

recognises that, even in the case of relevant disturbances to European

protected species, IROPI can justify some interference on the basis of the

needs of human society. Here, the need is pressing and WG proposes to

take all reasonable steps to mitigate effects upon bats.

Dormouse

480. As noted above, in connection with the licensing of European Protected

Species, NRW withdrew their objection to the Scheme on the basis of

impacts upon dormouse following extensive work on a draft Mitigation

280 CD 2.3.2 ES p.336, para. 10.9.282; p.337 para 10.9.288

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Strategy. The details are to be found in the Dormouse SOCG281 and the

draft Strategy itself.

481. GWT called no evidence on dormouse, but, following NRW’s withdrawal,

Mr Byrne sought, and was granted, permission to cross-examine Mr Jon

Davies. He concentrated on trying to demonstrate, in spite of NRW’s

exhaustive process of scrutiny, that the Strategy would not work. Mr

Davies made it clear – as, indeed, is evident from the history of this matter

set out in the agreed documents – that NRW had required a high level of

confidence, having regard to the high level of legal protection which the

dormouse enjoys and its conservation status. Not only had WG and NRW

addressed themselves to the maintenance test in Reg.55 of the 2017

Regulations, but they had also worked with the aim of enhancement,

pursuant to Part 1 of EWA 2016. Although dormouse is a European

Protected species, GWT’s Closing argues for an excessively rigid approach

to mitigation, for reasons set out in Annex 3. Having said that, WG’s draft

Mitigation Strategy, viewed objectively, gives a very high level of

confidence that favourable conservation status would be maintained.

482. In response to Mr Byrne’s general point about the effect of roads on

wildlife,282 Mr Davies was not “dismissive”, as GWT’s Closing dramatically

suggests, rather, he pointed to the manifest evidence that the relevant

population is already living within 5kms of the existing M4; he had survey

evidence, as opposed to a generalised academic paper, to back up what

he said – i.e. better evidence. Bridge Crossings were not considered

necessary by him or NRW because of the populations either side of the

281 ID154. 282 Moreno-Mateos – GWT Closing p.25 which does not fairly summarise Mr Davies’ answers on this point.

C:5493828v1 260

road would be greater after all the habitat enhancement work proposed.

This new habitat would be created with dormice in mind, unlike the 1970s

roadside landscaping which they have, in any event, colonised. Mr Davies

pointed to his experience of translocation success on the A2/M2 Scheme –

more specific evidence as opposed to generalised academic publications.

483. Mr Davies also confirmed his confidence and optimism with regard to the

Coed Mawr proposals. He rated the chance of success at 95%283 and

gave his reasons based on a thorough research of Coed Mawr and his

experience elsewhere. He was clear that the effect would be “to turn Coed

Mawr into 90ha of thriving dormouse habitat for expansion of the

population.”

Invertebrates

484. GWT instructed Mr Boyce to produce an assessment of the impacts of the

Scheme.284 That is not actually what he did; rather, he produced a critique

of the ES and September 2016 ESS and supporting surveys. He was

unsure whether he had looked at the appendices to the ES/ESS and had

not read the 2015 Desk Study or the Scoping Report, which Mr Jon Davies

had agreed with NRW. He had undertaken no surveys or analysis of his

own. Critically, given that he was commenting on water, as well as land-

based invertebrates, he said that he had made no assumptions on water

quality. Apparently he had “raised concerns” with GWT about this, but was

quite unclear about the basis of his critique; however, he accepted in cross-

283 GWT’s Closing (p.29, headline point) completely misstates the evidence actually given. No bridge is proposed and tunnels are not relied on for mitigation because WG and NRW agree that they are not required. Mr Davies had high confidence levels in the Mitigation Strategy. 284 Cross examination (ME QC)

C:5493828v1 261

examination that, if the inspectors agreed with WG and NRW about water

quality, that would “take care of lots of his concerns about aquatic

invertebrates”. This collection of points must reduce the weight to give to

this witness’s evidence, in addition to the facts that NRW:

i. scoped WG’s work;

ii. take no point on survey effort;

iii. take no point with regard to the conclusions of the ES and

do not object on the basis of invertebrates;

iv. are satisfied that the Scheme design has made proper

provision to secure water quality in the reens and ditches.

485. It was agreed that adequacy of survey effort and methodology are matters

of professional judgment. Mr Jon Davies (who has particular expertise in

invertebrates285) considered the level of effort and consequent attention to

invertebrates in the ES to be good. And, as we know, NRW have no

concerns in these respects. The details are summarised in WG’s Rebuttals

and the base documents are in the ES and ESS.

486. Mr Boyce also disagreed with NRW’s judgment that 1:1 replacement of

reens and ditches is the appropriate ratio. (In fact, the SSSI mitigation

areas do offer the opportunity for a little more).

487. The ES assumes that all reens and ditches are capable of supporting the

full assemblage of SSSI features. Mr Boyce accepted that this was a

generous assumption, in view of the evidence of unfavourable condition.

His own surveys of the Levels were referred to in the ES and factored into

285 He explained his role in working on the latest CIEEM guidance

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judgments, surveys which, he said at the time, were somewhat

disappointing for SSSIs. Therefore there was absolutely no basis for

criticising the EIA or suggesting that it was based on inadequate

information.

488. Whilst Mr Boyce’s main attack was on survey effort, he also made some

points about mitigation. His main concern was the alleged lack of

information. Whilst recognising that mitigation had been put forward,

especially by means of flower rich meadows in the SSSI mitigation areas,

which would be of value to shrill carder bee, he criticised lack of detail and

lack of mitigation for severance. Buglife and RSPB make similar points.

Clearly there would be some severance but Mr Boyce agreed286:

i. that some bees would successfully cross the road;

ii. that there would be less need to cross with mitigation in

place at the three SSSI mitigation sites and on the southern

embankments of the new road; and

iii. that land to the south would be unaffected, while much of

the SSSI land to the north was either already developed or

would be occupied by SSSI mitigation land.

489. WG has made a commitment287 to produce a Bumblebee Mitigation and

Protection Plan in consultation with the Bumblebee Conservation Trust and

RSPB. WG’s response to RSPB’s final submission explains the proposal

to work up detail for this Plan which was submitted in draft by those bodies.

286 In cross examination (ME QC) and (c) in answer to Inspector Wadrup. 287 Commitment 213

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Monitoring, which was a specific point raised by Mr Boyce, will be scoped

and agreed ahead of the survey season. WG has confirmed its willingness

to do further surveys.

490. Contrary to the submissions of Buglife288 and GWT in their Closing, it is not

the case that EWA 2016 or FGA 2015 requires full mitigation for every

impact upon biodiversity or listed species.

Birds

491. Wintering and breeding birds are the subject of a SOCG between WG and

NRW.289 Baseline data are agreed to be sufficient for EIA purposes and the

ES assessment is agreed.

492. Since drafting that SOCG, matters have moved on by reason of the

publication and consideration by NRW of ESS5 (August 2017) and

Addendum to the SIAA. They responded by letters dated 26 September

2017,290 6 December291 and 19th March 2017.292 The latter letters concern

otters, but it is quite clear that NRW have no objection to the Scheme or the

proposed Docks Works on EIA, SIAA or species licensing grounds.

493. RSPB has made a number of written representations. WG’s responses are

also listed:

RSPB Written Submissions Rebuttal WG/REB/OBJ0030-RSPB 7.02.2017 – (September 2017)

RSPB/GWT “Legal” Letter to Ken Legal Submissions above on Skates 26.05.2017293 -

288 ID/126 289 ID/105 Protected Species SOCG p.6 290 ID/130 291 ID/164 292 ID/236 293 ID/088

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interpretation of FGA 2015 and EWA

2016. WG’s interpretation and

application of the legislation has also

been the subject of evidence from Mr

Jon Davies MBE in his original and

final proofs,294 which he has delivered

publicly and upon which he has been

cross-examined, including on behalf

of GWT, with whom RSPB wrote their

letter to the Minister.

Letter from Director RSPB Cymru to Draft Bird Protection and Mitigation Ken Skates 31.08.2017295 - Plan (“BPMP”)296 and Commitment

193 presented to the inquiry on 27th

March 2018 in the presence of RSPB

representatives, who had the chance

to put questions.

– ID/243 - Modifications to proposed

orders to provide a new breeding and

rearing area for a pair of canes.

Final Submission for RSPB, WG Response. RSPB submission 20.03.2018 - OBJ 0030-ID/250

294 WG 1.23.1 and 1.23.7 295 ID/111 296 PID/187A

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494. Behind this suite of written exchanges, there lies a great deal of

engagement between Drs Zisman and Ireland and representatives of

RSPB and NRW to develop the draft BPMP. WG acknowledges that this

activity has been without prejudice to RSPB’s objection to the Scheme and

is grateful for their very proper approach. In WG’s submission, whilst the

Scheme and the Docks Works would have effects upon birds, these are

justified by the need for the Scheme and relevant environmental legislative

duties have been met by working up a detailed suite of mitigation

measures.

495. We shall not rehearse details here, partly because all the material is before

the inquiry and Dr Zisman has clarified where necessary. The inquiry has

also adopted an appropriately restrained approach to public discussion of

cranes. The key points are:

i. two potential breeding areas are proposed; one (“X”) is in NRW

ownership and control and can be prepared in advance of works

commencing in the vicinity of the current next; the other (“Y”) is close

to the existing nest area; both areas can be prepared with nesting

platforms and “early days” foraging areas for newly hatched chicks;

ii. NRW raise no objection on bird, or specifically, crane grounds;

iii. Area Y will also be able to provide useful habitat for shrill carder bee

and dormouse;

iv. There is scope for NRW, using its powers under s.16 EWA 2016, to

enter into management agreements to manage nearby fields in a

condition which would provide habitat for slightly older chicks;

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v. The point which has been raised about the solar farm NSIP proposal

is dealt with in WG’s final response to RSPB; information has been

shared on a confidential basis with the ecologists for that project and

effects upon crane will be taken into account in their cumulative

assessment; this will, of course, be subject to independent public

examination under the Planning Act 2008.

496. Mr Hepworth, on behalf of CPRW, responded to the draft BPMP.297 He

pointed out that there is no guarantee that the cranes would relocate as

proposed. He also stated that common crane is covered by the Convention

on the Conservation of Migratory Species (“CMS”) and an associated

Agreement on the Conservation of African-Eurasian Migratory Waterbirds

(“AEWA”).

497. A full response was made to these points in ID / 245. Mr Hepworth simply

re-iterated his points in his final response.

498. It is important to recognise that neither the terms of the Convention nor the

Agreement impose absolute obligations. WG reject the suggestion that it

would be unlawful to confirm the Scheme on its current line. As Mr John

Davies MBE explains, the principle of proportionality, which the Convention

espouses, entails looking at matters in the round. In this case, there are

good reasons, including environmental ones, for using developed,

brownfield land in preference to greenfield land, albeit within the SSSI.

Moreover, WG has gone to great lengths, in collaboration with NRW and

RSPB, to provide alternative areas of habitat. These are secured through

297 PID 245. Addendum to Further Evidence submitted by CPRW to the M4 Public Inquiry, 1.03.2018.

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the relevant Side Road and CPO Modifications298 and Commitments 138,

193, 204, 205, 114. The response is proportionate to the

Convention/Agreement obligations and the duties in EWA 2016.

499. Gwent Ornithological Society (“GOS”) objected in writing on general

grounds. They raised a supplementary point on 27.02.2018,299 concerning

the effects of rooftop nesting on lesser blacked back gulls and herring gulls.

WG responded in writing300 explaining how the surveys referred to by GOS

were consistent with and corroborated those of WG. In compliance with

duties under Part 1 EWA 2016, nesting needs would be taken into account

when designing Docks buildings for prior approval. Both NCC (as a local

authority) and APP (as a statutory undertaker) are under these duties.

Otters

500. The starting points are the Protected Species and the internationally

Designated Sites SOCGs.301 NRW agree with WG that the baseline survey

data is sufficient for EIA and SIAA purposes. The latter document

specifically records the precautionary approach adopted to the question of

whether otters associated with the R. Usk SAC could utilise a limited part of

Gwent Levels that would be affected by the Scheme. Having regard to the

small number of such otters, NRW agree that adverse effects on the

integrity of the River Usk SAC with respect to European otter features are

not predicted to occur as a result of the construction or operation of the

Scheme.302303 This SOCG was signed on 23.03.2018. They also indicate

298 To which all relevant parties consent: ID/243 299 WG-REB – OBJ0297 300 ID211 and ID211 Rev A 301 ID/105 302 ID/251

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that there is no evidence to suggest that a Habitats Regulation licence

would be necessary. They have never required preparation of a mitigation

plan.

501. NRW have also carefully considered ESS5 (August 2017) and

accompanying SIAA. These relate to proposed works in the Docks.

Initially304 NRW indicated a likely holding objection in relation to Otter.

Following discussions about the process, they confirmed by letter dated

18.03.2018 that they were not raising a holding objection. In this letter they

explained that, since no requirement for a licence had been identified,

NRW’s primary role would relate to European Sites and they were satisfied,

therefore, that appropriate mechanisms would be in place to ensure the

integrity of the SAC.

502. It is important to note the dates of the International Sites SOCG and Docks

correspondence given the nature of GWT’s objection in relation to otter.

Because of NRW’s stance, GWT had to mount an attack on their

conclusions with regard to adequacy of baseline information and scientific

certainty regarding the lack of effect of the Scheme upon the integrity of the

SAC. NRW will have been aware of their evidence, which was provided in

writing and orally by Mr Liles. Notwithstanding his views, NRW confirmed

their position in the recently signed International Sites SOCG and, after

very careful consideration, also in relation to the Docks. GWT, via the

written submissions of Lindi Rich,305 reiterated Mr Liles’ points about survey

effort and lack of information to inform a mitigation strategy / lack of a

strategy.

303 para 2.1.25 304 PID 164 305 PID 236

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503. Adequacy / methods of survey are, as Mr Liles agreed, matters of

professional judgment. Despite much criticism of the WG team, the fact is

that NRW have reviewed the work and are satisfied with it. GWT had not

commissioned him to undertake any surveys and he was unable to point to

evidence of any active sites – whether breeding or resting sites. Mr Jon

Davies considered that this absence was due to the relative unsuitability of

the Levels for such purposes, as opposed to the wealth of habitat further

north in the River Usk SAC. Subsequent survey of the Docks produced no

such evidence either, hence NRW’s opinion that Habitats Regulation

licensing would be unnecessary.

504. WG’s assessments have, however, assumed, on a precautionary basis,

that the whole of the route would be in use by otters travelling through the

area. The EMPs include otter fencing along the route and culverts beneath

it. Mr Davies – and NRW – consider this adequate mitigation for now and,

at detailed design stage, a mitigation strategy will be prepared. Mr Liles

regarded precise positioning of culverts as critical, but said in cross-

examination that he was not suggesting that the road should not go ahead.

This was an important answer and one which was, of course, conveniently

forgotten in GWT’s Closing, which does seek this result, on the basis of

Otter interests along with many others.

505. Mr Liles’ SIAA point was supported by a document prepared by research

students at Cardiff University. This report was submitted just before the

hearing date, although dated earlier. In the circumstances, WG provided a

considered response in writing.306 That response comprehensively rebuts

306 ID/106

C:5493828v1 270

the adequacy and relevance of the Cardiff Study. In particular, it should be

noted that Mr Liles stated in cross-examination that the authors had not

been given any information concerning mitigation for the Scheme. This

was obviously a fundamental omission since his case rested on an

assertion that mitigation was inadequate.

Water Vole (“WV”)

505A. WV is dealt with in the Protected Species SOCG between WG and NRW.307

Baseline data and assessment of effects are agreed. Commitment 140

deals with a proposed WV Mitigation Strategy, to be informed by further

surveys. NRW are satisfied that their requirements can be met in the

Strategy. Subject to the Strategy being fully implemented, NRW are

satisfied that her should be no adverse effects on the species.

505B. GWT led no evidence on WV. Nevertheless, as with Dormouse, they were

permitted to cross-examine Mr Jonathan Davies on his proof.308 Mr

Streeten’s questions sought to establish that WG’s survey effort had been

insufficient to found its assessment of effects or Mitigation Strategy.

505C. Mr Davies justified WG’s position very clearly. The population was

surveyed 500m either side of the route and assessed as being of County

value. The ecology team had a good and sufficient idea of where the

animals were likely to be and would take proper account of them in reen

mitigation and ditch creation in the SSSI mitigation areas. Contrary to the

307 ID/105 308 WG 1.19.1 Sections 3.1, 4.1, 5.2

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suggestion in GWT’s Closing, Mr Davies did not say that he was relying on

lengthy culverts as mitigation. Genetic exchange would, in his view, occur

and fragmentation was not an issue. GWT had no evidence to rebut his

opinions or, indeed, those of NRW. Here again, the Closing seeks to

impose a higher standard of mitigation than the law requires.

CONCLUSION

506. No doubt to the relief of many, we have come to the end. Despite the

length of this speech we have not tried to cover every point. We rely upon

the detailed and careful evidence of the WG project team in its entirety. We

have, however, tried to cover all of the fundamental issues and

controversies so as to assist the inspectors, as best we can, in the task

which confronts them.

507. We were informed during the course of this Inquiry that human beings

dislike cognitive effort and like to rely upon rules of thumb to guide their

actions. Avoidance of cognitive effort is not a luxury open to those in

government, nor to those charged with presiding over public local inquiries.

Some who have attended this inquiry have fallen into the trap of relying on

rules of thumb rather than examining the detail of what is proposed. That

new roads lead to more carbon emissions is, by and large, a reliable rule of

thumb. But it doesn’t hold true in this case. That new roads lead to new

traffic which re-introduces congestion and causes noise, air quality and

carbon impacts can also be true in certain circumstances. It is for that

reason that government guidance mandates that significant roads should

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be modelled so as to take account of induced traffic and so that noise, air

quality and carbon impacts can be ascertained. That has been done in this

case, showing that the Scheme will not be self-defeating, will not have

unacceptable environmental impacts and will become carbon neutral.

508. There is a consensus that the status quo is not sustainable, a recognition

that the recurrent congestion and incidents which blight the M4 around

Newport is also a blight on the economy of Wales and the aspirations of

her people. All conceivable alternatives were assessed during the M4 CEM

process. The conclusion reached was that there was no solution without

creating additional road capacity. That capacity has to be adequate for the

long term and has to provide good value for money. The Blue Route, which

is the only comprehensive alternative to the Scheme, fails miserably on

both counts. It may retain support amongst those who have not ascertained

the true factual position or objectively considered the evidence. But it has

comprehensively failed to survive the attention and scrutiny which it has

properly received within the Inquiry. WG is committed to public transport

and active travel. But those alone cannot meet the demand for long

distance travel along this corridor. The commitment to public transport and

active travel is not simply legislative; Metro is being implemented and the

choice between Metro and the Scheme posited by some objectors is a

false choice. Wales needs both.

509. WG does not pretend, of course, that building a new road across a valuable

and sensitive landscape does not have its disadvantages; there would be

admitted negative environmental impacts. But this is not the whole

environmental story and it should not obscure what has been achieved by

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collaborative and sustainable ways of working. Given the constraints and

sensitivities of the locality, environmentalists have been involved in design

from the outset and with some innovative thinking have shown that it is

possible to create environmental benefits and gains. WG have worked

collaboratively with other bodies. The Design Commission for Wales have

reviewed and praised the design of the road. Collaborative working has

identified a way of salvaging the listed building. Ecological mitigation has

been devised in discussion with NRW, the People’s Trust for Endangered

Species and RSPB. The team have talked to individuals whose land would

be affected by the Scheme to identify ways of reducing impacts, solving

problems. The real advantages of the mitigation measures incorporated

into the scheme should not be dismissed by reference to rules of thumb.

510. Cyfeiliornus yw’r portread o’r Cynllun hwn fel un anghynaladwy. Mae gan y

Cynllun lawer i’w gynnig i Gymru o ran yr economi, diwylliant, yr

amgylchedd a materion cymdeithasol. Ffordd yw hon sy’n abl i gysylltu prif

ddinasoedd, rhwydwaith gyfoes i ddatrys problemau’r presennol ac i liniaru

ar flynyddoedd mawr o rwystredigaeth yn sgil tagfeydd y twneli Bryn Glas.

511. Yn amlwg mae angen ffordd newydd ar Gymru i oresgyn y problemau

dybryd sy’n llethu’r rhwydwaith o gwmpas Casnewydd. Y Cynllun hwn yw’r

opsiwn gorau. Gofynnwn i chi i’w gymeradwyo i Weinidogion Cymru.

Rydym hefyd yn gwahodd Mr McCooey i argymell i Weinidogion Cymru y

dylid rhoi caniatad adeilad rhwystredig ar gyfer ficerdy Magwyr.

512. It is simply not true to characterise the Scheme as unsustainable. It has so

much to offer the nation in its economic, social, cultural and environmental

life – a resilient road fit to connect capital cities, smart twenty first century

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infrastructure to solve the environmental problems, frustrations and

dangers caused by years of “patch and mend”, at last, an artery freed from

the tourniquet of the Bryn Glas tunnels.

513. It is clear that Wales needs a new road to address the problems on the M4

around Newport and this Scheme is the best option. We invite the

inspectors to commend it to the Welsh Ministers. We also invite Mr

McCooey to recommend the Welsh Ministers to grant LBC in respect of

Magor Vicarage.

MORAG ELLIS QC EMYR JONES

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Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Traffic Peter Ireland WG 1.7 • Alternatives Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ 4.9.16 & 6.3.5‐6.3.7) OBJ0001 David Layton Matthew Jones WG 1.1 (Chapter 9) Matthew Jones WG 1.1.1 (Paragraphs 22.31‐22.32)

• Economics Matthew Jones WG 1.1.1 (Paragraph 13.5 & 22.27) • Environment Stephen Bussell WG 1.3. • Alternatives Nicholas Rowson WG 1.8 (Paragraph 3.14.5) Michael Bull WG 1.12 Philip Evans WG 1.14

OBJ0002 Dr Anthony Owen

• Water quality Julia Tindale WG 1.10.1 (Paragraphs 8.59‐8.62) • Land use Barry Woodman WG 1.6.1 (Paragraphs 10.2‐10.5 & 10.8‐ 10.11) OBJ0003 Statutory Jeff Neale

• Economics Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6‐6.8) • Environment Matthew Jones WG 1.1 • Design Stephen Bussell WG 1.3 • Landscape Barry Woodman WG 1.6 Monmouth County • Noise and Vibration Nicholas Rawson 1.8.1 (Paragraph 5.5‐5.5.10) OBJ0004 Councillor / Linda Philip Evans WG 1.14.1 (Chapter 8) Guppy Mick Rawlings, 1.9.1

• Ecology and Nature Conservation Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6‐6.8) • Air quality Matthew Jones WG 1.1 • Alternatives Matthew Jones WG 1.1 (Paragraph 22.27) • Economics Michael Bull WG 1.12 Keith Jones WG 1.18 OBJ0005 Emma Caresimo Philip Evans WG 1.14 (Chapter 8)

• Cultural Heritage Matthew Jones WG 1.1 (Paragraph 22.37‐22.38) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Economics Mick Rawlings WG 1.9 (Paragraphs 7.42 ‐ 7.50)

OBJ0006 Steven Wernham

OBJ0007 Amy Rackham • Land use Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 1 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Economics Matthew Jones WG 1.1.1 (Chapter 13) • Environment Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Alternatives Stephen Bussell WG 1.3 • Carbon Philip Evans WG 1.14.1 (Chapter 8) • Traffic Tim Chapman WG 1.13 • Alternatives Matthew Jones WG 1.1.1 (Paragraphs 22.31‐22.32 and 22.27) OBJ0008 A P Clark Document 4.7.2 WG/REB/OBJ0247

• Land Use, Community & Recreations Matthew Jones WG 1.1 • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Environment Ben Sibert WG 1.5 (Paragraphs 4.124‐4.127) • Alternatives

OBJ0009 Matthew Sutton

• Traffic Bryan Whittaker WG 1.2.6 (Paragraph 9.6.1‐9.6.8)

OBJ0010 Allan McBain

• Land Use, Community & Recreation Matthew Jones WG 1.1.1 (paragraph 10.12) OBJ0011 Anna Wilson Rebuttal WG/REB/OBJ0099 ‐ PJ Cromwell

• Traffic Matthew Jones WG 1.1.1 • Environment Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Carbon Peter Ireland WG 1.7 University of South • Cultural Heritage John Davies WG 1.23.1 (paragrapgh 49‐55) OBJ0012 Wales Mick Rawlings WG 1.9.1 (Chapter 7) Madeleine Gray

REVISED M4CAN objections schedule of evidence.xlsm 2 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature conservation Keith Jones WG 1.18 • Environment and Carbon Michael Vaughan WG 1.17.1 (Paragraph 5.78‐5.89) • Alternatives John Davies WG 1.23.1 (paragrapgh 49‐55) • Sustainable Development Matthew Jones WG 1.1.1 (Paragraph 3.18 & 22.33‐22.36) Verity and Julian • Cultural Heritage Mick Rawlings WG 1.9.1 OBJ0013 Branscombe Document 4.7.2 WG/REB/OBJ0247

• Sustainable Development John Davies WG 1.23 • Alternatives Matthew Jones WG 1.1.1 (Chapter 9) OBJ0014 Tom Bond Matthew Jones WG 1.1.1 (Paragraphs 22.28‐22.30)

• Air Qualiy Barry Woodman WG 1.6.1 (Paragraphs 10.13‐10.20) • Noise & Vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 5‐5.5) OBJ0015 Hazel White • Economics Philip Evans WG 1.14.1 (paragraphs 4.8.1 ‐ 4.8.9 & 10.3.4‐ 10.3.5) • Ecology and Nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Carbon 4.9.16 & 6.3.5‐6.3.7) • Alternatives Peter Ireland WG 1.7 Michael Bull WG 1.12.1 (Chapter 3.2‐3.6) Stephen Bussell WG 1.3.1 (paragraph 4.61) OBJ0016 Jeremy Gass Matthew Jones WG 1.1.1 (Chapter 13 and paragraph 22.27) Document 4.7.2 WG/REB/OBJ0247

• Economics Stephen Bussell WG 1.3 OBJ0017 Peter Harris Matthew Jones WG 1.1.1 (Chapter 13 & 22.19‐22.26, 22.27) • Ecology and nature conservation Keith Jones WG1.18 • Economics Stephen Bussell WG 1.3 • Environment Michael Bull WG 1.12.1 • Carbon Peter Ireland WG 1.7 • Sustainable Development John Davies WG 1.23.1 (paragraph 49‐55) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18‐20) • Economics Matthew Jones WG 1.1.1 (Chapter 13 & 22.19‐22.26) Tim Chapman WG 1.13.1 (Paragraphs 5.1‐5.1.3) Document 4.7.2 WG/REB/OBJ0247

OBJ0018 Patricia Sheehan

• Land use OBJ0019 Statutory W&M McDonald Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 3 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Consultation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Environment, Ecology and nature conservation 4.9.16 & 6.3.5‐6.3.7) • Flood Consequences assessment, Water quality Matthew Jones WG 1.1 • Economics Michael Vaughan WG 1.17.1 (Chapter 5) • Traffic Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & 5) • Environment Matthew Jones WG 1.1.1 (Chapter 13) • Alternatives Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy. Michael Vaughan WG 1.17.1 (Paragragh 5.5‐5.14) OBJ0020 David James Nicholas Rawson 1.8.1 (Paragraph 5.4‐5.4.3 & 5.5‐5.5.10)

• Land Use, Community and Recreation Julia Tindale WG1.10.1 Chapter 14 of the Environmental Statement (Document OBJ0021 Mark Heathfield 2.3.2)

• Noise and Vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 7.1) • Environment Philip Evans WG 1.14.1 (paragraphs 4.8.1 ‐ 4.8.9 & 10.3.4‐ • Design 10.3.8) • Air Quality Barry Woodman WG 1.6.1 (Paragraphs 10.2, 10.6‐10.7 & Howard & Elizabeth OBJ0022 • Environment 5.8‐5.10 & 5.16‐5.19) Wainwright • Noise & Vibration Nicholas Rawson WG 1.8.1 (Paragraphs 5.7‐5.7.8) • Construction • Traffic • Air quality • Traffic • Alternatives OBJ0023 o‐Dzin Tridral Withdrawn

• Traffic • Alternatives OBJ0023 o‐Dzin Tridral Withdrawn

• Economics Matthew Jones WG 1.1.1 (Paragraph 22.18 & 22.33‐22.36 • Alternatives & Chapter 13) • Ecology and nature conservation Stephen Bussel WG 1.3 • Carbon Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) • Ecology ‐ wildlife Document 4.7.2 • Ecology ‐ Water Voles WG/REB/OBJ0247 OBJ0024 Dave and Marilyn • Cultural Heritage • Consultation • Sustainable Development

• Land use Network Rail OBJ0025 Statutory Withdrawn Stephen Sprei

REVISED M4CAN objections schedule of evidence.xlsm 4 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Traffic WG/REB/OBJ0026 ‐ Rebuttal to Simon Turl • Economics WG/REB/OBJ0026 ‐ Rebuttal to Mke Axon ‐ by Dr P • Design Ireland • Environment WG/REB/OBJ0026 ‐ Rebuttal to Mike Axon ‐ by Bryan Whittaker WG/REB/OBJ0026 ; OBJ0292 BWo Rebuttal ‐ Roadchef & Rontec ‐ Construction WG/REB/OBJ0026 ; OBJ0292 Bwo Erratum Rebuttal ‐ Roadchef & Rontec ‐ Construction WG/REB/OBJ0026 ; OBJ0292 JD Rebuttal ‐ Roadchef & Rontec ‐ Planning WG/REB/OBJ0026 ; OBJ0292 MJ Rebuttal ‐ Roadchef & Road Chef Rontec ‐ Decision Making and Policy Simon Turl, OBJ0026 Statutory WG/REB/OBJ0026 ; OBJ0292 SB Rebuttal ‐ Roadchef & Chief Executive, Rontec ‐ Economics RoadChef WG/REB/OBJ0026 ; OBJ0292 SB Supplementary Rebuttal ‐ Roadchef & Rontec ‐ Economics WG/REB/OBJ0026 ; OBJ0292 BS Rebuttal ‐ Roadchef & Rontec ‐ Engineering PIQ/123 ID/078 ID/091 ID/094 (Statement of Common Ground)

• Econonmics Matthew Jones WG 1.1.1 (Chapter 13 and 19) • Environment, Ecology and nature Matthew Jones WG 1.1.6 • Design Keith Jones WG 1.18.1 • Port Economics, Shipping Document 4.7.2 • Alternatives

OBJ0027 Gerrard Williams

• Noise and Vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6‐6.8) • Air Quality Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Ecology and nature conservation 4.9.16 & 6.3.5‐6.3.7) OBJ0028 Dr Graham Small • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation WG/REB/OBJ0270 - Gwent Wildlife Trust • Sustainable development WG/REB/OBJ0247 • Alternatives ID/217 Wildlife Trust Wales ID/218 OBJ0029 Wildlife Trust Wales ID/219 Campaign ID/220

REVISED M4CAN objections schedule of evidence.xlsm 5 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation WG/REB/OBJ0030 ‐ RSPB • Alternatives ID/250 • Air quality • Ecology and nature conservation • Sustainable Development RSPB Cymru OBJ0030 The RSPB Campaign

• Port Economics PIQ/042 • Shipping PIQ/045 • Design PIQ/050 • Alternatives PIQ/056 PIQ/074 Associated British PIQ/080 OBJ0031 Statutory Ports Withdrawn PIQ/116 Matthew Kennerley ID/070 ID/188 ID/189 ID/196 ID/228 ID/239 • Ecology and Nature Conservation Keith Jones WG 1.18 OBJ0032 Andrea Jackman • Alternatives Matthew Jones WG1.1.1 (paragraph 22.27)

• Environment WG/REB/OBJ0271 ‐ Woodland Trust • Nature and conservation The Woodland Trust OBJ0033 The Woodland Trust Campaign

• Noise and Vibration Philip Evans WG 1.14.1 (Chapter 8) • Air Quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6‐6.8) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) • Environment Rebuttal WG‐REB‐OBJ0150 ‐ Magor and Undy Community OBJ0034 PJ Brannigan Council

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Water quality 4.9.16 & 6.3.5‐6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) Richard Graham WG 1.15.1 (Paragraph 11.26‐11.30) Document 4.7.2 OBJ0035 Dick Finch WG/REB/OBJ0247

• Ecology • Sustainable development • Alternatives Wildlife Trust Wales OBJ0036 Withdrawn campain letter

REVISED M4CAN objections schedule of evidence.xlsm 6 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Keith Jones WG 1.18.1 Chapter 5 and (Paragraph 4.9.1‐ • Alternatives 4.9.16 & 6.3.5‐6.3.7) Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) OBJ0037 Susan Danziger Nicholas Rawson 1.8.1 (Paragraph 5.2‐5.2.4) Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation • Sustainable development • Alternatives removed Wildlife Trust OBJ0038 Withdrawn Wales campain letter

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Sustainable development 4.9.16 & 6.3.5‐6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Chapter 9) OBJ0039 Pam Webb Matthew Jones WG 1.1.1 (Paragraph 3.18‐20 & 22.28‐ 22.30) Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Sustainable development 4.9.16 & 6.3.5‐6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Chapter 9) OBJ0040 Huw Evans MatthewJones WG 1.1.1 (Paragraph 3.18‐20 & 22.28‐ 22.30) Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Sustainable development 4.9.16 & 6.3.5‐6.3.7) • Alternatives Peter Ireland WG 1.7 OBJ0041 Caroline Wynn Matthew Jones WG 1.1.1 (Chapter 9) Matthew Jones WG 1.1.1 (Paragraph 3.18) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Keith Jones WG 1.18 (Paragraph 4.9.1‐4.9.16 & 6.3.5‐ • Carbon 6.3.7) OBJ0042 J Harding Morris Peter Ireland WG 1.7 Keith Jones WG 1.18 (Chapter 5,6) John Davies WG 1.23 (paragrapgh 49‐55) • Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Air Quality Matthew Jones WG 1.1.1 (Paragraphs 22.28‐22.30) • Ecology and nature conservation Keith Jones WG1.18 OBJ0043 Brian & Susan Roberts

• Alternatives Matthew Jones WG 1.1.1 (Chapter 9) • Air Quality Matthew Jones WG 1.1.1 (Paragraphs 22.18 & 22.28‐ • Ecology & Nature Conservation 22.30) • Sustainable Development Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9)

OBJ0044 Helene Jessop

REVISED M4CAN objections schedule of evidence.xlsm 7 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Consultation Matthew Jones WG 1.1.1 (Chapter 13 & 22.19‐22.26) • Economics Philip Evans WG 1.14.1 (Chapter 8) • Environment Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) • Alternatives Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6‐6.8) • Environment Document 4.7.2 • Ecology and Nature Conservation WG/REB/OBJ0247 • Noise and Vibration OBJ0045 Nicola Smith • Air Quality

• General Matthew Jones WG 1.1.1

OBJ0046 Margaret Pobjoy

• Land use OBJ0047 Statutory LDH Plant Withdrawn

• Land Use, Community and Recreation OBJ0048 Statutory Lyndon Williams Withdrawn

• Land Use, Community and Recreation WG/REB/OBJ0049 ‐ Parc Golf Club Parc Golf Club OBJ0049 Statutory TG Hicks

• Alternatives Matthew Jones WG 1.1.1 (Chapter 9) • Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Sustainable Development 4.9.16 & 6.3.5‐6.3.7) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation OBJ0050 IS Thompson Strategy. Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Paragraphs 22.28‐22.30)

• General Matthew Jones WG 1.1

OBJ0051 Lindsay Williams

• Environment Barry Woodman WG 1.6.1 (Paragraphs 10.13‐10.24) • Sustainable development Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) • Cultural Heritage Matthew Jones WG 1.1.1 (Chapter 13, Paragraph 22.27) • Traffic Philip Evans WG 1.14.1 (Chapter 8) • Economics Mick Rawlings, 1.9.1

Residents of Common y OBJ0052 Coed

REVISED M4CAN objections schedule of evidence.xlsm 8 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Noise and Vibration Philip Evans WG 1.14.1 (paragraphs 4.8.1 ‐ 4.8.9 & 10.3.4‐ • Landscape 10.3.5) • Design Nicholas Rowson WG1.8.1 (paragraph 5.5.‐5.5.10) OBJ0053 EJ Boardmore Ben Sibert WG 1.5.1 (paragraph 4.21 and 4.41‐4.45)

• General Matthew Jones WG 1.1

OBJ0054 Elizabeth Green

• Ecology & Nature Conservation Peter Ireland WG 1.7 OBJ0055 David Austin • Environment Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ 4.9.16 & 6.3.5‐6.3.7)) Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ270 ‐ Gwent Wildlife Trust OBJ0056 Nick Davies • Environment Keith Jones WG 1.18.1 (Chapter 4.11) • Ecology and Nature Conservation Keith Jones WG 1.18 OBJ0057 Lin Ashcroft Jon Davies WG 1.19 Richard Green 1.20 Simon Zisman 1.21

• Ecology & Nature Conservation Nicholas Rowson 1.8.1 (Paragraph 5.4‐5.4.3) • Landscape Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ 4.9.16 & 6.3.5‐6.3.7)

OBJ0058 Donal McCarthy

• Ecology & Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • General 4.9.16, 4.11 & 6.3.5‐6.3.7) Matthew Jones WG 1.1.1 (Paragraphs 22.31‐22.32 & 22.42‐22.44) OBJ0059 Daniel Webb

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Sustainable development 4.9.16 & 6.3.5‐6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Chapter 9) Matthew Jones WG 1.1.1 (Paragraph 3.18‐20 & 22.28‐ 22.30) Document 4.7.2 Pat Jones Jenkins OBJ0060 WG/REB/OBJ0247

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Noise and Vibration, Environment 4.9.16 & 6.3.5‐6.3.7) • Water Quality Richard Graham WG 1.15.1 (Paragraph 11.26‐11.30) OBJ0061 Chris Brown • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1‐4.9) Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 9 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• General Matthew Jones WG 1.1 OBJ0062 Alison Stroud

• Ecology and Nature Conservation Keith Jones WG 1.18.1 OBJ0063 Mary Watkins • Alternatives (Chapter 5 and Paragraph 4.9.1‐4.9.16 & 6.3.5‐6.3.7) • Noise and Vibration, Environment Richard Graham WG 1.15.1 (Paragraph 11.26‐11.30) • Traffic Keith Jones WG 1.18.1 (Paragraph 4.9.1‐4.9.16 & 6.3.5‐ • Ecolgy and Nature Conservation 6.3.7) • Water Quality Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) OBJ0064 Mary Pearce • Alternatives Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1‐ • Sustainable development 4.9.16 & 6.3.5‐6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Chapter 9 & Paragraph 3.18‐20 & 22.28‐22.30) Document 4.7.2 Angharad Beurle‐ WG/REB/OBJ0247 OBJ0065 Williams

• Traffic Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation • Alternatives Strategy. • Ecology and Nature Conservation Keith Jones WG 1.18 • Sustainable development Matthew Jones WG 1.1.1 (Paragraph 22.18)

OBJ0066 Rich Chandler

• Ecology and Nature Conservation Keith Jones WG 1.18 • Alternatives Simon Zisman 1.21 OBJ0067 Wendy Smith Matthew Jones WG 1.1.1 (Paragraph 3.18‐20) Document 4.7.2

• Land use Matthew Jones WG 1.1.1 (Paragraph 3.18‐20 and Chapter • Alternatives 23) • Design Ben Sibert WG 1.5.1 (Paragraph 5.13‐5.16)

IAC Systems OBJ0068 Statutory Peter Lewis

REVISED M4CAN objections schedule of evidence.xlsm 10 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation WG/REB/OBJ0270 - Gwent Wildlife Trust • Traffic • Sustainable Development

Wildlife Trust Wales OBJ0069 Ruth Loebl

• Alternatives Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and Nature Conservation 4.9.16 & 6.3.5-6.3.7) • Sustainable Development Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy. Matthew Jones WG 1.1.1 (Paragraph 22.18) OBJ0070 Max Hastings‐Herbert

• Alternatives WG/REB/OBJ0031 - ABP ID/235

The Newport Harbour OBJ0071 Statutory Commissioners J Lloyd

• Land use Refer to OBJ0238 Newland Rennie OBJ0072 Arthur G Smith

• Alternatives Now supporter 24/01/17

Caerphilly CBC OBJ0073 Withdrawn Terry Shaw

REVISED M4CAN objections schedule of evidence.xlsm 11 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Richard Graham WG 1.15.1 (Paragraphs 11.23-11.25) • Alternatives Matthew Jones WG 1.1 (Chapter 9) and paragraphs 8.5 - • Carbon 8.14 • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1- • Land Use, Community and Recreations 4.9) • Sustainable Development Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20 • Environment & 22.28-22.30) Keith Jones WG 1.18.1 (Chapter 4.11, 5 and Paragraph 4.9.1-4.9.16 & 6.3.5-6.3.7) Tim Chapman WG 1.13.1 (Paragraphs 5.1-5.1.3) Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127) Julia Tindale WG1.10.1 (Paragraph 8.117) Document 4.7.2 OBJ0074 Alison Willott Document 2.5.2 WG/REB/OBJ0247

• Ecology & Nature Conservation Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0075 John Staton Mitigation Strategy. Keith Jones WG 1.18 Document 4.7.2 WG/REB/OBJ0247 • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Ecology & Nature Conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0076 Thomas J Wheeler Mitigation Strategy. Keith Jones WG 1.18 • Water Quality WG/REB/OBJ0077 - Mr A Pickup OBJ0077 A R Pickup ID/052

• Noise and Vibration WG/REB/OBJ0078 - Llandevenny Residents • Air Quality ID/075 • Economics • Environment OBJ0078 Mrs J Pickup

• Land Use, Community and Recreation Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Design Julie Tindale WG 1.10.1

OBJ0079 Gareth Walters

REVISED M4CAN objections schedule of evidence.xlsm 12 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature Conservation Ben Sibert WG 1.5.1 (Paragraph 4.124-4.127) • Land use

OBJ0080 Adrian Deere‐Jones

• Traffic Barry Woodman WG 1.6.1 (Paragraphs 10.12-10.20 & • Economics 8.10-8.11) • Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) Matthew Jones WG 1.1.1 (Chapter 9, 13 & 22.19-22.26) Cardiff and Vale Public OBJ0081 Health Team Chris Jones

• Ecology and Nature Conservation Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Alternatives OBJ0082 Ceri Crossland

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Sustainable development 4.9.16 & 6.3.5-6.3.7) • Flood consequences assessment Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & • Cultural heritage 5) • Alternatives Michael Vaughan WG 1.17.1 (Paragraph 5.78-5.89) • Flooding Mick Rawlings 1.9.1 (Paragraph 6.39 & 7.42 - 7.51) Document 4.7.2 Matthew Jones WG 1.1.1 (Chapter 9 and Paragraph 3.18-20) OBJ0083 Rose Reveral Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Alternatives Mitigation Strategy. OBJ0084 Christopher Hatch Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Ecology and Nature Conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Landscape Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- 22.30) Document 4.7.2 OBJ0085 Ruth Brown WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 13 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature Conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Landscape Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- 22.30) Document 4.7.2 OBJ0086 Allan Cowhig

• Alternatives Richard Graham WG 1.15.1 (Paragraph 11.26-11.30) • Water quality Peter Ireland 1.7.1 • Environment Mr Bryan Whittaker 1.2.6 (Paragraphs 10.3.7 - 10.3.8) Matthew Jones WG 1.1.1 (Paragraph 22.18 & 22.28- 22.30 & Chapter 9) PIQ/078 PIQ/165 candidate of Newport OBJ0087 East Peter Varley

RSPB Cymru • Ecology and Nature Conservation WG/REB/OBJ0030 ‐ RSPB OBJ0088 Katie‐jo Luxton • Landscape Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3)

OBJ0089 Robert Hughes

• Land use Barry Woodman WG 1.6.1 (Paragraphs 10.42-10.43 & 9.9)

Vodafone OBJ0090 Statutory Withdrawn Rob Baker

• Alternatives Matthew Jones WG 1.1.1 (Chapter 9) • Air Quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Cultural heritage Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and Nature Conservation 4.9.16 & 6.3.5-6.3.7) Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) Peter Moore OBJ0091 Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.32)

• Economics WG/REB/OBJ0092 - Dr Catherine Linstrum • Traffic PIQ/087 OBJ0092 Dr Catherine Linstrum • Environment ID/059 • Alternatives

REVISED M4CAN objections schedule of evidence.xlsm 14 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Carbon and Sustainabe Development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and Nature Conservation 4.9.16 & 6.3.5-6.3.7) • Cultural heritage Matthew Jones WG 1.1.1 (Chapter 9) • Alternatives Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30)

OBJ0093 Dr Steve Palmer

• Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and Nature Conservation 4.9.16 & 6.3.5-6.3.7) • Economics Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- • Alternatives 22.30) Document 4.7.2 WG/REB/OBJ0247 OBJ0094 Caroline Syred

• Shipping WG/REB/OBJ0031 - ABP PIQ/012 Port Security Authority PIQ/032 OBJ0095 Statutory Ian Meredith PIQ/039

• Environment Barry Woodman WG 1.6.1 (Paragraphs 10.2 & 5.8-5.10 • Traffic &5.16-5.19 & 10.13-10.20) • Air quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 5-5.5) • Noise and vibration Philip Evans WG 1.14 (Chapter 8) • Alternatives Bryan Whittaker WG 1.2.6 • Ecology and nature conservation Matthew Jones WG 1.1.1 (Chapter 9 and 13 and OBJ0096 Ann Kenny Paragraphs 22.27-22.30) PIQ/072 PIQ/073 PIQ/085

• Land use Tarmac & Cambrian OBJ0097 Statutory Withdrawn Stone

REVISED M4CAN objections schedule of evidence.xlsm 15 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Land use

Carlsberg Supply Company UK Limited David Bodily OBJ0098 Statutory Head of Property, Withdrawn Facilities & Security Carlsberg Supply Company UK Limited

• Traffic WG/REB/OBJ0099 - PJ Cromwell • Alternatives WG/REB/OBJ0099 - Erratum to Rebuttal • Economics PIQ/058 PIQ/060 ID/038 (Statement of Common Ground)

OBJ0099 Paul J Cromwell

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) OBJ0100 Jill Rossiter Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2

• Alternatives • Ecology and nature conservation OBJ0101 Barbara Willis Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 16 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature Conservation Richard Graham WG 1.15.1 (Paragraphs 11.23-11.25) • Traffic Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Sustainable Development Mitigation Strategy. • Air Quality Keith Jones WG 1.18.1 (CHapter 4.11) • Noise and Vibration Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20) • Alternatives Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Water quality Philip Evans WG 1.14.1 (Chapter 8) Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - 4.9) Document 4.7.2 WG/REB/OBJ0247

OBJ0102 Margaret Durkin

• Land use WG/REB/OBJ0103 - Bovis Homes ID/050

OBJ0103 Statutory Bovis Homes Withdrawn

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 4.11) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 WG/REB/OBJ0247 OBJ0104 Gareth Jones

• Ecology and nature Conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Landscape 4.9.16 & 6.3.5-6.3.7) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Alternatives Matthew Jones WG 1.1.1 (Chapter 9) OBJ0105 Mal Jenkins Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- 22.30) Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 17 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature Conservation WG/REB/OBJ0270.13 - Lindi Rich • Sustainable development WG/REB/OBJ0247 • Alternatives • Air Quality • Noise and Vibration • Cultural Heritage

Gwent Wildlife Trust OBJ0106 Lindi K Rich

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Consultation 4.9.16 & 6.3.5-6.3.7) • Alternatives Peter Ireland WG 1.7.1 (Paragraph 11.11-11.16) OBJ0107 Dru Brooke Taylor Matthew Jones WG1.1.1 Chapter 3 and 23 Document 4.7.2

• Alternatives Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and Nature Conservation 4.9.16 & 6.3.5-6.3.7) OBJ0108 Carole Lewis • Economics Peter Ireland 1.7.1 Chapter 8 Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26)

• Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and nature conservation 4.9.16 & 6.3.5-6.3.7) • Carbon Richard Graham WG 1.15.1 (Paragraph 11.26-11.30) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 OBJ0109 Chris Kirby‐Lambert

• Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 OBJ0110 Keith Davies WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 18 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Noise and Vibration 4.9.16 & 6.3.5-6.3.7) • Traffic Philip Evans WG 1.14.1 (Chapter 8) • Environment Richard Graham WG 1.15.1 (Paragraph 11.26-11.30) • Cultural heritage Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20 • Water quality & 22.28-22.30) • Sustainable Development Matthew Jones WG 1.1.1 (Chapter 9) • Alternatives Nicholas Rowson WG 1.8.1 (Paragraphs 5.7-5.7.8) OBJ0111 Thomas Simcock • Landscape

• Shipping Jonathan Vine WG 1.22.1 (Paragraphs 8.1.1-8.1.8) • Design Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Air Quality 4.9.16 & 6.3.5-6.3.7) • Noise and Vibration Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Landscape Mitigation Strategy. • Ecology and Nature Conservation Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Alternatives OBJ0112 Mike Worthington

• Ecology and Nature Conservation Keith Jones WG1.18.1 (Chapter 4.11) • Traffic. Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - • Alternatives 4.9) OBJ0113se Chrissi Perry Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30)

• Ecology and Nature Conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Alternatives Mitigation Strategy. • Noise and vibration Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - Gareth Ham OBJ0114 • Air quality 4.9.16 & 6.3.5-6.3.7) • Landscape Philip Evans WG 1.14.1 (Chapter 8) Nicholas Rowson 1.8.1 (Paragraph 5.3-5.3.5) • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Environment 4.9.16 & 6.3.5-6.3.7) OBJ0115 Maggie Hampton

• Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Ecology and Nature Conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Environment Mitigation Strategy. OBJ0116 Sandra Alexander • Alternatives Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 WG/REB/OBJ0247 • Environment Peter Ireland WG 1.7 • Economics Matthew Jones WG 1.1.1 (Paragraph 3.18-20) OBJ0117 Jenny Cripps • Alternatives Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 19 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Matthew Jones WG 1.1.1 (Chapter 13 and Paragraph • Economics 3.18-20) OBJ0118 Liz Worthington • Alternatives Keith Jones WG1.18 Document 4.7.2 WG/REB/OBJ0247 • Environment Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) • Air quality Philip Evans WG 1.14.1 (Chapter 8) • Noise and Vibration Richard Graham WG 1.15.1 (Paragraph 11.26-11.30) OBJ0119 Lynne Topman • Landscape Document 4.7.2 • Water quality • Alternatives

• General DHB Accountants OBJ0120 Limited withdrawn Daw Bray • Ecology and Nature Conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Alternatives. Mitigation Strategy. OBJ0121 Sue Collingbourne Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Chapter 9)

• Air quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0122 Lyndon Waters • Environment Nicholas Rowson 1.8.1 (Paragraph 5.3-5.3.5) • Air quality Phillip Evans WG 1.14.1 (Chapter 8) • Noise and Vibration Michael Bull, WG 1.12.1 • Landscape OBJ0123 Sandra Dowrick

• Ecology and nature conservation OBJ0124 Ruth Dow • Economics withdrawn • Alternatives • Traffic WG/REB/OBJ0125 - Friends of the Earth - Gerald Kells • Alternatives ID/073 • Water Quality WG/REB/OBJ0247 • Air Quality ID/200 • Noise and Vibration WG/REB/OBJ0125-3 • Carbon • Economics • Sustainable Development Friends of the Earth OBJ0125 Cymru Gareth Clubb

• Noise & Vibration Phillip Evans WG 1.14.1 (Chapter 8) • Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Shipping, Port economics 4.9.16 & 6.3.5-6.3.7) • Air Quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0126 Thomas Timbul • Alternatives Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30)

REVISED M4CAN objections schedule of evidence.xlsm 20 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - 4.9.16 & 6.3.5-6.3.7) OBJ0127 Hugo Perks

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Environment 4.9.16 & 6.3.5-6.3.7) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0128 Barbara Spence Mitigation Strategy. Keith Jones WG 1.18

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Sustainable Development Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0129 Judy Hanny Mitigation Strategy. Matthew Jones WG 1.1.1 (Paragraph 22.18 & 22.28- 22.30 & Chapter 9) • Environment Nicholas Rowson 1.8.1 • Landscape Dr Peter Ireland 1.7.1 OBJ0130 Alison James

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Environment 4.9.16 & 6.3.5-6.3.7) • Air quality Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Noise and vibration Michael Bull 1.12 • Traffic

OBJ0131 Peter Warren

• Human rights Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30) • Environment Keith Jones WG1.18.1 (Chapter 4.11) • Alternatives Mick Rawlings 1.8.1 (Chapters 6, 7 & 8) • Noise and vibration Phillip Evans 1.14.1 • Ecology and nature conservation Peter Ireland 1.7.1 • Culture and heritage

OBJ0132 Mike Hall

REVISED M4CAN objections schedule of evidence.xlsm 21 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• General Matthew Jones WG 1.1.1 OBJ0133 Gavin Bray

• Traffic Matthew Jones WG 1.1.1 (Chapter 13) • Cultural heritage Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.33- • Ecology and Nature Conservation 22.36) OBJ0134 Natalie Davies • Economics Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8) • Alternatives Documents 4.1 - 4.7

• Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Economics Mitigation Strategy. OBJ0135 R B • Alternatives Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26)

• Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Sustainable Development Matthew Jones WG 1.1.1 (Paragraph 22.18) Document 4.7.2

OBJ0136 Mike Erskine

Cargo Services (UK) • Sustainable Development Ben Sibert WG 1.5.1 (Paragragh 5.26-5.29) OBJ0137 Statutory Ltd Withdrawn Barry Woodman WG 1.6.1 (Paragraphs 10.62-10.64) John Davey Peter Ireland WG 1.7.1 (Paragraphs 10.15-10.16) • General Matthew Jones WG 1.1.1 OBJ0138 Andrea Hennessey • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Economics 4.9.16 & 6.3.5-6.3.7) • Design Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0139 Carla Lewis • Air quality Michael Bull WG 1.12.1 (Paragraph 9.1) • Landscape Nicholas Rowson 1.8.1 (Paragraph 5.3-5.3.5) Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26)

• Alternatives Matthew Jones WG 1.1.1 (Chapter 9 & 13) • Ecology and Nature Conservation Keith Jones WG1.18.1 OBJ0140 Sue Emlyn Jones • Economics Document 4.7.2 WG/REB/OBJ0247

• Alternatives Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Sustainable Development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Landscape 4.9.16 & 6.3.5-6.3.7) Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20) Document 4.7.2 WG/REB/OBJ0247 OBJ0141 Barbara Dwyer

REVISED M4CAN objections schedule of evidence.xlsm 22 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- • Alternatives 22.30 & 22.33-22.36) • Design Keith Jones WG1.18.1 (Chapter 4.11) • Sustainable Development Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127) • Ecology and nature conservation Matthew Jones WG 1.1 (Chapter 9) • Carbon Document 4.7.2 WG/REB/OBJ0247 OBJ0142 Vivien Mitchell • Consultation

• General Matthew Jones WG 1.1.1 OBJ0143 Meyrick Jones • Cultural heritage WG/REB/OBJ0144-2 - Campaign for the Protection of • Environment Rural Wales (Victor Warren) Campaign for the • Carbon WG/REB/OBJ0144-1 - Campaign for the Protection of Protection of Rural • Ecology and nature conservation Rural Wales (Peter Ogden) OBJ0144 Wales Newport and • Traffic ID/213 Valleys Branch • Economics WG/REB/OBJ0144-4 CPRW Vic Warren WG/REB/OBJ0144-3 ID/245 ID/249 • Land use Michael Vaughan WG 1.17.1 (Paragraphs 4.46-4.58) Julia Tindale WG 1.10.1 (Paragraghs 8.4-8.9) Ben Sibert WG 1.5.1 (Paragraphs 5.30-5.32) Peter Ireland WG 1.7.1 (Paragraph 10.17) Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & 5)

Mr John Watts‐Baker & OBJ0145 Statutory Mr Peter Watts‐Baker

• Ecology and Nature Conservation Nicholas Rowson WG 1.8.1 (Paragraphs 5.7-5.7.8) OBJ0146 Isla Holland • Landscape • Shipping, Port economics Matthew Jones WG 1.1.1 (Paragraph 3.18-20 and 23) • Economics Stephen Bussel WG 1.3.1 (Paragraph 6.14) TU Agencies OBJ0147 • Port economics Andrew Meaney WG 1.4.1 Noel Challenger • Alternatives Document 4.7.2 WG/REB/OBJ0147 • Consultation Julia Tindale WG 1.10.1 (Paragraph 8.116) • Land Use, Community & Recreation Ben Sibert WG 1.5.1 (Paragraph 5.33-5.36) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - • Alternatives 4.9) Railway Paths Ltd OBJ0148 Statutory Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127) Howard Jones

REVISED M4CAN objections schedule of evidence.xlsm 23 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Consultation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Environment Mitigation Strategy. Keith Jones WG 1.18.1 (Chapter 5 • Ecology and nature conservation and Paragraph 4.9.1-4.9.16 & 6.3.5-6.3.7) • Flood consequences assessment Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Flooding Michael Vaughan WG 1.17.1 (Paragraph 4.46-4.58) • Alternatives Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & • Traffic 5) Dianne & David OBJ0149 • Economics Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - Roberts 4.9) Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) Document 4.7.2 WG/REB/OBJ0247

• Traffic WG/REB/OBJ0150 - Magor and Undy Community • Noise Council • Air quality WG/REB/OBJ0247 • Sustainable development • Economics • Alternatives • Consultation • Traffic • Flood consequesnce assessment • Ecology and nature conservation • Land Use, Community & Recreations • Design • Environment County Councillor OBJ0150 Frances Taylor

• Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Noise and vibration, Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127) • Air quality Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) • Economics • Environment • Land Use, Community & Recreation • Traffic OBJ0151 Robert Hayes • Alternatives • Consultation

REVISED M4CAN objections schedule of evidence.xlsm 24 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Barry Woodman WG 1.6.1 (Paragraphs 10.13-10.24) • Cultural heritage Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Construction Matthew Jones WG 1.1.1 (Chapter 13) • Traffic Mick Rawlings, 1.9.1 • Air quality • Economics

OBJ0152 Statutory S E Phillips

• Environment Philip Evans WG 1.14 (Chapter 8) • Air quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Noise & vibration Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - • Traffic 4.9) • Alternatives Document 4.7.2 OBJ0153 Mark Lane

• Traffic WG/REB/OBJ0154 - Laurence Lowe • Alternatives PIQ/044 • Economics WG/REB/OBJ0247 • Sustainable Development • Ecology and nature conservation • Consultation OBJ0154 Laurence Lowe

• Ecology and Nature Conservation Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30) • Alternatives OBJ0155 April Wiggins

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - OBJ0156 Charlotte Jones • Alternatives 4.9.16 & 6.3.5-6.3.7)

• General OBJ0157 Ian Cummings withdrawn • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Sustainable development 4.9.16 & 6.3.5-6.3.7) • Ecology ‐ Otters Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0158 David & Stella Collard • Land Use, Community and recreation Mitigation Strategy. Keith Jones WG 1.18 Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127)

REVISED M4CAN objections schedule of evidence.xlsm 25 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Sustainable development Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Alternatives Document 4.7.2 OBJ0159 Dr Ingo Schuder WG/REB/OBJ0247

• Noise & Vibration Michael Bull WG 1.12.1 (Chapter 3) • Air Quality Philip Evans WG 1.14.1 (Chapter 8) • Environment

OBJ0160 Nicola Evans

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Cutlural heritage 4.9.16 & 6.3.5-6.3.7) • Sustainable development Document 4.7.2 • Alternatives

OBJ0161 Kieron Huston

• Consultation Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) • Economics Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Alternatives Mitigation Strategy. OBJ0162 Dr William Picton • Ecology and nature conservation Keith Jones WG 1.18

• Traffic Matthew Jones WG 1.1.1 (Chapters 9, 13 & paragraphs • Economics 22.19-22.26) • Economics OBJ0163 Amanda Sergeant • Alternatives • Ecology and nature conservation

• Traffic Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.27) • Economics Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Alternatives Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) OBJ0164 Gareth Williams • Landscape Document 4.7.2

• Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Air quality Mitigation Strategy. • Noise and Vibration Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Sustainable development 4.9.16 & 6.3.5-6.3.7) • Traffic Philip Evans WG 1.14.1 (Chapter 8) OBJ0165 John Butler Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) Matthew Jones WG 1.1.1 (Paragraph 22.18)

• Environment Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Alternatives Peter Ireland WG1.7 OBJ0166 David Brassey Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 26 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation WG/REB/OBJ0270.17 - Iolo Williams • Alternatives WG/REB/OBJ0247 OBJ0167 Iolo Williams

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Sustainable Development 4.9.16 & 6.3.5-6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26, • Economics Paragraph 22.18 & 3.18-20) OBJ0168 Saran Allott Davey John Davies WG1.23 Stephen Bussell WG1.3 Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Keith Jones WG 1.18 • Alternatives Document 4.7.2 OBJ0169 Gill Saunders

• Economics Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30) • Alternatives OBJ0170 Nick Saunders

OBJ0171 Peter Gardner • General Matthew Jones WG 1.1 • Environment Michael Bull WG 1.12.1 (Chapter 3) • Ecology and nature conservation OBJ0172 Christina Gardner • Air quality

• Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Air quality Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Noise and vibration 4.9.16 & 6.3.5-6.3.7) • Traffic Philip Evans WG 1.14.1 (Chapter 8) OBJ0173 James Loftus • Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Landscape

• Environment Nicholas Rowson 1.8.1 (Paragraph 5.3-5.3.5) • Landscape Philip Evans WG 1.14.1 (Chapter 8) • Noise & Vibration Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Anne Warrell & Wayne • Air quality Document 4.7.2 OBJ0174 Smith • Alternatives WG/REB/OBJ0247 • Economics

• Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Air quality, Noise & Vibration Philip Evans WG 1.14.1 (Chapter 8) • Alternatives Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Landscape 4.9.16 & 6.3.5-6.3.7) OBJ0175 John Loftus • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9)

• Landscape Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) OBJ0176 Dafydd Lewis • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - 4.9.16 & 6.3.5-6.3.7)

REVISED M4CAN objections schedule of evidence.xlsm 27 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Landscape Mitigation Strategy. • Environment Keith Jones WG 1.18 • Shipping, Port economics Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Alternatives Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) Documents 4.1 - 4.7

OBJ0177 Helen Lyndon

• Ecology and nature conservation Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Alternatives Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - 4.9.16 & 6.3.5-6.3.7) OBJ0178 Ed Drewitt Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Landscape Matthew Jones WG 1.1.1 (Chapter 9) OBJ0179 Mike Morris Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- 22.30) Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) OBJ0180 Marina Branscombe Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30)

• Alternatives Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Ecology and nature conservation 4.9.16 & 6.3.5-6.3.7) • Shipping Matthew Jones WG 1.1.1 (Chapter 9, 13 & Paragraphs • Sustainable development 318-20, 22.19-22.26 & 22.28-22.30) • Economics Document 4.7.2 WG/REB/OBJ0247 OBJ0181 Michelle Cross

• Environment Matthew Jones WG 1.1.1 (Chapter 9) • Alternatives OBJ0182 Maria Phipps

REVISED M4CAN objections schedule of evidence.xlsm 28 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Philip Evans WG 1.14.1 (Chapter 8) • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Noise and Vibration 4.9.16 & 6.3.5-6.3.7) • Air Quality Richard Graham WG 1.15.1 (Paragraph 11.26-11.30) • Water Quality Matthew Jones WG 1.1.1 (Paragraph 3.18-20) OBJ0183 Caroline Robertson • Alternatives Document 4.7.2 WG/REB/OBJ0247

• Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - 4.9.16 & 6.3.5-6.3.7) OBJ0184 Dave Farthing Document 4.7.2 WG/REB/OBJ0247

• Ecology and Nature Conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Cultural heritage 4.9.16 & 6.3.5-6.3.7) • Sustainable development Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20, • Carbon and 13 & 22.19-22.26 & 22.28-22.30 & 22.33-22.36) • Economics Michael Vaughan WG 1.17.1 (Paragragh 5.39- 5.45) • Alternatives Document 4.7.2 • Flood consequences assessment WG/REB/OBJ0247

OBJ0185 Richard Waller

• Air quality Philip Evans WG 1.14.1 (Chapter 8) • Noise and vibration Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Ecology and nature conservation 4.9.16 & 6.3.5-6.3.7) • Water Quality Matthew Jones WG 1.1.1 (Chapter 9 and Paragraph • Alternatives 3.18-20) Document 4.7.2 WG/REB/OBJ0247 OBJ0186 Rhodes Family

• Environment Matthew Jones WG 1.1.1 OBJ0187 Carol Gunter

REVISED M4CAN objections schedule of evidence.xlsm 29 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - • Economics 4.9) • Ecology and nature conservation Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy. OBJ0188 Christine Seabridge Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Shipping, Port economics 4.9.16 & 6.3.5-6.3.7) • Cultural Heritage • Traffic • Alternatives OBJ0189 Tracey Lawrence

• General Matthew Jones WG 1.1 OBJ0190 Andrea Turner • Noise and vibration Philip Evans WG 1.14.1 (Chapter 8) • Air quality Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Ecolgy & Nature Conservation 4.9.16 & 6.3.5-6.3.7) • Water quality Matthew Jones WG 1.1.1 (Chapter 9 and Paragraph • Alternatives 3.18-20 & 22.28-22.30) Document 4.7.2 OBJ0191 Alexander Rhodes WG/REB/OBJ0247

• Ecology and nature conservation Philip Evans WG 1.14.1 (Chapter 8) • Air quality Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) • Noise and vibration OBJ0192 Marje • Economics • Alternatives

• General Matthew Jones WG 1.1 OBJ0193 Mei Gordon • Ecology and Nature Conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Sustainable development Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Landscape Matthew Jones WG 1.1 (Chapter 9 and Paragraph OBJ0194 Ruth Lovell 22.18 & 3.18-20 & 22.28-22.30) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Flood consequences assessment Michael Vaughan WG 1.17.1 (Paragragh 5.5-5.14) • Flooding Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & OBJ0195 Kate Pearce • Cultural Heritage 5) • Alternatives Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 30 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Air quality Philip Evans WG 1.14.1 (Chapter 8) • Noise and vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0196 Derek Coldwell • Ecology and nature conservation

• Noise and vibration Philip Evans WG 1.14.1 (Chapter 8) • Air quality Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Traffic 4.9.16 & 6.3.5-6.3.7) • Ecology and nature conservation Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0197 Robin Moore • Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) Matthew Jones WG 1.1.1 (Paragraph 3.18-20)

• Cultural heritage Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Ecology and nature conservation Keith Jones WG 1.18.1(Chapter 5 and Paragraph 4.9.1- • Landscape 4.9.16 & 6.3.5-6.3.7) • Sustainable development Matthew Jones WG 1.1.1 (Paragraph 22.18) OBJ0198 Steven Rogers • Alternatives

• Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) OBJ0199 Hannah Williams • Landscape

• Economics Matthew Jones WG 1.1.1 (Chapter 13 and paragraph • Alternatives 3.18-20) OBJ0200 Roger James Document 4.7.2 WG/REB/OBJ0247 • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 4.9) • Alternatives Matthew Jones WG 1.1.1 (Chapter 23)

OBJ0201 Ian Mclver

• Air quality Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Noise and vibration Philip Evans WG 1.14.1 (Chapter 8) OBJ0202 Jane Doyle

• Ecology and nature conservation WG/REB/OBJ0203 - Ann Picton • Consultation PIQ/035 • Alternatives PIQ/069 • Traffic PIQ/070 OBJ0203 Ann Picton • Economics PIQ/076 • Shipping, Port economics ID/073 • Sustainable Development ID/103 • Alternatives PIQ/166 ID/255 • Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Air quality Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Landscape 4.9.16 & 6.3.5-6.3.7) • Sustainable development Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Traffic Matthew Jones WG 1.1 (Chapter 9) OBJ0204 Dipti Patel • Alternatives Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20 & 22.39-22.40) Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) Document 4.7.2 WG/REB/OBJ0247

• Land use National Grid OBJ0205 Statutory Withdrawn Nicholas Dexter

REVISED M4CAN objections schedule of evidence.xlsm 31 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation WG/REB/OBJ0206 - Rogiet Community Council • Ecology ‐ water voles. • Cultural heritage • Flood consequence assessment • Environment • Air quality Rogiet Community • Noise and vibration OBJ0206 Statutory Council • Land use Maureen • Shipping, Port economics • Traffic • Land use, community and recreation • Alternatives • Economics • Consultation

• Environment Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & • Noise and Vibration 10.3.4-10.3.5) • Design Ben Sibert WG 1.5.1 (Paragraph 5.37-5.41) • Construction Barry Woodman WG 1.6.1 (Paragraphs 10.82) Nicholas Victor OBJ0207 Statutory Rebecca Jane

• Traffic OBJ0208 Robert Withdrawn

• Land use WG/REB/OBJ0209 - Mr Rabbitt, Daffodil Lodge ID/086

OBJ0209 Statutory Clive William

• Alternatives WG/REB/OBJ0210 - Mr & Mrs Smith • Design ID/208 • Environment WG/REB/OBJ0210-2 • Landscape • Land use

OBJ0210 Mike & Liz

REVISED M4CAN objections schedule of evidence.xlsm 32 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Ben Sibert WG 1.5.1 (Paragraph 5.45-5.49) • Land use

OBJ0211 Statutory T.C. F . Allen

• Environment Julia Tindale WG 1.10.1 (Paragraphs 8.10-8.11) • Land use Ben Sibert WG 1.5.1 (Paragraph 5.50-5.52) Peter Ireland WG 1.7.1 (Paragraph 10.18) R.P OBJ0212 Statutory Mrs D

• Economics Julia Tindale WG 1.10.1 (Paragraphs 8.12-8.17) • Environment Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & • Land use 10.3.4-10.3.5) • Construction Ben Sibert WG 1.5.1 (Paragraph 5.53-5.59) OBJ0213 Statutory JS & RE Anstey • Noise and vibration Barry Woodman WG 1.6.1 (Paragraphs 10.82) Peter Ireland WG 1.7.1 (Paragraph 10.22)

• Economics Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Environment Julia Tindale WG 1.10.1 (Paragraphs 8.18-8.23) • Land use Philip Evans WG 1.14.1 (Paragraphs 4.8.1 - 4.8.9 & 10.3.4-10.3.5) Ben Sibert WG 1.5.1 (Paragraphs 5.60-5.69) OBJ0214 Statutory SG Anstey

• Economics ID191 • Land use

OBJ0215 Statutory D Colley

REVISED M4CAN objections schedule of evidence.xlsm 33 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Economics Modification 30 • Environment • Land use • Noise and vibration • Air quality

OBJ0216 Statutory Mr Derek Trevor David

• Economics Julia Tindale WG 1.10.1 (Paragraphs 8.36-8.41) • Land use Ben Sibert WG 1.5.1 (Paragraph 5.83-5.88) Barry Woodman WG 1.6.1 (Paragraphs 10.82)

Huw Richard OBJ0217 Statutory Brenda Kathleen

• Land use • Environment • Noise and vibration

OBJ0218 Statutory W.T German Withdrawn

• Land use Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Design Julia Tindale WG 1.10.1 (Paragraph 8.43) Ben Sibert WG 1.5.1 (Paragraph 5.90-5.95) Peter Ireland WG 1.7.1 (Paragraph 10.28)

OBJ0219 Statutory Exectors of DG Harris

• Land use Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Design Julia Tindale WG 1.10.1 (Paragraph 8.44) Ben Sibert WG 1.5.1 (Paragraph 5.96-5.100) Peter Ireland WG 1.7.1 (Paragraph 10.29) OBJ0220 Statutory M.D.W Hazell

• Land use Peter Griffiths OBJ0221 Statutory Withdrawn Deborah Jane Howells

• Environment Peter Ireland WG1.7.1 (Chapter 9) • Land use Document 2.3.2 (Chapters 3 and 18) OBJ0222 B.G James

REVISED M4CAN objections schedule of evidence.xlsm 34 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Land use Barry Woodman WG 1.6.1 (Paragraphs 10.82) Julia Tindale WG 1.10.1 (Paragraph 8.45-8.47) Ben Sibert WG 1.5.1 (Paragraph 5.102-106) Peter Ireland WG 1.7.1 (Paragraphs 10.30)

OBJ0223 Statutory David Howard James

Trustees of • Land use Barry Woodman WG 1.6.1 (Paragraphs 10.82) Ben Sibert WG 1.5.1 (Paragraph 5.107-5.112) FH James Peter Ireland WG 1.7.1 (Paragraphs 10.31-10.33) Joyce Doubleday Frank Jones Diane Price OBJ0224 Statutory Heather Richards Kathleen Harris Rosemary Ballard Janet Corbett Judith Parry Trustees of FH James Partnership • Economics Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Environment Julia Tindale WG 1.10.1 (Paragraph 8.48-49) • Land use Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & 10.3.4-10.3.5) Ben Sibert WG 1.5.1 (Paragraph 5.113-5.117) OBJ0225 Statutory R.M Jenkins Peter Ireland WG 1.7.1 (Paragraphs 10.34 & 11.24- 11.30)

REVISED M4CAN objections schedule of evidence.xlsm 35 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Economics • Land use

OBJ0226 Statutory C.W Jones Withdrawn

• Economics WG/REB/OBJ0277 - New Park Farm • Environment • Land use • Noise and vibration • Air quality • Economics • Water quality

Roger Jones Gillian OBJ0227 Statutory Kate Matthew Rhiannon

• Economics PID191 • Design Julia Tindale WG 1.10.1 (Paragraph 8.59-8.62) • Land use Ben Sibert WG 1.5.1 (Paragraph 5.129-5.135) Barry Woodman WG 1.6.1 (Paragraphs 10.8-10.11)

OBJ0228 Statutory William David Jones

REVISED M4CAN objections schedule of evidence.xlsm 36 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Land use Michael Bull WG 1.12.1 (Chapter 3 & paragraph 5-5.5) Julia Tindale WG 1.10.1 (Paragraph 8.118-8.119) Ben Sibert WG 1.5.1 (Paragraph 5.136-5.140) Peter Ireland WG 1.7.1 (Paragraphs 11.40-11.46) OBJ0229 Statutory John & Joan

• Economics Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Environment Julia Tindale WG 1.10.1 (Paragraph 8.63-8.65) Philip Evans WG 1.14.1 (Paragraphs 4.8.1 - 4.8.9 & 10.3.4-10.3.5) OBJ0230 Statutory Laura Neville Ben Sibert WG 1.5.1 (Paragraph 5.141-5.146) Peter Ireland WG 1.7.1 (Paragraphs 10.38 & 11.47- 11.53)

• Land use PID191 • Economics WG/REB/OBJ0231 - Mr N S Park

Nicholas Simon Park

Alicia Sarah OBJ0231 Statutory Sophie Rebecca Verity Lydia Adam Brandon

REVISED M4CAN objections schedule of evidence.xlsm 37 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Economics PID191 • Environment WG/REB/OBJ233 - Phillips PIQ/117 Julia Tindale WG 1.10.1 (Paragraph 8.69-8.76) Ben Sibert WG 1.5.1 (Paragraph 5.151-5.154) Peter Ireland WG 1.7.1 (Paragraphs 11.54-11.61)

Christine Margaret OBJ0232 Statutory Phillips

• Economics PID191 • Land use WG/REB/OBJ0233 - Mr S C Phillips • Environment PIQ/112 • Flood consequence assessment PIQ/117

Stephen Charles OBJ0233 Statutory Phillips

• Environment Barry Woodman WG 1.6.1 (Paragraphs 10.2 & 5.8-5.10 • Construction & 5.16-5.19) OBJ0234 J W

REVISED M4CAN objections schedule of evidence.xlsm 38 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Economics PID191 • Land use WG/REB/OBJ0235 - Mr L Pritchard - The Beeches

Llewellyn Morgan OBJ0235 Statutory Pritchard

• Economics Julia Tindale WG 1.10.1 (Paragraph 8.81) • Environment Ben Sibert WG 1.5.1 (Paragraph 5.172-5.176) • Land use Peter Ireland WG 1.7.1 (Paragraphs 10.43 & 11.66- 11.67)

OBJ0236 Statutory William Reece

• Economics Julia Tindale WG 1.10.1 (Paragraph 8.69-8.76) • Land use Ben Sibert WG 1.5.1 (Paragraph 5.163-5.166) • Environment OBJ0237 Statutory Jane Renton

• Land use Julia Tindale WG 1.10.1 (Paragraph 8.82-8.84) • Economics Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & • Land use 10.3.4-10.3.5) Ben Sibert WG 1.5.1 (Paragraph 5.177-5.181) Barry Woodman WG 1.6.1 (Paragraphs 10.2 & 5.8-5.10 & 5.16-5.19 & 10.82) OBJ0238 Statutory Arthur George

• Land use Ben Sibert WG 1.5.1 (Paragraph 5.182-5.184)

Messrs. J.J. & A.D. OBJ0239 Statutory Turner & Sons

REVISED M4CAN objections schedule of evidence.xlsm 39 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Land use Barry Woodman WG 1.6.1 (Paragraphs 10.82) OBJ0240 Statutory Alan James Ben Sibert WG 1.5.1 (Paragraphs 5.185-5.190) Peter Ireland WG 1.7.1 (Paragraph 10.44) • Economics PID191 • Environment Barry Woodman WG 1.6.1 (Paragraphs 10.82) • Land use Michael Bull WG 1.12.1 (Paragraph 11.1) • Air quality Julia Tindale WG 1.10.1 (Paragraph 8.85-90) • Noise and vibration Ben Sibert WG 1.5.1 (Paragraph 5.191-5.197) OBJ0241 Statutory Lyndon James Peter Ireland WG 1.7.1 (Paragraphs 11.68-11.69)

• Ecology and nature conservation • Noise and vibration • Air quality • Environment • Consultation • Traffic OBJ0242 William Withdrawn • Economics • Port Economics • Alternatives

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Traffic 4.9.16 & 6.3.5-6.3.7) • Economics Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Alternatives Mitigation Strategy. Keith Jones WG 1.18 • Air quality Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - Newport Friends of the • Sustainable development 4.9) OBJ0243 Earth Matthew Jones WG 1.1.1 (Chapter 9, 13, 22.18, 22.19- Dave 26 & 13 & paragraphs 22.28-22.30) Ben Sibert WG 1.5.1 (Paragraph 4.124-4.127) Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) Rebuttal - WG/REB/OBJ0125 - Friends of the Earth

• Sustainable development Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Ecology and nature conservation 4.9.16 & 6.3.5-6.3.7) • Landscape Nicholas Rowson WG1.8.1 • Alternatives Matthew Jones WG 1.1 (Chapter 9 & paragraph 22.18 & 3.18-20 & 22.28-22.30 & 22.39-22.40) Document 4.7.2 WG/REB/OBJ0247 OBJ0244 Rebecca

REVISED M4CAN objections schedule of evidence.xlsm 40 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Sustainable development WG/REB/OBJ0030 ‐ RSPB • Flooding • Ecology and nature conservation • Ecology ‐ ornithology • Alternatives • Sustainable development

RSPB Cymru OBJ0245 Simon

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) Matthew Jones WG 1.1.1 (Chapter 9 and Paragraph OBJ0246 Lynda 3.18-20) Document 4.7.2 WG/REB/OBJ0247 • Noise & vibration WG/REB/OBJ0247-BS - Engineering Evidence • Air quality WG/REB/OBJ0247-SB - Economics Evidence • Sustainable development WG/REB/OBJ0247-MJ - Chief Evidence • Traffic WG/REB/OBJ0247-JD - Planning Evidence • Alternatives WG/REB/OBJ0247-BW - Traffic Evidence • Economics WG/REB/OBJ0247 - BW - Traffic Evidence part 2 • Health Impact Assessment WG/REB/OBJ0247-PI - Environmental Evidence • Land use, community & recreation PIQ/092 Cycling UK ID/066 OBJ0247 Hugh ID/073 ID/092 WG/REB/OBJ0247 ID/210 WG/REB/OBJ0247-4 PIQ/162

REVISED M4CAN objections schedule of evidence.xlsm 41 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1- • Economics 4.9.16 & 6.3.5-6.3.7) • Traffic Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Air quality Mitigation Strategy. • Carbon Matthew Jones WG 1.1.1 (Paragraph 22.18 & 3.18-20 • Noise & vibration & 22.28-22.30 & 22.33-22.36) • Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1- • Sustainable development 4.9) Philip Evans WG 1.14.1 (Chapter 8) OBJ0248 Matthew Jones WG 1.1.1 (Chapter 9) Document 4.7.2 WG/REB/OBJ0247

• Noise and vibration Philip Evans WG 1.14.1 (Chapter 8) • Air quality Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - OBJ0249 Mrs Kitcatt • Ecology and nature conservation 4.9.16 & 6.3.5-6.3.7) • Landscape Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4)

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Flooding 4.9.16 & 6.3.5-6.3.7) OBJ0250 Ruth Watkins Michael Vaughan WG 1.17.1 (Paragragh 5.15-5.38) Philip Evans WG 1.14 (Chapter 8) • Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Economics Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0251 Julia Shaw Mitigation Strategy. Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Paragraph 22.27) • Ecology and nature conservation WG/REB/OBJ0252 - Carole Jacob • Land use ID/073 • Alternatives WG/REB/OBJ0247 Torfaen Friends of the OBJ0252 Earth Carole Jacob

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) OBJ0253 Tom Rugg Matthew Jones WG 1.1.1 (Paragraphs 22.28-22.30) Documents 4.1-4.7

• General OBJ0254 Nick & Rebecca Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 42 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16, 4.2.60-64 & 6.3.5-6.3.7) • Sustainable development Matthew Jones WG 1.1.1 (Paragraphs 22.39-22.40 and • Ecology ‐ water vole Chapter 23) John Davies WG 1.23 Jon Davies WG 1.19

OBJ0255 Richard Pearcy

• Land use OBJ0256 Statutory Keith & Jane Withdrawn • Land use Paul & Karen • Construction OBJ0257 Statutory Withdrawn Clatworthy

• Air quality • Carbon Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Traffic Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Economics Mitigation Strategy. Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1-4.9.16 & 6.3.5-6.3.7) OBJ0258 Steve Rawlings • Alternatives Matthew Jones WG 1.1 (Chapter 9, 13 & 22.19-22.26 and Paragraph 3.18-20 & 22.28-22.30 & 22.33-22.36) Document 4.7.2 WG/REB/OBJ0247

• Economics Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26 & • Alternatives 22.28-22.30) OBJ0259 Mae Holland • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - 4.9)

• Ecology and nature conservation WG/REB/OBJ0270 - Gwent Wildlife Trust Wildlife Trust Wales OBJ0260 PIQ/08 James Byrne • Air quality Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- OBJ0261 David Wall • Economics 4.9.16 & 6.3.5-6.3.7) Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Economics Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26 • Environment and Paragraph 3.18-20) OBJ0262 D & C • Alternatives Peter Ireland WG1.7 Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 43 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Sustainable development 4.9.16 & 6.3.5-6.3.7) • Alternatives Matthew Jones WG 1.1.1 (Chapter 9, 13 & 22.19-22.26 and Paragraph 22.18 & 3.18-20 & 22.28-22.30) Document 4.7.2 WG/REB/OBJ0247

OBJ0263 Karen Maddock‐Jones

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Economics 4.9.16 & 6.3.5-6.3.7) • Traffic Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Alternatives Mitigation Strategy. OBJ0264 Andrew Gainsbury Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) Matthew Jones WG 1.1.1 (Paragraph 3.18-20 and Chapter 13 & 22.19-22.26) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Matthew Jones WG 1.1.1 (Chapter 9, 13 & 22.19-22.26 • Sustainable development & 22.28-22.30) • Economics Keith Jones WG1.18.1 (Chapter 4.11) OBJ0265 Dr Joanna Stafford • Alternatives

• Alternatives WG/REB/)BJ0266 - Louise Davies • Traffic. WG/REB/)BJ0266 - Supplementary - Louise Davies • Environment WG/REB/OBJ0247 OBJ0266 Louise Davies • Ecology and nature conservation

Buglife ‐ the • Ecology and nature conservation Keith Jones WG 1.18.1 (Paragraphs 7.6.57-7.6.70) Invertebrate Rebuttal WG-REB-OBJ0270.13 - Lindi Rich OBJ0267 Conservation Trust Alice Farr

REVISED M4CAN objections schedule of evidence.xlsm 44 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment WG/REB/OBJ0268.2 - Elizabeth Halliwell • Ecology and nature conservation WG/REB/OBJ0268.4 - Jean Matthews • Flooding WG/REB/OBJ0268.5 - Jessica Poole WG/REB/OBJ0268.6 - Purnell PIQ/06 PIQ/093 PIQ/094 PIQ/095 PIQ/098 ID/048 (Statement of Common Ground) ID/049 ID/053 (Statement of Common Ground) Natural Resources ID/055 OBJ0268 Statutory Wales ID/056 John Hogg ID/058 ID/060 ID/061 (Statement of Common Ground) ID/087 ID/185 ID/192 ID/233 ID/236 ID/244 ID/254

• Environment Michael Bull WG 1.12.1 (Chapter 3) • Air quality Documents 4.1 - 4.7 OBJ0269 Alison Thomas • Alternatives

• Consultation WG-REB-OBJ0270.1 - Prof Marsden • Ecology and nature conservation WG-REB-OBJ0270.2 - Prof Calvin Jones • Environment WG-REB-OBJ0270.2 – Prof Calvin Jones Addendum • Traffic WG-REB-OBJ0270.3 – Prof John Whitelegg • Economics WG-REB-OBJ0270.4 - Prof Kevin Anderson • Sustainable development WG-REB-OBJ0270.4 - Errata to Rebuttal to Prof Kevin Anderson WG-REB-OBJ0270.5 - Prof Lorrain Whitmarsh WG-REB-OBJ0270.6 – Prof John Altringham WG-REB-OBJ0270.6 - Prof John Altringham Addendum WG-REB-OBJ0270.7 – David Boyce WG-REB-OBJ0270.8 - Richard Bakere Gwent Wildlife Trust OBJ0270 Statutory WG-REB-OBJ0270.11 - Geoff Liles Ian Rappel WG-REB-OBJ0270.11 - Geoff Liles Erratum WG-REB-OBJ0270.12 - Prof John Lawton WG-REB-OBJ0270.13 - Lindi Rich WG-REB-OBJ0270.14 - Neil Ward WG-REB-OBJ0270.15 – Mike Webb WG-REB-OBJ0270.17 - Iolo Williams PIQ/055 ID/051 ID/068 ID/073 WG/REB/OBJ0270-18 WG/REB/OBJ0270-19 WG/REB/OBJ0270-20 WG/REB/OBJ0270-21 GWT Ecology and nature conservation

The Woodland Trust OBJ0271 WG/REB/OBJ0271 - Woodland Trust Jack

REVISED M4CAN objections schedule of evidence.xlsm 45 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Alternatives • Noise and vibration • Air quality • Ecology and nature conservation OBJ0272 Gavin Withdrawn

• Land use Ben Sibert WG1.5.1 (Paragraphs 4.217-8 Julia Tindale WG1.10.1 (Paragraphs 8.59-62)

OBJ0273 Statutory Claire Rose

• Environment OBJ0274 Barbara Hancock • Ecology and nature conservation Withdrawn • Alternatives • Environment Keith Jones WG 1.18.1 (Chapter 4.11, 5 and Paragraph • Ecology and nature conservation 4.9.1-4.9.16 & 6.3.5-6.3.7) • Air quality Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Carbon Mitigation Strategy. • Sustainable development Matthew Jones WG 1.1.1 (Chapter 9) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- 22.36 & 22.41) Campaign for Better Document 4.7.2 OBJ0275 Transport WG/REB/OBJ0247 Bridget Fox

• Air quality Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & • Noise and vibration 10.3.4-10.3.5) • Contamination Andy Clifton WG 1.11.1 (Paragraphs 6.16-6.18) Anthony & Catherine OBJ0276 • Economics Venn • Alternatives

• Environment Keith Jones WG1.18 • Ecology ‐ water voles. Jon Davies WG1.19 OBJ0277 Charlotte Jones Peter Ireland 1.7.1 Chapter 10

• Air quality Michael Bull WG 1.12.1 (Chapter 3) OBJ0278 Amanda Hurst

• Ecology Barry Woodman WG 1.6.1 (Paragraphs 10.2 & 5.8-5.10 • Environment & 5.16-5.19 & 10.13-10.20) OBJ0279 Mark Cottrell • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Peter Ireland 1.7.1

• Ecology ‐ Ornithology Simon Zisman WG 1.21 OBJ0280 Darryl Spittle

REVISED M4CAN objections schedule of evidence.xlsm 46 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Landscape Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) OBJ0281 Jane Brookes • Air quality Philip Evans WG 1.14.1 (Chapter 8) • Noise and vibration

• Ecology and Nature Conservation WG/REB/OBJ0270 - Gwent Wildlife Trust • Sustainable development WG/REB/OBJ0247 • Alternatives • Air Quality • Noise and vibration • Cultural heritage

Gwent Wildlife OBJ0282 Campiagn

• Traffic • Alternatives • Sustainable development • Economics

Cardiff County Council OBJ0283 Withdrawn Andrew

REVISED M4CAN objections schedule of evidence.xlsm 47 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Alternatives Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Sustainable development 4.9.16 & 6.3.5-6.3.7) • Economics Matthew Jones WG 1.1.1 (Chapter 9 and Paragraph 22.18 & 3.18-20 & 22.27-22.30 & 22.39-22.40) John Davies WG1.23) OBJ0284 Elizabeth Thomas Document 4.7.2 WG/REB/OBJ0247

• Alternatives Matthew Jones WG 1.1.1 (Chapter 9, 13 & 22.19-22.26) • Traffic Matthew Jones WG 1.1.1 (Chapter 13) • Economics Bryan Whittaker WG 1.2.6 • Shipping, Port Economics Stephen Bussell WG1.3.5 (Paragraphs 3.3.8-3.3.10) • Environment Keith Jones WG 1.18.1 (paragraph 4.18.6) • Ecology and nature conservation Michael Bull WG 1.12.1 • Noise and vibration Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Air quality Philip Evans WG 1.14.1 (Chapter 8) • Landscape OBJ0285 Statutory Barbara & James Ward

• Noise and vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Air quality Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Ecology and nature conservation Mitigation Strategy. Keith Jones WG 1.18.1 (Chapter 5 • Economics and Paragraph 4.9.1-4.9.16 & 6.3.5-6.3.7) OBJ0286 John H & Mrs P Price • Alternatives Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.27) • Cultural heritage • Economics

• Alternatives WG/REB/OBJ0287 - Mr & Mrs Wynton • Traffic PIQ/096 • Noise and vibration PIQ/100 OBJ0287 Graham B Wynton

• Traffic Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1 - • Alternatives 4.9) • Air quality Matthew Jones WG 1.1.1 (Chapter 9 and Paragraph • Sustainable development 22.18 & 3.18-20 & 22.28-22.30) Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0288 D Jones John Davies WG1.23 Document 4.7.2 WG/REB/OBJ0247

OBJ0289 Statutory Air Products Ltd • Land use Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 48 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.4-5.4.3) • Noise and vibration Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Alternatives 4.9.16 & 6.3.5-6.3.7) • Economics Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) OBJ0290 E M Allan • Traffic Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Matthew Jones WG 1.1.1 (Chapter 9, 13 & 22.19-22.26 & 22.28-22.30) Nicholas Rawson 1.8.1 (Paragraph 5.2-5.2.4)

• Land use WG/REB/OBJ0031 - ABP • Shipping WG/REB/OBJ0291 Orign Uk Operations OBJ0291 Statutory ID/232 Ltd

• Design WG/REB/OBJ0026 - Rebuttal to Simon Turl • Sustainable development WG/REB/OBJ0026 - Rebuttal to Mke Axon - by Dr P • Environment Ireland • Economics WG/REB/OBJ0026 - Rebuttal to Mike Axon - by Bryan • Traffic Whittaker • Alternatives WG/REB/OBJ0026 ; OBJ0292 BWo Rebuttal - Roadchef & Rontec - Construction WG/REB/OBJ0026 ; OBJ0292 Bwo Erratum Rebuttal - Roadchef & Rontec - Construction WG/REB/OBJ0026 ; OBJ0292 JD Rebuttal - Roadchef & Rontec - Planning WG/REB/OBJ0026 ; OBJ0292 MJ Rebuttal - Roadchef & Rontec - Decision Making and Policy Statutory Rontec Roadside retail OBJ0292 WG/REB/OBJ0026 ; OBJ0292 SB Rebuttal - Roadchef & Rontec - Economics WG/REB/OBJ0026 ; OBJ0292 SB Supplementary Rebuttal - Roadchef & Rontec - Economics WG/REB/OBJ0026 ; OBJ0292 BS Rebuttal - Roadchef & Rontec - Engineering ID/078 ID/089 ID/091

• Economics Matthew Jones WG1.1.1 (Chapter 24) • Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Environment Mitigation Strategy. Keith Jones WG 1.18.1 (Chapter 5 • Noise and vibration and Paragraph 4.9.1-4.9.16 & 6.3.5-6.3.7) Nicholas Rowson 1.8.1 (Paragraph 5.3-5.3.5) OBJ0293 P McCann • Alternatives Philip Evans WG 1.14.1 (Chapter 8)

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Air quality 4.9.16 & 6.3.5-6.3.7) • Noise and vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) • Alternatives Philip Evans WG 1.14.1 (Chapter 8) OBJ0294 Peter Hall Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 49 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and nature conservation Keith Jones WG 1.18.1 (Chapter 5 and Paragraph 4.9.1 - • Consultation 4.9.16 & 6.3.5-6.3.7) • Alternatives Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Sustainable development Mitigation Strategy. Keith Jones WG 1.18 Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.33- OBJ0295 TJ Russell 22.36) Richard Graham WG 1.15.1 (Paragraphs 11.2-11.22) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Keith Jones WG1.18.1 (Chapter 4.11) • Alternatives Matthew Jones WG 1.1.1 (Paragraphs 3.18-20 and • Flood consequences assessment Chapter 23) Elizabeth and Nigel OBJ0296 • Sustainable development PIQ/78 Cann ID/100 Document 4.7.2 WG/REB/OBJ0247 • Sustainable development WG/REB/OBJ0297 - Gwent Ornithological Society • Consultation WG/REB/OBJ0247 Gwent Ornithological • Ecology ‐ birds OBJ0297 Society • Alternatives Trevor Russell

• Ecology ‐ Bats Rebuttal - NRW (Jean Elizabeth Matthews, Bats) Richard Green WG 1.20.1 (Paragraphs 7.8.1-7.8.16)

Bat Conservation Trust OBJ0298 Steve Lucas

• Environment Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Ecology and nature conservation Mitigation Strategy. Keith Jones WG 1.18 (Chapter 5 • Port Economics, Shipping and Paragraph 4.9.1-4.9.16 & 6.3.5-6.3.7) • Noise and vibration Michael Bull WG 1.12.1 (Chapter 3 & paragraph 6-6.8) OBJ0299 Nicholas Vittle • Air quality Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & • Economics 10.3.4-10.3.5) Andrew Meaney WG1.4

• Alternatives Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) • Noise and vibration Philip Evans WG 1.14 (Chapter 8) • Air quality Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Ecology and nature conservation Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.27) OBJ0300 Gleanda Lowe • Economics Stephen Bussell WG 1.3 • Traffic

• Land use Ashtenne (AIF) LTD & Ashtenne Industrial OBJ0301 Statutory Withdrawn Fund Nominee No 1 Ltd

REVISED M4CAN objections schedule of evidence.xlsm 50 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Land use WG/REB/OBJ0031 - ABP WE Dowds Shipping WG/REB/OBJ0302 – W E Dowds (Shipping) Ltd. OBJ0302 Statutory Ltd ID/246

• Land use ID/229

Western Power OBJ0303 Statutory Distribution Withdrawn G Strongman

• Land use ID/229

Surf Telecoms Limited OBJ0304 Statutory Withdrawn Andrew Baker

REVISED M4CAN objections schedule of evidence.xlsm 51 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Barry Woodman WG 1.6.1 (Paragraphs 10.27-10.29) • Economics Ben Sibert WG 1.5.1 (Paragraph 5.210-5.213) • Land use Matthew Jones WG1.1.1 (Chapter 24) • Human Rights

OBJ0305 Statutory Hanson Uk

• Land use

Royal Ordnance (Crown Service) OBJ0306 Statutory Withdrawn Pension Scheme Trustees Limited

• Ecology and nature conservation • Economics • Traffic WG/REB/OBJ0307 - Ellen Law • Carbon WG/REB/OBJ0247 • Alternatives • Sustainable development OBJ0307 Miss Ellen Law

• Land use WG/REB/OBJ0308 - Liberty Steel Liberty Steel Newport OBJ0308 Statutory Limited Withdrawn Richard Steed • Consultation Matthew Jones WG1.1.1 (Chapter 24) • Environment Matthew Jones WG 1.1.1 Paragraph 22.27 • Economics Matthew Jones WG 1.1.1 • Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- 4.9.16 & 6.3.5-6.3.7) OBJ0309 Catherine Baker • Alternatives Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy. Document 4.7.2 WG/REB/OBJ0247

REVISED M4CAN objections schedule of evidence.xlsm 52 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Economics Stephen Bussell WG1.3 • Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Sustainable development 4.9.16 & 6.3.5-6.3.7) • Traffic Matthew Jones WG 1.1.1 (Chapters 9, 13, 19 & 22) • Alternatives Matthew Jones WG 1.1.6 • Consulation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Flood consequences assessment Mitigation Strategy. • Shipping, Port Economics Michael Vaughan WG 1.17.1 (Paragragh 5.5-5.14 & • Design 5.46-5.58) OBJ0310 Andrea Rodley Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & 5) Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1-4.1.9 & 9.6.1-9.6.8)

• Alternatives Matthew Jones WG1.1.1 (Chapter 24) • Environment Matthew Jones WG1.1.1 (Chapter 24) • Economics Matthew Jones WG 1.1.1 Paragraph 22.27 • Ecology and nature conservation Matthew Jones WG 1.1.1 • Alternatives Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- OBJ0311 Dr Mario Bisi 4.9.16 & 6.3.5-6.3.7) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy. Document 4.7.2 WG/REB/OBJ0247

• Land use Ben Sibert WG 1.5.1 (Paragraph 5.278-5.284) Matthew Jones WG1.1.1 (Chapter 19) OBJ0312 Statutory CJN Engineering Ltd WG/REB/OBJ0031 - ABP WG/REB/OBJ0312 • Land use Ben Sibert WG 1.5.1 (Paragraph 5.285-5.291) Jewson Ltd & Saint Jonathan Vine WG 1.22.1 (Paragraphs 8.3.1-8.3.9) OBJ0313 Statutory Gobain Building WG/REB/OBJ0031 - ABP Distribution Limited WG/REB/OBJ0313

REVISED M4CAN objections schedule of evidence.xlsm 53 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Landuse, community and recreation WG/REB/OBJ0150 - Magor and Undy Community • Sustainable development Council • Alternatives ID/090 • Economics WG/REB/OBJ0247 • Enviroment • Ecology and nature conservation • Flood consequence assessment • Traffic • Carbon

Magor with Undy OBJ0314 Statutory Community Council Berverly Cawley

• Environment Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Shipping, Port economics Mitigation Strategy. • Economics Philip Evans WG 1.14 (Chapter 8) Keith Jones WG OBJ0315 Statutory Carol & Allan Beer • Alternatives 1.18 Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 WG/REB/OBJ0247

Bulk hauliers UK & • Port Economics Ben Sibert WG 1.5.1 (Paragraph 5.292-5.298) OBJ0316 Statutory Europe • Design Matthew Jones WG1.1.1 (Chapter 19) Ronnie Evans WG/REB/OBJ0316 • Land use Ben Sibert WG 1.5.1 (Paragraph 5.224-5.227) Peter Ireland WG 1.7.1 (Paragraphs 10.47-10.48)

OBJ0317 Statutory Technoplan Anstalt

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Alternatives 4.9.16 & 6.3.5-6.3.7) •Traffic Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Landscape Mitigation Strategy. OBJ0318 Keith Williamson Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) Document 4.7.2

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Alternatives 4.9.16 & 6.3.5-6.3.7) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy. OBJ0319 Ursula Williams Keith Jones WG 1.18 Matthew Jones WG1.1.1 (Chapter 9) Document 4.7.2

REVISED M4CAN objections schedule of evidence.xlsm 54 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Ecology and Nature conservation Keith Jones WG1.18.1) Chapter 4.11)

OBJ0320 Helen Chambers

• Consultation

OBJ0321 Statutory Dwr Cymru Withdrawn

• Alternatives Julia Tindale WG 1.10.1 (Paragraph 8.91) • Land use Ben Sibert WG 1.5.1 (Paragraph 5.228-5.232) • Economics Barry Woodman WG 1.6.1 (Paragraphs 10.74-10.76 & • Construction 10.82) Matthew Jones WG1.1.1 (Chapter 24) Mark Williams Document 4.7.2 Mark Skinner OBJ0322 Statutory Mark Williams Pension Fund Clive Coulthard

• Environment Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Ecology and nature conservation 4.9.16 & 6.3.5-6.3.7) OBJ0323 Judith Cornish • Alternatives Matthew Jones WG 1.1 (Chapter 9 and Paragraphs 22.28-22.30)

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- 4.9.16 & 6.3.5-6.3.7) OBJ0324 Tony Unstead Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI Mitigation Strategy.

• Ecology and nature conservation Keith Jones WG1.18 OBJ0325 Mrs J K A Atkins • Landscape Nicholas Rowson WG1.8

• Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0326 Dr Steven Murray Mitigation Strategy. Keith Jones WG 1.18 • Environment Matthew Jones WG1.1.1 (Chapter 3) OBJ0327 Ro Douglas

• Sustainable development Matthew Jones WG 1.1 (Chapter 9 & 13 and Paragraph • Alternatives 22.27-22.30 & 22.39-22.40) • Ecology and nature conservation Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Economics Mitigation Strategy Keith Jones WG 1.18 John Davies WG1.23

OBJ0328 Colin R. Cheesman

REVISED M4CAN objections schedule of evidence.xlsm 55 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Land use WG/REB/OBJ0329 - Marshall's Marshalls Group WG/REB/OBJ0329 - Erratum to Marshall's Rebuttal OBJ0329 Statutory Andrew Johnson ID/216 WG/REB/OBJ0329-2 • Environment Barry Woodman WG 1.6.1 (Paragraphs 10.2-10.5, 10.8- • Noise and vibration 10.11 & 5.8-5.10 & 5.16-5.19) • Alternatives Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- • Carbon 22.30 & 22.33-22.36 and Chapter 9 Christopher & Wendy Phil Evans WG1.14 OBJ0330 Statutory Perkins Tim Chapman WG1.13 Document 4.7.2 WG/REB/OBJ0247

• Traffic Matthew Jones WG 1.1.1 (Paragraph 3.18-20) • Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Alternatives 4.9.16 & 6.3.5-6.3.7) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI OBJ0331 Graham Horder Mitigation Strategy. Keith Jones WG 1.18 Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) WG/REB/OBJ0247 • Ecology and nature conservation Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) • Cultural heritage Matthew Jones WG 1.1.1 (Paragraphs 22.33-22.36) • Traffic Michael Bull WG1.12 OBJ0332 Linda Moore • Environment Tim Chapman WG1.13 • Economics Document 4.7.2

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- OBJ0333 Gavin Harrison 4.9.16 & 6.3.5-6.3.7) Peter Ireland WG 1.7.1 (Paragraph 3.17) & SSSI • Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Alternatives 4.9.16 & 6.3.5-6.3.7) • Landscape Matthew Jones WG 1.1.1 (Paragraph 3.18-20) OBJ0334 James Hanning Nicholas Rowson 1.8.1 (Paragraph 5.2-5.2.4) Document 4.7.2 WG/REB/OBJ0247 • Ecology and nature conservation WG/REB/OBJ0335 - Tom Chinnick • Sustainable development • Economics OBJ0335 Thomas Chinnick • Alternatives • Carbon

• Ecology and nature conservation Keith Jones WG 1.18 (Chapter 5 and Paragraph 4.9.1- • Alternatives 4.9.16 & 6.3.5-6.3.7) OBJ0336 Francesca Shrapnel Matthew Jones WG 1.1.1 (Paragraph 3.18-20) Document 4.7.2 WG/REB/OBJ0247 • Noise and vibration Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & Fletcher Morgan 10.3.4-10.3.5) OBJ0337 Lorraine Nolan

• Economics Matthew Jones WG 1.1.1 (Chapter 13 & 22.19-22.26) • Traffic Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) OBJ0338 Mr David Cheseldine PID-43

REVISED M4CAN objections schedule of evidence.xlsm 56 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Environment Ben Sibert WG 1.5.1 (Paragraph 5.233-5.236) UK Health Care OBJ0339 Statutory Property 1 LLP

• Land Use Residual Lands Limited See Issue 008 OBJ0340 Statutory Withdrawn Nigel Phillips

CADW • Cultural heritage Statutory Withdrawn OBJ0341 Matthew Coward • Sustainable development WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0342 Steve Albaya Campaign ‐ Gwent Wildlife Trust

OBJ0343 David Allan Campaign ‐ Gwent Wildlife Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0344 Katherine Ruth Allen Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0345 Paul Anderton Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0030 - RSPB OBJ0346 Helen Arthur Campaign ‐ RSPB & Gwent Wildlife WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0347 Chris Avanti Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0348 Colin Balch Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0349 Katy Beddoe Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0350 A J Bennett Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0351 David Biddles Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0352 Sarah Binmore Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0353 Hannah Blackaby Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust

OBJ0354 Catherine Blundell Campaign ‐ Gwent Wildlife Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0355 Godfrey Bradshaw Campaign ‐ Gwent Wildlife & Woodland Trust WG/REB/OBJ0271 - Woodland Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0356 Wendy Brady Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0357 Tansy Branscombe Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0358 Keith Bucknall Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0359 Bryn Burgess Campaign ‐ Gwent Wildlife Trust

OBJ0360 Ian Burns Campaign ‐ Gwent Wildlife Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0361 Anita Burrett Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0362 Robert Campbell Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0363 Frances Cattanach Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0364 Tony & Linda Clark Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0365 Tim Colebrook Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0366 Alison Colebrook Campaign ‐ Gwent Wildlife Trust

REVISED M4CAN objections schedule of evidence.xlsm 57 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0367 Dr Richard Cowie Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0368 Alan Cripps Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0369 Miss Dawn Cromwell Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0370 Dr Rachael Daniels Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0371 Naomi Davis Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0372 Toity Deave Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0373 David Dewsbury Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0374 A Dillamore Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0375 Emily Downs Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0376 Ian Draycott Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0377 Richard Drew Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust Professor Brian I. OBJ0378 Campaign ‐ Gwent Wildlife Trust Duerden CBE,MD

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0379 Marilyn Dunkelman Campaign ‐ Gwent Wildlife Trust Same person as OBJ0141 OBJ0380 Barbara Dwyer Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0381 Ann Eggleton Campaign ‐ Gwent Wildlife Trust Same person as OBJ0029 OBJ0382 Chloe Elding Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0383 Susan Evans Campaign ‐ Gwent Wildlife Trust Same person as OBJ0186 OBJ0384 The Rhodes Family Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0385 Wayne Forster Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0386 David Gale Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0387 Kate Gibbs Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0388 Jane Gibson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0389 Mrs T E Green Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0390 Paul Greenfield Campaign ‐ Gwent Wildlife Trust

OBJ0391 Tom Grove Campaign ‐ Wildlife Trusts Wales Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0392 Coral Guppy Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0393 Clive Hamersley Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0394 Roy Harris Campaign ‐ Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0395 Chris Hatcher Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0396 Robin Hayward Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0397 John David Hopkin Campaign ‐ Gwent Wildlife Trust

REVISED M4CAN objections schedule of evidence.xlsm 58 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0398 Helen Houston Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0399 Jadwiga Howell Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0400 Lynne Howles Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0401 Sam Hughes Campaign ‐ Gwent Wildlife Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0402 Arwen Hutchings Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0403 Mrs Helen James Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0404 Gillian Johnson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0405 Nicola Johnson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0406 Lynn Astley Jones Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0407 Jenny Jones Campaign ‐ Gwent Wildlife & Woodland Trust WG/REB/OBJ0271 - Woodland Trust

Same person as OBJ0407 OBJ0408 Morris Jones Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0409 Audrey B Jones Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0410 Ceri Jones Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0411 Gary Jones Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0412 William Jutton Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0413 Andy Karren Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0414 Nigel Kempson Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0415 Paul Kinnersley Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0416 Bleddyn Lake Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0417 Jeanette Lawrenson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0418 Hilary Lee Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0419 Alicia Leow‐Dyke Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0420 Arwyn Lewis Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0421 Rachel Locke Campaign ‐ Gwent Wildlife Trust Same person as OBJ0194 OBJ0422 Ruth Lovell Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0423 Jane MacFarlane Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0424 Gwen Maggs Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0425 Alice Marlow Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0426 Clare Martin Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0427 JK Mason Campaign ‐ Gwent Wildlife Trust

REVISED M4CAN objections schedule of evidence.xlsm 59 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust Rosemary Mason and OBJ0428 Campaign ‐ Gwent Wildlife Trust Palle Uhd Jepsen

WG/REB/OBJ0270 - Gwent Wildlife Trust Vaughn Matthews MSc OBJ0429 Campaign ‐ Gwent Wildlife Trust ACIEEM WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0430 Victoria Matthewson Campaign ‐ Gwent Wildlife Trust

OBJ0431 Liz McBride Campaign ‐ Gwent Wildlife Withdrawn WG/REB/OBJ0030 - RSPB OBJ0432 Paul McCarthy Campaign ‐ RSPB & Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0433 Sean McHugh Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0434 Mary McMurran PhD Campaign ‐ Gwent Wildlife Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust Rachel & Julian OBJ0435 Campaign ‐ Gwent Wildlife Trust Merriman WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0436 Chris Metters Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0437 James Moore Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0438 Paul Morton Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0439 Annette Murray Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0440 Paul James Newton Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0441 Alison Nimmo Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0442 P J Nurse Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0443 Helen and Ian Okines Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0444 Elin Owen Campaign ‐ Gwent Wildlife Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust

Emily Parfitt‐Croydon OBJ0445 Campaign ‐ Gwent Wildlife Trust MA, BA (Joint Hons)

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0446 Andrew Parker Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0447 Jim Partington Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0448 Gillian Peace Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust Robert and Judy OBJ0449 Campaign ‐ Gwent Wildlife Trust Pemberton WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0450 Dr Sean Perkins Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0451 C M Pitman Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0452 Cyrene Powell Campaign ‐ Gwent Wildlife Trust

REVISED M4CAN objections schedule of evidence.xlsm 60 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust Emlyn and Jennifer OBJ0453 Campaign ‐ Gwent Wildlife Trust Powell WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0454 John Putman Campaign ‐ Gwent Wildlife Trust

OBJ0455 Martin Puzey Campaign ‐ Gwent Wildlife Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0456 Ella Grace Quincy Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0457 Ellen Quinton Campaign ‐ Gwent Wildlife Trust Same person as OBJ0191 OBJ0458 Alex Rhodes Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0459 David Richards Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0460 Lloyd Richards Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0461 Mrs Elaine Richardson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0462 Beth Roberts Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0463 Rebecca Robinson Campaign ‐ Gwent Wildlife Trust Same person as OBJ0198 OBJ0464 Steven Rogers Withdrawn

OBJ0465 Keith Roylance Campaign ‐ Wildlife Trust Wales & Woodland Trust Withdrawn

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0466 Roger Ruston Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0467 T. J. Sandles Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0468 Dr S P Satterthwaite Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0469 Angus Scott Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0470 Charles E Serafin Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust Miranda Seymour‐ OBJ0471 Campaign ‐ Gwent Wildlife Trust Smith Same person as OBJ0028 Dr Graham Small PhD OBJ0472 Withdrawn DLSHTM FRES MRQA

Jeremy Smith BSc WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0473 Campaign ‐ Gwent Wildlife Trust MRes WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0474 Chris Stott Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0475 Angela Swan Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0476 Sarah Symondson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0477 Elspeth Thomas Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0478 Tom Pitts Tucker Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0479 Helen Varney Campaign ‐ Gwent Wildlife & Woodland Trust WG/REB/OBJ0271 - Woodland Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0480 Gavin Vella Campaign ‐ Gwent Wildlife Trust

REVISED M4CAN objections schedule of evidence.xlsm 61 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust Jonathan Vining BSc OBJ0481 Campaign ‐ Gwent Wildlife Trust BArch MSc RIBA AoU

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0482 Christine Walby Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0483 Rebecca Ward Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0484 David Watkins Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0030 - RSPB OBJ0485 Kim Western Campaign ‐ RSPB & Gwent Wildlife WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0486 Dr Chris Williams Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0487 Frances Williams Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0488 Maggie Wilson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0489 Paul Wilson Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0490 Mr J Winder Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0491 Thomas Winstone Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust Georgia Witton‐ OBJ0492 Campaign ‐ Wildlife Trusts Wales Maclean WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0494 Jim Wright Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0495 R Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0496 Wendy Tyler Batt Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0497 Aline Denton Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0498 Margret Jones Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0499 Mrs Audrey Woodrow Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0500 Elaine Wright Campaign ‐ Gwent Wildlife Trust

OBJ0501 Susan Campbell Campaign ‐ Gwent Wildlife Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0502 Ian S Vicary Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0503 Francis Lewis Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0504 Philip Jones Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0506 Evan Hopkins Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0507 Barbara M Heys Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0508 Diana Clark Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0509 Sandra Forster Campaign ‐ Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0510 Jane Adams Campaign ‐ Wildlife Trusts Wales

OBJ0511 Ian Allen Campaign ‐ Wildlife Trusts Wales Withdrawn Same person as OBJ0168 OBJ0512 Saran Allott‐Davey Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 62 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0513 John Anderton Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0514 Malcolm Appleton Campaign ‐ Wildlife Trusts Wales Same person as OBJ0057 OBJ0515 Lin Ashcroft Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0516 Lynn Astley ‐Jones Campaign ‐ Wildlife Trusts Wales Same person as OBJ0160 OBJ0517 Nicola Balmforth Withdrawn WG/REB/OBJ0030 - RSPB OBJ0518 Ken Barker Campaign ‐ RSPB & Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0519 Phil Barnett Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0520 Enid Beckett Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0521 Nicholas Beswick Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0522 Haley Bowcock Campaign ‐ Wildlife Trusts Wales Same person as OBJ0355 OBJ0523 Mr Godfrey Bradshaw Withdrawn Same Person as OBJ0013 OBJ0524 Julian Branscombe Withdrawn Same Person as OBJ0166 OBJ0525 Dave Brassey Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0526 Mrs Laura Bray Campaign ‐ Wildlife Trusts Wales Same person as OBJ0061 OBJ0527 Chris Brown Withdrawn Same person as OBJ0085 OBJ0528 Mrs Ruth Brown Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0529 John Butler Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0530 Natalie Buttriss Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust James Byrne BSc, MSc, OBJ0531 Campaign ‐ Wildlife Trusts Wales CEnv, MCIEEM

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0532 Imogen Cavadino Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0533 Gillian Cawthorne Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0534 Karen Chadwick Campaign ‐ Wildlife Trusts Wales Same person as OBJ0066 OBJ0535 Rich Chandler Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0536 Donna Chinnick Campaign ‐ Wildlife Trusts Wales Same person as OBJ008 OBJ0537 A P Clark Withdrawn David and Stella Same person as OBJ0158 OBJ0538 Withdrawn Collard WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0539 Helen Collis Campaign ‐ Wildlife Trust Wales & Woodland Trust WG/REB/OBJ0271 - Woodland Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0540 Dr Michael Coogan Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0541 Sharon Cullen Campaign ‐ Wildlife Trusts Wales Same person as OBJ0542 OBJ0542 Ian Cummings withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 63 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0543 Lucy Curtis Campaign ‐ Wildlife Trusts Wales Same person as OBJ0037 OBJ0544 Susan Danziger Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0545 Kyleigh Davies Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0546 Joan Davies Campaign ‐ Wildlife Trust Wales & Woodland Trust WG/REB/OBJ0271 - Woodland Trust

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0547 Roger Davies Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0030 - RSPB OBJ0548 Rhys Davies Campaign ‐ RSPB & Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0030 - RSPB OBJ0549 Matt Davies Campaign ‐ RSPB & Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust Same person as OBJ0371 OBJ0550 Naomi Davies Withdrawn

OBJ0551 R L Davies Campaign ‐ Wildlife Trusts Wales Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0552 Bran Devey Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0553 Catrin Devonald Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0554 Anthea M. Dewhurst Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0555 Tim Dodman Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0556 Mrs Amy Doore Campaign ‐ Wildlife Trusts Wales Same person as OBJ0202 OBJ0557 Jane Doyle Withdrawn Same person as OBJ0178 OBJ0558 Ed Drewitt Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0559 Jon Dunkelman Campaign ‐ Wildlife Trusts Wales Same person as OBJ0102 OBJ0560 Margaret Durkin Withdrawn Same person as OBJ0029 OBJ0561 Chloe Elding Withdrawn Same person as OBJ0140 OBJ0562 Sue Emlyn‐Jones Withdrawn Same Person as OBJ0040 OBJ0563 Dr Huw Evans Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0564 John Evans Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0565 Rachel Evans Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0566 Rhian Evans Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0567 S Evans Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0568 Alice Fairnie Campaign ‐ Wildlife Trusts Wales Same person as OBJ0267 OBJ0569 Alice Farr Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0570 Sophie Faupel Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0571 C Field Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0572 M C Field Campaign ‐ Wildlife Trusts Wales Same person as OBJ0035 OBJ0573 Dick Finch Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 64 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0574 Roger & Sue Finn Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0575 C Furmage Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0576 L Furmage Campaign ‐ Wildlife Trusts Wales Same person as OBJ0171 OBJ0577 Peter Gardner Withdrawn Same person as OBJ0054 OBJ0578 Elizabeth Green Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0579 Andrew Green Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0580 Tim Green Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0581 Amy Green Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0582 Martin Griffett Campaign ‐ Wildlife Trusts Wales Same person as OBJ0391 OBJ0583 Tom Grove Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0584 Linda Grove Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0585 Robyn Guppy Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0586 Steve Hale Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0587 Miss Alice Hanning Campaign ‐ Wildlife Trusts Wales Same person as OBJ0129 OBJ0588 Judy Hanny Withdrawn Same person as OBJ0394 OBJ0589 Roy Harris Withdrawn

OBJ0590 Sue Harrison Campaign ‐ Wildlife Trusts Wales Withdrawn Same person as OBJ0138 OBJ0591 Andrea Hennessey Withdrawn WG/REB/OBJ0030 - RSPB OBJ0592 Ralph Hobbs Campaign ‐ RSPB & Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0030 - RSPB OBJ0593 Andy Hodge Campaign ‐ RSPB & Wildlife Trust Wales WG/REB/OBJ0270 - Gwent Wildlife Trust WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0594 Susan Hodgkinson Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0595 D C Hopkins Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0596 Samantha Horsburgh Campaign ‐ Wildlife Trusts Wales Same person as OBJ0398 OBJ0597 Helen Houston Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0598 Natalie Howard Campaign ‐ Wildlife Trusts Wales Same person as OBJ0089 OBJ0599 Robert K Hughes LRPS Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0600 Jayne Hunt Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0601 Dr Stephen Hussey Campaign ‐ Wildlife Trusts Wales Same person as OBJ0161 Kieron Huston BSc, OBJ0602 Withdrawn MSc, MCIEEM

OBJ0603 Pamela Ireland Campaign ‐ RSPB & Wildlife Trust Wales Withdrawn Same person as OBJ0105 OBJ0604 Mal Jenkins Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 65 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0605 Kelly‐Louise Jennings Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0606 Helen John Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0607 Tanya Johnson Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0608 Andrew Jones Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0609 Andrew Jones Campaign ‐ Wildlife Trusts Wales Same person as OBJ0156 OBJ0610 Dr Charlotte Jones Withdrawn Same person as OBJ0081 OBJ0611 Chris Jones Withdrawn

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0612 Elen Jones Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0613 Nicky Jones Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0614 David Jones Campaign ‐ Wildlife Trusts Wales Same person as OBJ0410 OBJ0615 Ceri Jones Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0616 Megan Jones Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0617 Robert Jones Parry Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0618 Chris Kelsey Campaign ‐ Wildlife Trusts Wales Same person as OBJ0414 RSPB Campaign OBJ0619 Nigel Kempson Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0620 Tom Killick Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0621 Sophie Lawrenson Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0622 Philip A. Leicester Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0623 Kerry Lewis Campaign ‐ Wildlife Trusts Wales Same person as OBJ0173 OBJ0624 James Loftus Withdrawn Same person as OBJ0175 OBJ0625 John Loftus Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0626 Dr David Lonsdale Campaign ‐ Wildlife Trusts Wales Same person as OBJ0177 OBJ0627 Helen Lyndon Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0628 Mark Lynn Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0629 Bill Mackie Campaign ‐ Wildlife Trusts Wales Same person as OBJ0263 OBJ0630 Karen Maddock‐Jones Withdrawn

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0631 Gwen Maggs Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0632 E.D Mantell Campaign ‐ Wildlife Trusts Wales Same person as OBJ0429 Gwent Wildlife Campaign OBJ0633 Vaughn matthews Withdrawn Same person as OBJ0058 OBJ0634 Mr Donal McCarthy Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 66 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0635 Mrs Ann McClean Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust Catherine C Mendez, OBJ0636 Campaign ‐ Wildlife Trusts Wales BA Hons, MEng Hons

Same person as OBJ0437 OBJ0637 James Moore Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0638 Mike Morris Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0639 Tessa Murray Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0640 Peter Neale Campaign ‐ Wildlife Trusts Wales Same person as OBJ0440 OBJ0641 Paul James Newton Withdrawn Same as OBJ0441 OBJ0642 Alison Nimmo Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0643 Rob Nottage Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0644 B O'Hara Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust Richard & Gillian OBJ0645 Campaign ‐ Wildlife Trusts Wales Osborne Same person as OBJ0445

Emily Parfitt‐Croydon OBJ0646 Withdrawn MA, BA (Joint Hons)

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0647 Howard Park Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0648 Mary Parker Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0649 Rosemary Parkhouse Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0650 Jim Partington Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0651 Catherine Pawson Campaign ‐ Wildlife Trusts Wales Same person as OBJ0064 OBJ0652 Mary Pearce Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0653 Abigail Pedlow Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0654 Barrie Peers Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0655 Philip Pell Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0656 Zelah Pengilley Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0657 Monica Peyton Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0658 Sarah Philpott Campaign ‐ Wildlife Trusts Wales Same person as OBJ0162 OBJ0659 Dr William Picton Withdrawn Same person as OBJ0203 OBJ0660 Ann Picton MBE Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0661 Chris Piddington Campaign ‐ Wildlife Trusts Wales

REVISED M4CAN objections schedule of evidence.xlsm 67 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0662 Megan Pitman Campaign ‐ Wildlife Trusts Wales Same person as OBJ0046 OBJ0663 Margaret Pobjoy Withdrawn Same person as OBJ0244 OBJ0664 Ms Rebecca Price Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0665 Julian Price Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0666 Sue Priestland Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0667 Ella Grace Quincy Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0668 Julie Rees Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0669 Michael Rees Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0670 Joanna Richards Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0671 Kevin Riddell Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0672 Christine Roberts Campaign ‐ Wildlife Trusts Wales Same person as OBJ0183 OBJ0673 Caroline Robertson Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0674 Bob Roome Campaign ‐ Wildlife Trusts Wales Same person as OBJ0465 OBJ0675 Keith Roylance Withdrawn Same person as OBJ0253 OBJ0676 Tom Rugg Withdrawn same person as OBJ0170 OBJ0677 Nick Saunders Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0678 Dr Deborah Sazer Campaign ‐ Wildlife Trusts Wales Same person as OBJ0159 Dr Ingo Schuder OBJ0679 Withdrawn MCIEEM

Same person as OBJ0163 OBJ0680 Amanda Sergeant Withdrawn Same parson as OBJ0471 Miranda Seymour‐ OBJ0681 Withdrawn Smith WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0682 Gaye Sheridan Campaign ‐ Wildlife Trusts Wales Same person as OBJ0067 OBJ0683 Wendy Smith Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0684 Christine Snape Campaign ‐ Wildlife Trusts Wales Same Person as OBJ0280 OBJ0685 Darryl Spittle Withdrawn Same Person as OBJ0075 OBJ0686 John Staton Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0687 Kath Stevens Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0688 Richard Stone Campaign ‐ Wildlife Trusts Wales Same person as OBJ0062 OBJ0689 Alison Stroud Withdrawn Same as OBJ475 OBJ0690 Angela Swan Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 68 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0691 Sarah Symondson Campaign ‐ Wildlife Trusts Wales Same person as OBJ0094 OBJ0692 D Caroline Syred Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0693 Dr Katherine Syred Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust Professor Nicholas OBJ0694 Campaign ‐ Wildlife Trusts Wales Syred WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0695 Andrea Thomas Campaign ‐ Wildlife Trusts Wales Same person as OBJ0477 OBJ0696 Elspeth Thomas Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0697 Marc Tippler Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0698 Julian Tubb Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0699 Brian Tubb Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0700 Norma Tubb Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0701 Diana Tyler Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0702 Stephanie Tyler Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0703 Andrew Urquhart Campaign ‐ Wildlife Trusts Wales Same person as OBJ0176 Dafydd Vaughn Lewis OBJ0704 BA, BSc, MBA, CBiol, Withdrawn FRSB, MCLIP

Same person as OBJ0482 OBJ0705 Christine Walby Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0706 Natalie Waller Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0707 ‐ Robert Waller WG/REB/OBJ0270 ‐ Gwent Wildlife Trust PIQ/071 Personal response in addition to a campaign response ‐ Wildlife Trust Wales PIQ/086 OBJ0707 Robert Waller • Traffic ID/073 • Alternatives ID/209 PIQ/156 and 156a (revised) WG/REB/OBJ0707‐2 Anne Warrell & Wayne Same person as OBJ0174 PIQ 156b i d OBJ0708 Withdrawn Smith WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0709 Gail Watkins Campaign ‐ Wildlife Trusts Wales Same person as OBJ0063 OBJ0710 Mary Watkins Withdrawn Same person as OBJ0250 OBJ0711 Dr Ruth Watkins Withdrawn Same person as OBJ0059 OBJ0712 Daniel Webb Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0713 Madeleine Wells Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0714 Jamie White Campaign ‐ Wildlife Trusts Wales same person as OBJ0155 OBJ0715 April Wiggins Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0716 Dr Lizzie Wilberforce Campaign ‐ Wildlife Trusts Wales

REVISED M4CAN objections schedule of evidence.xlsm 69 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0717 Anna Williams Campaign ‐ Wildlife Trusts Wales

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0718 Charlotte Williams Campaign ‐ Wildlife Trusts Wales Same person as OBJ0164 OBJ0719 Gareth Williams Withdrawn Same person as OBJ0027 OBJ0720 Gerrard Williams Withdrawn same person as OBJ0167 OBJ0721 Iolo Williams Withdrawn Same person as OBJ051 OBJ0722 Lindsay Williams Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0723 David Williams Campaign ‐ Wildlife Trusts Wales Same as OBJ0074 OBJ0724 Mrs Alison Willott WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0725 J Winder Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0726 Mel Witherden Campaign ‐ Wildlife Trusts Wales Same person as OBJ0492 Georgia Witton‐ OBJ0727 Withdrawn Maclean WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0728 Helen Wood Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0729 Ruth Wood Campaign ‐ Wildlife Trusts Wales WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0730 John Woodruff Campaign ‐ Wildlife Trusts Wales Same person as OBJ0020 OBJ0731 David Withdrawn WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ0732 C Campaign ‐ Wildlife Trusts Wales Same person as OBJ0729 OBJ0733 Ruth Wood Withdrawn OBJ0734 Roger Puxley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0735 Mrs Linda Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0736 Miss Glen Oconnell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Ms Emma Spurgin OBJ0737 Campaign ‐ RSPB Hussey WG/REB/OBJ0030 ‐ RSPB OBJ0738 Mr Stephen Inglis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0739 Miss Faye Munro Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0740 Mr Peter Etheridge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0741 Dr Douglas Stannard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0742 Mr John Gregory Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0743 Mrs Helen Cross Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0744 Mrs Janet Hyde Campaign ‐ RSPB OBJ0745 Mr Jeffrey Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0746 Mr David Jarrett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0747 Mr Nathan Tovey Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 70 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ0748 Mr Kristian Hallihan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0749 Mrs J Boardman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0750 Mr Bruce Moore Campaign ‐ RSPB Same person as OBJ0093 OBJ0751 Dr Steve Palmer Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0752 Dr Richard Miller Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0753 Mr Tom Delaney Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0754 Mr Tony Pritchard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0755 Miss Joy Roscoe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0756 Mr Jim Cunning Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0757 Mr Roy Rhodes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0758 Mr Ronald Kinrade Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0759 Ms Jean Tomlinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0760 Mrs Tracy Gould Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0761 Mr Michael Trew Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0762 Mr Richard Chew Campaign ‐ RSPB

OBJ0763 Mr Patrick Crowley Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0764 Mrs Angela Trew Campaign ‐ RSPB Mrs Michelle O'Neill‐ WG/REB/OBJ0030 ‐ RSPB OBJ0765 Campaign ‐ RSPB Kiddie Same person as OBJ0194 OBJ0766 Mr Rhys Aneurin Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0767 Miss Eleanor Morrison Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0768 Mr Andrew Barnett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0769 Mr Phillip Moore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0770 Mr Peter Newmark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0771 Mrs Valerie Mann Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0772 Mr Ken Maurice Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0773 Mr David Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Alexandra OBJ0774 Campaign ‐ RSPB Osborne WG/REB/OBJ0030 ‐ RSPB OBJ0776 Dr Timothy Maberly Campaign ‐ RSPB OBJ0777 Mr Tim Corke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0778 Mr Jonathan Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0779 Ms Catriona Gray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0780 Mr Peter Cartwright Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 71 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ0781 Dr Paul Gale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0782 Mr Andrew Bladon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0783 Mr Terence Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0784 Mr Gareth Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0785 Mr Joseph Marshall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0786 Mrs Susan Swift Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0787 Miss Kate Newman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0788 Mr Richard Hopkin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0789 Mr Colin Neale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0790 Miss Rebekah Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0791 Mr Martin Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0792 Mr Roger Dunn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0793 Mr Steve Howells Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0794 Dr Christine Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0795 Mr Neil Robinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0796 Mr James Bear Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0797 Mr Michael Rook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0798 Mr Paul Pearson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0799 Mr Philip Palmer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0800 Mr Richard Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0802 Mr Antony Pooles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0803 Mr Martin Kerby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0804 Mr Don Manhire Campaign ‐ RSPB OBJ0805 Mrs Jane Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0806 Mrs Rae Cecil Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0807 Miss Jill Abbott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0808 Ms Shusha Lamoon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0809 Mr Chris Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0810 Miss Kirsty Osman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0811 Ms Elaine Dunn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0812 Mr Michael Frost Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0813 Dr Jennifer Woodward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0814 Mr Michael Jones Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 72 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ0815 Al Reeve Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Elizabeth OBJ0816 Campaign ‐ RSPB Withdrawn Armstrong WG/REB/OBJ0030 ‐ RSPB OBJ0817 Miss Wayne Watkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0818 Mrs Elizabeth Ackroyd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0819 Ms Danielle Styles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0820 Mrs Rebecca Wade Campaign ‐ RSPB OBJ0821 Mrs Rita Carr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0822 Ms Jean Rainey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0823 Miss Evelyn Marshall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0824 Mr Edward Crabtree Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0825 Mr Brian Lancastle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0826 Mr Robert Hopson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0827 Miss Alice Groom Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0828 Mrs Julie Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0829 Mrs Elizabeth Cornish Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0830 Mr Mike Cleary Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0831 Mr Daniel Barrett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0832 Mr Anthony Newton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0833 Dr Chris Wooff Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0834 Mr David Carson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0835 Prof Oliver Watson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0836 Mr John Mackay Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0837 Mrs Lorna Fisher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0838 Mr Paul Coffman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0839 Mr David Pinner Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr & Mrs George and OBJ0840 Campaign ‐ RSPB Mary Fricker WG/REB/OBJ0030 ‐ RSPB OBJ0841 Mrs Sandra Bletchly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0842 Mr Nikolas Bertholdt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0843 Mr Kit Roskelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Emmeline OBJ0844 Campaign ‐ RSPB Hannelly WG/REB/OBJ0030 ‐ RSPB OBJ0845 Mr Stephen Oddy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0846 Mr Laurence Pearce Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 73 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ0847 Mr Jeffrey Hazell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0848 Mrs Paula Howarth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0849 Mr Adrian Jaques Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0850 Mrs Susan Mellon Campaign ‐ RSPB OBJ0851 Mr Ian Elphick Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0852 Miss Alice Kirk Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0853 Mr Michael Park Campaign ‐ RSPB same person as OBJ0091 OBJ0854 Mr Peter Moore Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0855 Mrs Barbara Loxley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0856 Mr Dennis Owen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0857 Mr Anthony Scoffield Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0858 Mrs Patricia Scoffield Campaign ‐ RSPB OBJ0859 Mr Ian Forsyth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0860 Mr Jeremy Moore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0861 Miss Eirian Edwards Campaign ‐ RSPB OBJ0862 Dr Tony Gillie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0863 Mr Joseph Fleming Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ0864 Mr Martin Unwin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0865 Mr Chris Moorhouse Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0866 Ms Emma Ordonez Campaign ‐ RSPB

OBJ0867 Mr David Lewis Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0868 Mrs Mandy Gothorp Campaign ‐ RSPB Mrs Dinah and Patrick WG/REB/OBJ0030 ‐ RSPB OBJ0869 Campaign ‐ RSPB Wise WG/REB/OBJ0030 ‐ RSPB OBJ0870 Dr Nigel G Harris Campaign ‐ RSPB OBJ0871 Ms Jo Fraser Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0872 Mr Edward Hutchings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0873 Mrs Julie Shaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0874 Mrs Gemma M Griffiths Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0875 Mrs Elaine Hunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0876 Mr Peter Wilkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0877 Mr David Carter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0878 Mr Alexander Stout Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0879 Mr Andrew Stott Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 74 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ0880 Mr Phill Robinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0881 Mrs Hazel Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0882 Mr Roger Milligan Campaign ‐ RSPB OBJ0883 Mr Tim Aske Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0884 Mr David Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0885 Mr Neal Moss Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0886 Mr Gordon Piper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0887 Dr Christopher Jeans Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ0888 Mrs Helen Rafferty Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0889 Mr Mike Brookes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0890 Mr Simon Murray Campaign ‐ RSPB

OBJ0891 Mr David Colls Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0892 Mr Jonathan Evans Campaign ‐ RSPB OBJ0893 Mr John Seal Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0894 Mr Roger Fickling Campaign ‐ RSPB Same person as OBJ05952 OBJ0895 Mr Ralph Hobbs Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0896 Mr Roger Gilbert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0897 Mr Michael Lindsey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0898 Mr Derek Antropik Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0899 Mr Chris Gooddie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0900 Mr Richard Marsh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0901 Mrs Ann Barratt Campaign ‐ RSPB Same person as OBJ0902 Campaign ‐ RSPB Withdrawn OBJ05952 C943:D956 OBJ0903 Ms Gill Finch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0904 Mr Peter Perrott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0905 Mr Leslie Etheridge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0906 Dr Stephen Preston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0907 Mr Dave Powner Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0908 Mr David Saunders Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0909 Miss Pat Armstrong Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0910 Mr Nigel Pleass Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0911 Mr Lee Marshall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0912 Mr Barrie English Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 75 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ0913 Miss Charlotte Perry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0914 Mr Darren Matthews Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0915 Mrs Susie Turnbull Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0916 Mr Peter Mellor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0917 Mr Richard Thomas Campaign ‐ RSPB

OBJ0918 Mr Roger Hoodless Campaign ‐ RSPB Withdrawn

OBJ0919 Mrs B Hutton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0920 Mr P Thomas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0921 Mrs Juliet Hambleton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0922 Mr Richard Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0923 Mr Geoff Smith Campaign ‐ RSPB Mrs Julia WG/REB/OBJ0030 ‐ RSPB OBJ0924 Campaign ‐ RSPB Wawrzynowicz WG/REB/OBJ0030 ‐ RSPB OBJ0925 Mr David Killon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0926 Mr John Lambert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0927 Mrs Georgia Eldridge Campaign ‐ RSPB

OBJ0928 Mrs Trudi Kettle Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0929 Mr Michael O'Brien Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0930 Miss Emma Charles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0931 Mr Michael Charles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0932 Mrs Vivienne Charles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0933 Mr Stephen Dransfield Campaign ‐ RSPB

OBJ0934 Mr Andrew Jayne Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0935 Miss Angela Kings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0936 Mrs Debra Hooper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0937 Mr Jamie Allen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0938 Mr Timothy Rowley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0939 Mr Steve Ashton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0940 Mr George Jacob Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0941 Ms Sarah Blake Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0942 Miss Patricia Loukes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0943 Mrs Elizabeth Butler Campaign ‐ RSPB Same person as OBJ0176 OBJ0944 Mr Dafydd Lewis Withdrawn

OBJ0945 Ms Karen Neill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 76 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ0946 Mr Stephen Ashby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0947 Mrs Viktoria Nealis Campaign ‐ RSPB OBJ0948 Mr Matt Prince Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0949 Mrs Jenny Wright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0950 Mr Thomas Barker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0951 Mrs Margaret Fishwick Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0952 Miss Llynn Thompson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0953 Dr Christine Farmer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0954 Mrs Heather Mills Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0955 Miss Alice Tribe Campaign ‐ RSPB OBJ0956 Mr Paul Braid Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0957 Mrs Deborah Bowditch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0958 Mr John Savery Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0959 Miss Alison Keedy Campaign ‐ RSPB Miss Gabrielle WG/REB/OBJ0030 ‐ RSPB OBJ0960 Campaign ‐ RSPB Cleghorn WG/REB/OBJ0030 ‐ RSPB OBJ0961 Mr Mike Welch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0962 Mr Dean Smith Campaign ‐ RSPB OBJ0963 Mr Kevin Ilsley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0964 Miss Patricia Kemp Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0965 Mrs Valerie Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0966 Mrs Margaret Dittmer Campaign ‐ RSPB OBJ0967 Mr Alan Parfitt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0968 Mr Peter Stilts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ0969 Mrs Julia McCord Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0970 Mr Robert Badcock Campaign ‐ RSPB OBJ0971 Mrs Fiona Yuill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0972 Mr Guy Lawrence Campaign ‐ RSPB OBJ0973 Mrs Liz Albert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0974 Mr Ernie Scales Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0975 Mr David Frost Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0976 Mrs Valerie Higgon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0977 Mrs Janet Piper Campaign ‐ RSPB OBJ0978 Mr Tim Barrett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0979 Mrs Shanti Srinivas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0980 Miss Lorraine Leicester Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 77 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ0981 Mr Roland Pitts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0982 Mrs Janet Burdon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0983 Mrs Sumi Olson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0984 Mr Kevin Bower Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0985 Mr Jonathan Jenkins Campaign ‐ RSPB OBJ0986 Mr Alan Petrie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0987 Mr Madoc Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0988 Mrs Irene Kettle Campaign ‐ RSPB OBJ0989 Mr Philip John Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0990 Mrs Diane Malpass Campaign ‐ RSPB OBJ0991 Dr M Parry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0992 Mr Andrew Keeble Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0993 Mrs Jane Corlett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0994 Miss Robert Hughes Campaign ‐ RSPB

OBJ0995 Mr Peter McSweeney Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ0996 Mr Richard Rees Campaign ‐ RSPB

OBJ0997 Mrs Heather Marshall Campaign ‐ RSPB Withdrawn

OBJ0998 Mr L Stallard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ0999 Miss Zoe McMillan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1000 Dr David G Sanger Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1001 Mrs Annette Hardy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1002 Mr Stephen Blow Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1003 Mr Maurice Hardy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1004 Ms Kay Mitchell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1005 Jeanette Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1006 Mrs Jill Nieuwenhuys Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1007 Miss Susanne Lane Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1008 Mr Robert Bish Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1009 Mr David Kemish Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1010 Mr David Preston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1011 Mrs Margaret Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1012 Mr Jonathan Angell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1013 Mrs Susan Gough Campaign ‐ RSPB OBJ1014 Mrs Joy Hunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 78 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1015 Ms Brigitte Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1016 Miss Rina Quinlan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1017 Miss Kenvin Dainton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1018 Mr Stephen Goddard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1019 Mr Ian Robinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1020 Mr Ian Thompson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1021 Miss Katrina Day Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1022 Mrs Joyce Murray Campaign ‐ RSPB OBJ1023 Dr Rob Best Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1024 Mr Wyn Mason Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1025 Mr Adrian Powell Campaign ‐ RSPB OBJ1026 Mr Mark Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ1027 ‐ Welsh Green Party Wales Green Party • Environment OBJ1027 ID/073 Ms Pippa Bartolotti • General WG/REB/OBJ0030 ‐ RSPB OBJ1028 Dr Robert Irving Campaign ‐ RSPB

OBJ1029 Mrs Ann Leonard Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1030 Mr Alan Reynolds Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1031 Mrs Julie Pester Campaign ‐ RSPB OBJ1032 Mr Oliver Grey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1033 Mrs Jean Stewart Campaign ‐ RSPB Same person as OBJ0087 OBJ1034 Dr Peter Varley Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1035 Mr Gareth Wainwright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1036 Miss Ellin Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1037 Ms Virginia Haines Campaign ‐ RSPB OBJ1038 Mr John Lewis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1039 Mr Michael Bevin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1040 Mrs Julie Edge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1041 Ms Ilona de Souza Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1042 Mr Daniel Whitelegg Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1043 Mrs Judith Whitmore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1044 Mr Norman Jones Campaign ‐ RSPB OBJ1045 Rhys Dutson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1046 Miss Yvonne Locke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1047 Ms Georgina Jane Petty Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 79 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1048 Mr Robert Wallman Campaign ‐ RSPB Mr Andy Atkins‐ WG/REB/OBJ0030 ‐ RSPB OBJ1049 Campaign ‐ RSPB Dotrice WG/REB/OBJ0030 ‐ RSPB OBJ1051 Mrs Hazel Jessett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1052 Mr Robert Coyne Campaign ‐ RSPB OBJ1053 Ms Lara Starr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1054 Ms Susan Hedger Campaign ‐ RSPB OBJ1055 Dr Dan Hoare Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1056 Mr Michael Gorton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1057 Mr Alun Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1058 Miss Sally Murphy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1059 Miss Alicia Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1060 Mrs Anna Newson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1061 Mr Trystan Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1062 Mr David Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1063 Mrs Lucinda Middleton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1064 Mr Nicholas Page Campaign ‐ RSPB OBJ1065 Mrs Sue Foot Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1066 Mr Brian O'Leary Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1067 Ms Linda Phelps Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1068 Dr Rob Sheldon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1069 Mr David Fisher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1070 Mr Paul Robertson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1071 Miss Moira Chapman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1072 Mr John Drewett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1073 Mr Steven Shipway Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1074 Mrs Nicola Taw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1075 Mrs Karen Nicklin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1076 Mr Mike Vickers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1077 Miss Chantal Redley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1078 Miss Natasha Murphy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1079 Miss Helen Prandy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1080 Mrs Christine Horsley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1081 Mrs Susan Taylor Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 80 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ1082 Mr John Allen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1083 Dr Chris Sherrington Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1084 Mr Kenneth Newton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1085 Ms Francesca Salmon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1086 Mrs Judith Ongeri Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1087 Mr Stephen Hinchley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1088 Mr Martin Fidler Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1089 Mr Graeme Walker Campaign ‐ RSPB

OBJ1090 Mrs Patricia Fennell Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1091 Mr Alec Fennell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1092 Miss Peter Stronach Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1093 Mr Richard Mash Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1094 Mr Sam Valente Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1095 Mrs Helen Phillips Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1096 Mrs Sue Harris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1097 Mr Paul Howard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1099 Mrs Vicki Gardner Campaign ‐ RSPB Same person as OBJ0017 OBJ1100 Mr Peter Harris Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1101 Mrs Lynnette Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1102 Mr George Baldock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1103 Miss Nancy Nussb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1104 Mrs Diana Golding Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1105 Mr Peter Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1106 Dr Katharine Carr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1107 Ms Vicky Duckworth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1108 Mr Alan Chambers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1109 Mr Sean Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1110 Mr David Brede Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1111 Mrs Alana Loughran Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1112 Mr Chris Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1113 Miss Jean Gerrard Campaign ‐ RSPB OBJ1114 Carlton Parry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1115 Miss Louise McCartney Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 81 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1116 Mrs Wendy Gale Campaign ‐ RSPB

OBJ1117 Mr Ben Payne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1118 Mr Philip Baker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1119 Mr Brian Daniels Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1120 Mrs Pauline Rosenberg Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1121 Mr Julian Doyle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1122 Miss Dawn Marshall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1123 Dorothy E. Wilson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1124 Lewis Thomson Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust

WG/REB/OBJ0030 ‐ RSPB OBJ1125 Steven Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1126 Miss Vicky Owen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1127 Stephen Emery Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1128 Mr Hadyn Jones Campaign ‐ RSPB OBJ1129 Mr Mel Kemp Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1130 Jude BaileyMurfin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1131 Miss Katie Jones Campaign ‐ RSPB Same person as OBJ0111 OBJ1132 Mr Thomas Simcock Withdrawn

OBJ1133 Andy Myles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1134 Mrs Teresa Greally Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1135 Mr Richard Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1136 Mr Oliver Glenister Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1137 Mr Mike Kellett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1139 Mrs Heather Rowe Campaign ‐ RSPB OBJ1140 Nicky Wright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1141 Patrick Driscall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1142 Mr John Cartlidge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1143 Rachael Hopley Campaign ‐ RSPB Same person as OBJ0109 Christopher Kirby‐ OBJ1144 Withdrawn Lambert WG/REB/OBJ0030 ‐ RSPB OBJ1145 Miss Bethan Casseldine Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1146 Miss Natalie Wylde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1147 Mrs Vera McCarthy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1148 Shannon Francis Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 82 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1149 Mr Chris Knapman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1150 Mr Gerard Fordham Campaign ‐ RSPB Same person as OBJ1027 OBJ1151 Pippa Bartolotti Withdrawn OBJ1152 Peter Wright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1153 Mr Hywel Arnold Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1154 Mr Stephen Dungey Campaign ‐ RSPB OBJ1155 Mr Martin Clift Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1156 Mr Geri Foster‐Thomas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1157 Mrs Sarah Reed Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Christopher OBJ1158 Campaign ‐ RSPB Brimble WG/REB/OBJ0030 ‐ RSPB OBJ1159 Mrs J C Mackenzie Campaign ‐ RSPB OBJ1160 Gillian Bourn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1161 Mrs Della Lack Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1162 Mrs Emma Cram Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Mr Daniel Jenkins‐ WG/REB/OBJ0030 ‐ RSPB OBJ1163 Campaign ‐ RSPB Jones WG/REB/OBJ0030 ‐ RSPB OBJ1164 Mr Kevin Sparkes Campaign ‐ RSPB OBJ1165 Dr Ian Francis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1166 Mrs Sophie Thomas Campaign ‐ RSPB OBJ1167 Geoff Gibbs Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Dr Alasdair and Dr OBJ1168 Campaign ‐ RSPB Susanna Jacks

WG/REB/OBJ0030 ‐ RSPB OBJ1169 Mr Richard Groves Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1170 Mr Justin Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1171 Miss Annabel Osborn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1172 Miss Kate Reece Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1173 Miss Alex Hoffrock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1174 Miss Sara Watkin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1175 Mr Stephen Shutt Campaign ‐ RSPB OBJ1176 Jo Webb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1177 Mr Maurice Wilkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1178 Mrs Lynn Gazal Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1179 Mr Ian Johnstone Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1180 Mrs Anne Marie Jones Campaign ‐ RSPB OBJ1181 Meyrick Jone Same person as OBJ0143 Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 83 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1182 Mrs Linda Laurenson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1183 Mrs Wendy Hartrey Campaign ‐ RSPB OBJ1184 Mr Ian Harris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1185 Mr Mike Ricketts Hein Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Penny Kingsley OBJ1186 Campaign ‐ RSPB Poynter

OBJ1187 Eleanor Wade Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1188 Sharon Hodgkiss Campaign ‐ RSPB Miss Gwenan Jenkins‐ WG/REB/OBJ0030 ‐ RSPB OBJ1189 Campaign ‐ RSPB Jones WG/REB/OBJ0030 ‐ RSPB Mr Simon Hugheston‐ OBJ1190 Campaign ‐ RSPB Roberts WG/REB/OBJ0030 ‐ RSPB OBJ1191 Kristibelle Hart Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1192 Mr Harry Bellew Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1193 Miss Alison Enticknap Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1194 Dr Mark Donovan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1195 Dr Chiara Ceci Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1196 Phil Bennington Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1197 Valerie Conniff Campaign ‐ RSPB OBJ1198 Julia James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1199 John Dransfield Campaign ‐ RSPB Same person as OBJ0128 OBJ1200 Barbara Spence Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1201 Ms Pat Barlow Thomas Campaign ‐ RSPB OBJ1202 John Waters Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1203 Mr Mark Hipkin Campaign ‐ RSPB OBJ1204 Iain Barclay Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1205 Dr Martin Kaye Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1206 Mr Robert Leeder Campaign ‐ RSPB OBJ1207 Camilla Edlin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1208 Mr Grant Powney Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1209 Ms Alexandra Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1210 Mr Antony Sanderson Campaign ‐ RSPB Miss Philippa WG/REB/OBJ0030 ‐ RSPB OBJ1211 Campaign ‐ RSPB Northcott WG/REB/OBJ0030 ‐ RSPB OBJ1212 Miss Anna Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1213 Miss C Alexander Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ1214 Dr Stuart Pringle Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 84 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB Miss Shaun Steiner‐ OBJ1215 Campaign ‐ RSPB Goldberg

OBJ1216 Tom Eyles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1217 Katharine Pitts‐Tucker Campaign ‐ RSPB OBJ1218 Dr Mark Avery Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1219 Mr Christopher Goding Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ1220 Mrs Jocelyn Gould Campaign ‐ RSPB OBJ1221 Dr Oliver Fox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1222 Mr Simon Crockford Campaign ‐ RSPB OBJ1223 Dr Barry Yates Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1224 Mr Ben Andrew Campaign ‐ RSPB OBJ1225 Mr David Allan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1226 Mr Robert Morsley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1227 Mr Dean Powell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1228 Mr Ben McCarthy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1229 Mr Les Wallace Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1230 Ms Ann Leeeuwerke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1231 Mr Alan Turnbull Campaign ‐ RSPB OBJ1232 Eliza Wilson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1233 Mr Joe Costley Campaign ‐ RSPB OBJ1234 Mr Tim Dixon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1235 Mr Tim Pankhurst Campaign ‐ RSPB OBJ1236 Rob Hepworth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1237 Mrs Marion Moss Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1238 Mrs Ann Clemison Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1239 Mrs Liz O'Hanlon Campaign ‐ RSPB OBJ1240 Mr Brian Egan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1241 Mr Mark Grieve Campaign ‐ RSPB OBJ1242 Mr Matt Merritt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1243 Mr John Olley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1244 Ms Juliette Young Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1245 Mrs Jean Hodgkinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1246 Lesley Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1247 Mr Malcolm Ware Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1248 Miss Jacqueline Fleet Campaign ‐ RSPB

OBJ1249 Mr Andy Field Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 85 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1250 Miss Gabriella Keaney Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1251 Mr Tony James Campaign ‐ RSPB OBJ1252 Anita Howard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Marianne WG/REB/OBJ0030 ‐ RSPB OBJ1253 Campaign ‐ RSPB Longstaff WG/REB/OBJ0030 ‐ RSPB OBJ1254 Alissa Pemberton Campaign ‐ RSPB Miss Karen R WG/REB/OBJ0030 ‐ RSPB OBJ1255 Campaign ‐ RSPB Thompson WG/REB/OBJ0030 ‐ RSPB OBJ1256 Michelle Househam Campaign ‐ RSPB OBJ1257 Mr Phil Hyde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1258 Christine Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1259 Miss Nicola Dixon Campaign ‐ RSPB OBJ1260 Nigel Cottle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1261 Mr Ron Walsh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1262 Arnold Woolley Campaign ‐ RSPB OBJ1263 Sharon Nevin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1264 Mr James Mowat Campaign ‐ RSPB Mrs Elisabeth WG/REB/OBJ0030 ‐ RSPB OBJ1265 Campaign ‐ RSPB Thompson OBJ1266 Andrew Rees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1267 Howard Mellett Campaign ‐ RSPB OBJ1268 Mr Dave Peck Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1269 Frances Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1270 Mr Carl Downing Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1271 Mrs Jenny Nesbitt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1272 Miss Doris McLean Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1273 Louise Sullivan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1274 Miss Andrea Godsell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1275 Miss Mark Flack Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1276 Mr Peter O'Duffy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1277 Miss Jean Johnston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1278 Miss Sharon Caughey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1279 Mrs Lindsay Osborn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1280 Dr Alistair Galley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1281 Miss Sian Jones Campaign ‐ RSPB OBJ1282 Alice Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1283 Mr Brian Russell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1284 Mr Joe Winstanley Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 86 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ1285 Mr Bob Crook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1286 Dr Andrew Cooke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1287 Mr Jeffrey Wragg Campaign ‐ RSPB OBJ1288 Mr Ian Gray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1289 Miss Nina O'Hanlon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1290 Mr Pete Burgin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1291 Mr Alan Gribben Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1292 Mrs Lyndsey Maiden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1293 Mr Stuart Allington Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1294 Mrs Valerie Carr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1295 Miss Beth Aucott Campaign ‐ RSPB OBJ1296 Mr Jim Peters Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1297 Mr David Church Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1298 Mr Andrew Lucas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1299 Mr Stewart Abbott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1300 Mr Mike Douglas Campaign ‐ RSPB OBJ1301 Miss Maria R Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1302 Mr Edward King Campaign ‐ RSPB OBJ1303 Mr Robert Ince Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1304 Miss Samantha King Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ1305 Mrs Jane Mcvickers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1306 Mrs Michelle Iles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1307 Mr John Cromarty Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1308 Mrs Natalie Avey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1309 Mr Robert Mills Campaign ‐ RSPB OBJ1310 Mr Kevin Rush Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1311 Mr Martyn Fletcher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1312 Mrs Kirsty Brannan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1313 Mr John Butterfield Campaign ‐ RSPB OBJ1314 Miss Lis Daly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1315 Mr Robert Barnett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1316 Mr Keith Bowser Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1317 Mr Martin Pollard Campaign ‐ RSPB OBJ1318 Mr Paul Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1319 Mr Paul Glading Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 87 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1320 Mr John Blewett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1321 Miss Leela O'Dea Campaign ‐ RSPB Mrs Rosemary WG/REB/OBJ0030 ‐ RSPB OBJ1322 Campaign ‐ RSPB Ashworth WG/REB/OBJ0030 ‐ RSPB OBJ1323 Mrs Linda Moore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1324 Mr Philip Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1325 Mr Jonathan Wallace Campaign ‐ RSPB

OBJ1326 Mr Malcolm Hawkes Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1327 Mrs Sarah Young Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1328 Mr Graham Rowling Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1329 Mr Greg Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1330 Ms Steph Elliott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1331 Mr Stuart Foster Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1332 Mr Roger Pannell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1333 Julian Vallance Campaign ‐ RSPB

OBJ1334 Mr Bruce Martin Campaign ‐ RSPB Withdrawn

OBJ1335 Mr Neil Heath Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB • Carbon WG‐REB‐OBJ1336 • Traffic WG/REB/OBJ0030 ‐ RSPB OBJ1336 Andrew McDermid • Flooding ID/073 • Economics WG/REB/OBJ0030 ‐ RSPB OBJ1337 Mr Hugh Brazier Campaign ‐ RSPB Miss Lehanne WG/REB/OBJ0030 ‐ RSPB OBJ1338 Campaign ‐ RSPB Thornton WG/REB/OBJ0030 ‐ RSPB OBJ1339 Miss Megan Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1340 Mr Steven Robinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1341 Mr Nick P Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1342 Mr Anthony Perry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1343 Ms Jenny Scholfield Campaign ‐ RSPB OBJ1344 Dr Mike Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1345 Mr G Edge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Erasmus zu WG/REB/OBJ0030 ‐ RSPB OBJ1346 Campaign ‐ RSPB Ermgassen WG/REB/OBJ0030 ‐ RSPB OBJ1347 Mr Jonathan Pinnick Campaign ‐ RSPB OBJ1348 Miss Jill Rixon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1349 Mr John Sleaford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1350 Mrs Jo Crabtree Campaign ‐ RSPB OBJ1351 Mr Mark Mills Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1352 Ms R Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 88 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1353 Dr Michael Davis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1354 Rob McPherson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1355 Mr Paul Walden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Catharine OBJ1356 Campaign ‐ RSPB Shellswell

OBJ1357 Mr Will Soar Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1358 Mr Terence Marsden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1359 Mr Steve Mitchell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1360 Mrs Anna Robertson Campaign ‐ RSPB OBJ1361 Ceri Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1362 Mark Balch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1363 Mr Terry Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1364 Mr Neil Harnott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1365 Mr Neville Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1366 Dr Sally Huband Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1367 Mrs Cristina Parker Campaign ‐ RSPB OBJ1368 C Baker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1369 Mr Giles Bradshaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1370 Ms Susan Richardson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1371 Mr Clive Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1372 Mr Dean Fenton Campaign ‐ RSPB OBJ1373 Mr Mike Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1374 Dr Russell Holden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1375 Mr Craig O'Brien Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1376 Dr Paul Horswill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1377 Prof Steve Ormerod Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1378 Mr Nigel Scriven Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1379 Mr Jonathan Bye Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1380 Mr Will Meredith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1381 Mrs Donna Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1382 Mrs Wendy Parry Campaign ‐ RSPB OBJ1383 David James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1384 Mr John Hunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1385 Mr Thomas Sutcliffe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1386 Miss Alex Russell Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 89 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1387 Genevieve Dalley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1388 Dr Andrew Baird Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1389 Sally Simmons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1390 Mr Adam Miller Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1391 Mr John Ravenscroft Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1392 Mr Phil Burfield Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1393 Mrs Sophie McCulloch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1394 Ms Brianna Reid Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1395 Miss Laura Mears Campaign ‐ RSPB OBJ1396 Nia Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1397 Mr Mervyn Lowe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1398 Miss Tanya Johnson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1399 Mr David Howell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1400 Mr Adam Bourns Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1401 Mr Matt Williams Campaign ‐ RSPB OBJ1402 Dipti Patel Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1403 Ms Jessica Chappell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1404 Malcolm Wright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1405 Mr Samuel Witham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1406 Mrs Lucy Bjorck Campaign ‐ RSPB OBJ1407 Mrs Jo Koszel Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1408 Mr Nick Tribe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1409 Dr Nathan Richardson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1410 Miss Katharine Holmes Campaign ‐ RSPB

OBJ1411 Lizzie Dealey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1412 Mr Graeme Wallace Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1413 Dr Dieter Hoffmann Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1414 Miss Amy Batchelor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1415 Miss Carolyn Sherratt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1416 Mrs Caroline Masters Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1417 Mr Edward Stevens Campaign ‐ RSPB OBJ1418 Mr Phil Pickett Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1419 Miss Helen Bradley Campaign ‐ RSPB OBJ1420 Scott Fryer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 90 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1421 Lynda Clarkson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1422 Ms Rosalind Sampson Campaign ‐ RSPB Miss Rhianne WG/REB/OBJ0030 ‐ RSPB OBJ1423 Campaign ‐ RSPB Cakebread WG/REB/OBJ0030 ‐ RSPB OBJ1424 Mr John Landais Campaign ‐ RSPB OBJ1425 Helen Croft Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1426 Emily Cunningham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1427 Miss Deborah Croker Campaign ‐ RSPB OBJ1428 Dr Ian McLean Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1429 Mrs Sue Birchall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1430 James Anderson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1431 Mr Thomas Lancaster Campaign ‐ RSPB OBJ1432 Mr Mali Halls Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1433 Ms Claire Perrens Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1434 Helen Houghton Campaign ‐ RSPB OBJ1435 Mr Mark Black Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1436 Mr Dennis Patton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1437 Mr Martin Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1438 Ms Steffeny McGiffen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1439 Mrs Eleri Norris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1440 Dr Sarah Manchester Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1441 Mr Alister Clunas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1442 Mrs Laura Perkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1443 Miss Zoe Parker Campaign ‐ RSPB

OBJ1444 Clive Shakesheff Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1445 Eleanor Hanrahan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1446 Mr Dean Powell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1447 Mrs Chrissy Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1448 Mr Ben Jackson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1449 Mr Daniel Grace Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Dr Alex Pollard OBJ1450 Campaign ‐ RSPB MCIEEM MRSB

WG/REB/OBJ0030 ‐ RSPB OBJ1451 Mr Jonathan Symons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Martha Halford‐ OBJ1452 Campaign ‐ RSPB Fumagalli

REVISED M4CAN objections schedule of evidence.xlsm 91 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1453 Mr Roger Crofts Campaign ‐ RSPB

OBJ1454 Karen Hyde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1455 Mr Iain Johnson Campaign ‐ RSPB OBJ1456 Dr Tom Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1457 Mrs Sharon Baker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1458 Mr Robert Hook Campaign ‐ RSPB

OBJ1459 Matt Davies Campaign ‐ RSPB Withdrawn

OBJ1460 Anthony Cook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1461 Mr Ian Armstrong Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1462 Prof John Altringham Campaign ‐ RSPB OBJ1463 Anthony Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1464 Mr Paul Thornton Campaign ‐ RSPB OBJ1465 Max Barclay Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1466 Miss Kerry Milligan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1467 Mr Simon Harrap Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1468 Mr Martin Kettell Campaign ‐ RSPB OBJ1469 Mr Peter Otley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1470 Mr Neil Douglas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1471 Mx Anand Prasad Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1472 Renee LaScala Campaign ‐ RSPB OBJ1473 Bethia Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1474 Sinead Lynch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1475 Mr Michael Hoult Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1476 Miss Sandra Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1477 Charlotte Guillain Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1478 Mr Andrew Bevan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1479 Mr Daniel Turner Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Jane Baines‐ OBJ1480 Campaign ‐ RSPB Holmes WG/REB/OBJ0030 ‐ RSPB OBJ1481 Mr David Roche Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Jacqueline Venn‐ OBJ1482 Campaign ‐ RSPB Jones WG/REB/OBJ0030 ‐ RSPB OBJ1483 Mrs Kristina Carroll Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1484 Mrs Stella Thomas Campaign ‐ RSPB

OBJ1485 Clare Harrington Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1486 Mr Ben Wynde Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 92 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1487 Ms Irene Stowe Campaign ‐ RSPB

OBJ1488 Gemma Bode Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1489 Mr Daniel Alexander Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1490 Mrs Caroline Rigg Campaign ‐ RSPB OBJ1491 Peter Gray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1492 Mrs Joan Thompson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1493 Mr William Jenman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1494 Rachel Hackett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1495 Mr Patrick Stirling‐Aird Campaign ‐ RSPB OBJ1496 Henry Cook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1497 Ms Pamela Stevens Campaign ‐ RSPB OBJ1498 Mr Ian Watson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1499 Mr Jonathan Heath Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1500 Mr Martin Wigley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1501 Mr Stephen Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1502 Mr Leigh Canham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1503 Mr Glenn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1504 Rachel Griffiths Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1505 Mrs Jacqueline Hull Campaign ‐ RSPB

OBJ1506 Rev 'o‐Dzin Tridral Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1507 Dr Michael Peacock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1508 Miss Lucy Kelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1509 Mr Paul Beevers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1510 Dr Chris Andrews Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1511 Prof Timothy Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1512 Mr Daniel Heptinstall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1513 Mr Charles Nathan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1514 Mr Tim Weaver Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1515 Miss Michelle Flynn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1516 Mr Derick Evans Campaign ‐ RSPB OBJ1517 Ms Julie Lee Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1518 Mr T Anderson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1519 Mrs Sally Evans Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 93 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1520 Mr Allan Hunton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1521 Mr Daniel Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1522 Prof David Norman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1523 Miss Caroline McAdam Campaign ‐ RSPB OBJ1524 Mr John Miller Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1525 Mr Marcus Rhodes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1526 Mr Keith Ballard Campaign ‐ RSPB OBJ1527 Susan Hiscox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Anthony WG/REB/OBJ0030 ‐ RSPB OBJ1528 Campaign ‐ RSPB Wesselbaum WG/REB/OBJ0030 ‐ RSPB OBJ1529 Mr Julian Thomas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1530 Mrs H R Kirk [B.E.M.] Campaign ‐ RSPB

OBJ1531 Mr Brian Horswill Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1532 Mrs Gwyneth Ramsey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1533 Miss Naomi Nelson Campaign ‐ RSPB OBJ1534 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1535 Leanne Manchester Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1536 Mr Douglas Radford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1537 Dr Emily Joachim Campaign ‐ RSPB OBJ1538 Mr Philip Allen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Christopher OBJ1539 Campaign ‐ RSPB Woodham WG/REB/OBJ0030 ‐ RSPB OBJ1540 Mr Paul Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1541 Mr Matthew Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1542 Margaret Wright Campaign ‐ RSPB OBJ1543 Karen Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1544 Ms Maggie Wilcox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1545 Dr Ieuan Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1546 Ms Kate Cartmell Done Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1547 Mrs Elizabeth Baum Campaign ‐ RSPB OBJ1548 Mr Rob Curtis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1549 Mr Brian Chapman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1550 Jonathan & Fiona Stone Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ1551 Miss Sue Hyde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1552 Eddie Urbanski Campaign ‐ RSPB Mr William John WG/REB/OBJ0030 ‐ RSPB OBJ1553 Campaign ‐ RSPB Roberts

REVISED M4CAN objections schedule of evidence.xlsm 94 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1554 Miss M A Wilson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1555 Miss Nathaniel Dargue Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ1556 Mr Richard Stow Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1557 Miss Alice Bricogne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1558 Mr Justin Tunstall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1559 Mr Michael Young Campaign ‐ RSPB OBJ1560 Mr John Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1561 Mr Steve Jones Campaign ‐ RSPB OBJ1562 Mr Peter Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Margaret WG/REB/OBJ0030 ‐ RSPB OBJ1563 Campaign ‐ RSPB Nicholson WG/REB/OBJ0030 ‐ RSPB OBJ1564 Dr Rob Thomas Campaign ‐ RSPB OBJ1565 Mr Mark Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1566 Ms Juliet Wilson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1567 Mr Jack Devlin Campaign ‐ RSPB OBJ1568 Estelle Bailey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1569 Dr Anthony Caravaggi Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1570 Mr Callum Peel Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1571 Mrs Ingrid Budge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1572 Ms Katie Fuller Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1573 Miss Lucy Rouse Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1574 Miss Elinor Parry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1575 Miss Rachel Stickler Campaign ‐ RSPB

OBJ1576 Mr John Boorman Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1577 Mr Stephen Meek Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Christopher OBJ1578 Campaign ‐ RSPB Baldock WG/REB/OBJ0030 ‐ RSPB OBJ1579 Mr Nicholas Carter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1580 Mr Chris Foster Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1581 Mr Colin Matthews Campaign ‐ RSPB Mrs Pauline WG/REB/OBJ0030 ‐ RSPB OBJ1582 Campaign ‐ RSPB Greenhalgh WG/REB/OBJ0030 ‐ RSPB OBJ1583 Mrs Karren Ward Campaign ‐ RSPB OBJ1584 John Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1585 Ms Vicky Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1586 Sophie Paterson Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 95 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

Miss Shannon WG/REB/OBJ0030 ‐ RSPB OBJ1587 Campaign ‐ RSPB Llewellyn WG/REB/OBJ0030 ‐ RSPB OBJ1588 Miss Zoe Deakin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1589 Mrs Lausanne Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1590 Dr Viola Ross‐Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1591 Mr Michael Lush Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1592 Mr David Beveridge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1593 Mrs Sarah Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1594 Mrs Kerry Swinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1595 Mr Bill Bisgood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1596 Mr Nicholas Foster Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1597 Miss Luned Defis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1598 Mr Wayne Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1599 Claire B Vallance Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1600 Mrs Celia Bryant Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1601 Mrs Lynne Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1602 Mr Gerry O'Rourke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1603 Ms Sarah‐Jane Wright Campaign ‐ RSPB OBJ1604 Mr Bob Elliot Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1605 Mr Keith Nichols Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1606 Ms Giselle Sterry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1607 Ms Rebecca Pitman Campaign ‐ RSPB OBJ1608 Mr Paul Frost Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1609 Mr Anthony Godber Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1610 Ms Clare Birch Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1611 Miss Henry Rothwell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1612 Christine Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1613 Miss Karen Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1614 Miss Kate Thorpe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1615 Mr Arne Swithenbank Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1616 Miss Hayley Blackwell Campaign ‐ RSPB OBJ1617 Fay Mansell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1618 Mrs Liz Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1619 Mr Ray Tier Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1620 Mrs Jo Whitfield Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 96 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1621 Miss Rachel Henson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1622 Mr Allen Stevens Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1623 Mrs Sandra Padfield Campaign ‐ RSPB

OBJ1624 Miss Rosemary Holden Campaign ‐ RSPB Withdrawn

Mrs Marilyn Jones WG/REB/OBJ0030 ‐ RSPB OBJ1625 Campaign ‐ RSPB Barnett WG/REB/OBJ0030 ‐ RSPB OBJ1626 Mr Simon Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1627 Mrs Natalie Matthews Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1628 Miss Kirsty Franklin Campaign ‐ RSPB OBJ1629 Mr Ben Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Alex Humphreys‐ OBJ1630 Campaign ‐ RSPB Jones WG/REB/OBJ0030 ‐ RSPB OBJ1631 Mr John Fisher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1632 Mrs Gill Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1633 Ms Sarah Blake Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1634 Miss Jenny Donelan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1635 Miss Stephanie Leese Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ1636 Mr Joe Hughes Campaign ‐ RSPB OBJ1637 Miss Lis Daly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1638 Mrs Sarah Fraser Campaign ‐ RSPB OBJ1639 Mr Ben Fraser Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1640 Mr Dylan Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1641 Mr Steve Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1642 Mr Steve Gillings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1643 Mrs Elizabeth Postles Campaign ‐ RSPB OBJ1644 Lesley Dance Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1645 Mr Paul Irving Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1646 Mr Albert Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1647 Mr Graham Jones Campaign ‐ RSPB OBJ1648 Tom Hackett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1649 Mr Drew Lyness Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1650 Mr Ronald Kinrade Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1651 Miss Thea Powell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1652 Mr Nick Roden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1653 Dr Nuvraj Sanghera Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 97 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1654 Mrs Christine Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1655 Mr Scott Chalmers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1656 Mr Jonathan Blackmore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1657 Miss Julia Lewis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1658 Miss Margaret Payne Campaign ‐ RSPB OBJ1659 Mr Ian Spence Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1660 Miss Sharon Locke Campaign ‐ RSPB OBJ1661 Mr Jon Barker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1662 Mr Stephen Jennings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1663 Mr Stewart Whitworth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1664 Miss Bethan Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1665 Mr Howard Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1666 Mr Phillip Thackeray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1667 Ms Stephanie Samphire Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1668 Mr Jack Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1669 Mr Andrew Mart Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1670 Mrs Rebecca Micklem Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1671 Mrs Karen Guthrie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1672 Miss Jeremy Robson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1673 Mr Geoff Jeffrey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1674 Mr Jerry Kinsley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1675 Mr Tim Lennox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1676 Mr Cody Levine Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1677 Mr Stephen Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1678 Mr Oliver Clanford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1679 Mr Giles Turnbull Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1680 Mr Julian Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1681 Mr Andy Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1682 Miss Erin Taylor Campaign ‐ RSPB OBJ1683 Mr Vic Doyle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1684 Ms Katy Carr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1685 Mr Julian Rosser Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1686 Miss Stella Woodman Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 98 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1687 Dr Rosemary Cockerill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1688 Mrs Aby Harrison Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1689 Mr John McKinnie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1690 Mr Chris Johnson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1691 Miss Philippa Lucas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1692 Mrs Julie Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1693 Mr Steven Savage Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1694 Mrs Caroline Gellor Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ1695 Miss Sue Everett Campaign ‐ RSPB OBJ1696 Mr Jon Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1697 Mrs Annette Soar Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1698 Mr Peter Rafferty Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1699 Mr Colin Lougher Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust

OBJ1700 Chris Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1701 Mrs Audrey Rafferty Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1702 Mr Pete Martin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1703 Ms Jacqui Adams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1704 Stephen Le Quesne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1705 Ms Emily Lloyd Campaign ‐ RSPB Mrs Christine Von WG/REB/OBJ0030 ‐ RSPB OBJ1707 Campaign ‐ RSPB Hagen WG/REB/OBJ0030 ‐ RSPB OBJ1708 Mr Cameron Keily Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1709 Mr Logan Steele Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1710 Mr Chris McNaghten Campaign ‐ RSPB OBJ1711 Mr Mike Smelt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1712 Mr Simon Webb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1713 Mrs Heather Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1714 Mr Matt Swaine Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1715 Mrs Eve Templeton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1716 Ms Katherine Hamper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1717 Prof Nessa Carey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1718 Prof Tim Blackburn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1719 Mr Anthony Lewis Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 99 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1720 Mrs Sophie Cooper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1721 Mr Justin Hood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1722 Mrs Sarah Haine Campaign ‐ RSPB OBJ1723 Alex Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1724 Dr Pablo Orozco Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1725 Miss Camille Felouzis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1726 Prof Kevin Gaston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1727 Mr John Ingham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1728 Mrs Mel Stewart Campaign ‐ RSPB OBJ1729 Claire Deacon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1730 Mr Mark Underhill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1731 Mr Robert Walthew Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1732 Kevin Clements Campaign ‐ RSPB OBJ1733 Miss B Kelly Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1734 Mr Richard Mason Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1735 Mr Martin McGill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1736 Mr Andrew Davis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1737 Mr Christopher Jones Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ1738 Mr Mike Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1739 Mr Peter Massini Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1740 Robert McEwen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1741 Ms Jane Mason Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1742 Mrs Penny Richards Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1743 Mrs Isabel Jackson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1744 Dr Renata Medeiros Campaign ‐ RSPB OBJ1745 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1746 J M Gorry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1747 Mrs Sarah Russell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1748 Mr Philip Aylen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1749 Mrs Jane Armitage Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1750 Miss Peter Alfrey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1751 Mr Andrew Crutchley Campaign ‐ RSPB OBJ1752 Mr Gary White Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1753 Mr Mark Duffell Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 100 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1754 Nicky Williamson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1755 Mr Simon Tucker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1756 Dr Adrian Davis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1757 Miss Amy Liptrot Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1758 Miss Sue Gent Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1759 Mrs Kate Genesi Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1760 Mrs Leigh Forman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1761 Miss Holly Showell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1762 Miss Alison Rees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1763 Ms Trudi Clamp Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1764 Mr Steven Bradbury Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1765 Mr Ed Goddard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1766 Ms Kirstie Armitage Campaign ‐ RSPB

Ms Karen Maddock‐ OBJ1767 Campaign ‐ RSPB Withdrawn Jones

OBJ1768 Lynne Thomas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1769 Oliver Gorrigan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1770 Mrs Iona Macphie Campaign ‐ RSPB OBJ1771 Mr Paul Heare Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1772 Miss Barbara Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1773 Ms Sarah Jaques Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1774 Mr Kevin Sharpe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1775 Mrs Kay Ball Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1776 Mrs Donna Dean Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1777 Mrs Carol Chapmam Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1778 Mrs Gladys Grant Campaign ‐ RSPB OBJ1779 Sally Harries Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1780 Mr Andy Teasdale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1781 Dr Richard Scorer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1782 Miss Julia Migne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1783 Mrs Therese Smout Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1784 Mr Jim Baldwin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1785 Miss Bethan Dalton Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 101 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1786 Paul Chambers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1787 Tamasine Stretton Campaign ‐ RSPB

OBJ1788 Ms Amy Christie Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1789 Mr Stuart Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1790 Mr Geoff Sawers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1791 Claire Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1792 Miss C M White Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1793 Mr Andy Holden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1794 Ms Anita Joysey Campaign ‐ RSPB OBJ1795 Mr Philip Hurst Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1796 Mr Steven Penn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1797 Miss Sally Hind Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1798 Mr Steve Todd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1799 Ms Ingunn Ruffles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1800 Miss Diana Tuson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1801 Miss Sophie Barrell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1802 Mr Michael Clifford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1803 Miss Lisa Mobley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1804 Mr Marc Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1805 Ms Erica Halliday Campaign ‐ RSPB OBJ1806 Chris Wynne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1807 Mr John Davis Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ1808 Mr Tim Poole Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1809 Miss Lesley Gore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Reverend Capt Charles OBJ1810 Campaign ‐ RSPB Thody

OBJ1811 Mr David Carson Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1812 Mrs Jackie Stevens Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1813 Mr Peter Bagshaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1814 Mr Trevor Riddle Campaign ‐ RSPB OBJ1815 Jane Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1816 James Byrne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1817 Charlotte Rowley Campaign ‐ RSPB

OBJ1818 Audrey Evans Campaign ‐ RSPB Withdrawn

OBJ1819 Alice Fairnie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 102 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ1820 Campaign ‐ RSPB Withdrawn OBJ1821 Paul Wise Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1822 Amanda Hurst Campaign ‐ RSPB Withdrawn OBJ1823 Katrina Rigby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1824 Mr Peter Bagshaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1825 Mr Cameron Keily Campaign ‐ RSPB Mrs Christine Von WG/REB/OBJ0030 ‐ RSPB OBJ1826 Campaign ‐ RSPB Hagen WG/REB/OBJ0030 ‐ RSPB OBJ1827 Mr Howard Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1828 Miss Bethan Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1829 Mr Jack Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1830 Mrs Jane Armitage Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1831 Mr Phillip Thackeray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1832 Ms Stephanie Samphire Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1833 Miss Lucy Rouse Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1834 Mrs Karen Guthrie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1835 Miss Jeremy Robson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1836 Mr Martin Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1837 Mr Dennis Patton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1838 Mrs Rebecca Micklem Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1839 Mr Geoff Jeffrey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1840 Mr Brian Horswill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1841 Mrs Gwyneth Ramsey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1842 Ms Teresa Fowler Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1843 Mrs Rhian Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1844 Mr Stephen Adams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1845 Mr Martin Bailey‐Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1846 Miss Hannah Scott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Ashley Crombet‐ OBJ1847 Campaign ‐ RSPB Beolens WG/REB/OBJ0030 ‐ RSPB OBJ1848 Ms Susan Fleming Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1849 Mrs Heather Clare Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1850 Miss Helen Peck Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1851 Mr Robert Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1852 Mrs Margaret Owen Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 103 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1853 Dr Mike Young Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1854 Mr Simon Craft Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1855 Mr Alistair Lockett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1856 Mr David Owen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1857 Mr Matthew Wyre Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1858 Mrs Fiona Karbal Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1859 Mrs Jean Mottershead Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1860 Mr Peter Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1861 Ms Mandy Marsh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1862 Mr Alan Durham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1863 Miss Steve Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1864 Mrs Pamela James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1865 Mr David Husband Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1866 Ms Chriss O'Connell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1867 Miss Rachel Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1868 Miss Shelley Hamilton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1869 Mrs Nicola Chester Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1870 Miss Jean Gerrard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1871 Ms Michell Chubb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1872 Mr Andrew Twyman Campaign ‐ RSPB Mr David‐John WG/REB/OBJ0030 ‐ RSPB OBJ1873 Campaign ‐ RSPB Newman WG/REB/OBJ0030 ‐ RSPB OBJ1874 Dr Paul Fitzpatrick Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1875 Miss Sheila Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1876 Mrs Jennifer Vaudin Campaign ‐ RSPB OBJ1877 Mr Ian Wicks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Dr Gwyneth Denver OBJ1878 Campaign ‐ RSPB Davies

OBJ1879 Mr Ken Barker Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1880 Mr Dave Hilliard Campaign ‐ RSPB

OBJ1881 Ms Gail Courtney Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1882 Mr Mark Crutchley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1883 Miss Lisa Bromley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1884 Mr Jim Flanagan Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 104 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1885 Mr Michael Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1886 Mr Delwyn Edwards Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1887 Dr Robert McEwen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1888 Mrs Suzanne Finlay Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1889 Ms Sue Mcguey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1890 Mr Paul Glading Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1891 Mr Michael Henwood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1892 Mrs Ellen Kershaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1893 Miss Jeanette Harrison Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1894 Mrs Rachael Hayward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1895 Mr Andrew Morton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1896 Mr Marc Stanley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1897 Mrs Tracey Mckay Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1898 Mrs Jennifer Wilson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1900 Miss Carrie‐Anne Judge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1901 Mrs Pamela Simmons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1902 Mrs Jane Collett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1903 Mr Bryan Collett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1904 Mrs Sandra Gibbons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1905 Mr David Harriss Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1906 Ms Shan Lloyd‐Packer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1907 Mrs Michele Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1908 Miss Dianna Gunby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1909 Mr Paul Curson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1910 Mr Andy Wattson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1911 Miss Gaynor Hodge Campaign ‐ RSPB Mr Michael OBJ1912 Campaign ‐ RSPB Withdrawn Burtenshaw WG/REB/OBJ0030 ‐ RSPB OBJ1913 Ms Judith Wilkings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1914 Mr Peter Leppert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1915 Mrs Patricia Mason Campaign ‐ RSPB OBJ1916 Mr A E King Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1917 Mrs Marjorie J Lewis Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 105 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1918 Miss Carole Summers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1919 Mrs Hazel Chadwick Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1920 Ms Ann Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1921 Mrs Mary‐Carol Gales Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1922 Mr Nigel Bruce Ingleby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1923 Miss George Short Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1924 Mr Steven Haynes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1925 Dr Sandra Domizio Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1926 Mrs Amanda Stacpoole Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1927 Mrs Alison Nash Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1928 Mr Len Massey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1929 Mr Kevin Pittman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1930 Mr Simon Towers Campaign ‐ RSPB

OBJ1931 Dr David Guyoncourt Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1932 Mrs Jennifer Woodman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1933 Miss Elaine St Leger Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1934 Mr Martin Keefe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1935 Ms Ceri Dunstan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Robert O'Connor OBJ1936 Campaign ‐ RSPB BSc. GradCIEEM

WG/REB/OBJ0030 ‐ RSPB OBJ1937 Mr Gareth Morgan Campaign ‐ RSPB OBJ1938 Mrs Rose Gill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1939 Ms Helen Gough Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1940 Ms Tracey Lovering Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1941 Mr Geoffrey Walton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1942 Mr Gerald Cannon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1943 Mrs Laura Warner Campaign ‐ RSPB Miss Charlotte WG/REB/OBJ0030 ‐ RSPB OBJ1944 Campaign ‐ RSPB McKeggie Mrs Rachel WG/REB/OBJ0030 ‐ RSPB OBJ1945 Campaign ‐ RSPB Beardsmore WG/REB/OBJ0030 ‐ RSPB OBJ1946 Mr Michael Rodwell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1947 Mr Hedley Nichols Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1948 Mrs Sue Johncock Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 106 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1949 Ms Christine Toland Campaign ‐ RSPB

OBJ1950 Miss Fran Hollinrake Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1951 Miss Michele Speirs Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1952 Mrs Samantha Clews Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1953 Mrs Janet Meredith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1954 Mr Michael Pinnock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1955 Mrs Jacquie Butler Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1956 Mr Robert Sato Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1957 Mrs Carrina Rowe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1958 Mrs Dawn Locke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1959 Mr Jason Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1960 Mr Mark Robinson Campaign ‐ RSPB OBJ1961 Mr Peter Trigg Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1962 Ms Esther Roebuck Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1963 Ms Ruthi Brandt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1964 Mrs Ann Powrie Campaign ‐ RSPB Miss Anne‐Marie WG/REB/OBJ0030 ‐ RSPB OBJ1965 Campaign ‐ RSPB Hewitt WG/REB/OBJ0030 ‐ RSPB OBJ1966 Mr Daniel Middlewood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1967 Mrs Heather Brayshaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1968 Mr Andrew White Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1969 Mrs Ann Johnson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1970 Miss Rachel Hamilton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1971 Mrs Michelle Hennessy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1972 Miss Claire Edmonds Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1973 Mrs Jo HollingsheadCampaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1974 Mr Stuart Fraser Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1975 Ms Margaret King Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1976 Mr Keith Gosling Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1977 Mrs Beverley Brock Campaign ‐ RSPB OBJ1978 Mrs S Watkin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1979 Mrs Angela Blackshaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1980 Mrs Jennifer Lees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1981 Mr David Perks Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 107 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ1982 Mrs Glenis Blakiston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1983 Mrs Brigitta MacMillan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1984 Mrs Karan Smith Campaign ‐ RSPB OBJ1985 Mr Paul Lilley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1986 Mr Ian Thomson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1987 Mrs Claire Townsend Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1988 Miss Jess D'Arcy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1989 Mrs Caroline Dallimore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1990 Mrs Denise Ramsden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1991 Miss Emily King Campaign ‐ RSPB OBJ1992 Mr P Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1993 Miss Annabelle Tipper Campaign ‐ RSPB

OBJ1994 Dr Paul Hayes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1995 Mrs Eileen Allan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1996 Mr John Jakeman Campaign ‐ RSPB

OBJ1997 Mr Mike Cleary Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ1998 Mrs Vivien Thornber Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ1999 Mrs Carol Anne Lloyd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2000 Miss Jane McKay Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2001 Ms Linda Cartlidge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2002 Mrs Jean Coombes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2003 Miss Diana Lewis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2004 Mr Chris Wright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2005 Mr Brian Dorsett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2006 Mrs Maureen Daniels Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2007 Mrs Elaine FIsher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2008 Mr Roger Ackroyd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2009 Mrs Sarah Perrin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2010 Rev Paul Davies Campaign ‐ RSPB

OBJ2011 Mr Peter Sandell Campaign ‐ RSPB Withdrawn

OBJ2012 Miss Andrea Wiskin Campaign ‐ RSPB Withdrawn

OBJ2013 Mr Giles Broomfield Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 108 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2014 Miss Sue Albiston Campaign ‐ RSPB

OBJ2015 Mr Tim Fox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2016 Miss Juliet Kavanagh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2017 Miss Zoe Chappell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2018 Mr Peter Mittins Campaign ‐ RSPB OBJ2019 Ms Tricia Rice Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2020 Mrs Philippa Pickworth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2021 Ms Rowan Adams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2022 Mr David Fisher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2023 Mrs Lyn Goswell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2024 Mrs Pamela Warren Campaign ‐ RSPB OBJ2025 Mr Colin Rose Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2026 Ms Sharron Goddard Campaign ‐ RSPB OBJ2027 Mr Tony Kilker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss M Jennifer OBJ2028 Campaign ‐ RSPB Meredith WG/REB/OBJ0030 ‐ RSPB OBJ2029 Mrs Marian Hussenbux Campaign ‐ RSPB OBJ2030 Mr Philip Key Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2031 Ms Annabel Brown Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2032 Miss Patricia Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2033 Mrs Cornelia Bower Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2034 Mr Robert Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2035 Mrs Amanda Price Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2036 Ms Julie Hunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2037 Miss Hannah Withers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2038 Mrs Chris Ward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2039 Mr Pete Griffith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2040 Ms Christine Shields Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2041 Mrs Dawn Walton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2042 Mr David Cohen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2043 Mrs Mary Betteridge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2044 Mrs Jackie White Campaign ‐ RSPB Mrs Tom and Sandra WG/REB/OBJ0030 ‐ RSPB OBJ2045 Campaign ‐ RSPB Unite WG/REB/OBJ0030 ‐ RSPB OBJ2046 Mr Brian Witty Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 109 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2048 Mr Gregory Snelgrove Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2049 Miss Selma Rauf Campaign ‐ RSPB OBJ2050 Mr Ray Poole Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2052 Mrs Heather Procter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2053 Mr Gavin Whitelock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2054 Ms Nikki Titchard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2055 Ms Dawn Bishop Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2056 Mrs Gillian Hind Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2057 Mr Tom Tamplin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2058 Mr Athony Murray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2059 Mrs Joanne Banks Campaign ‐ RSPB

OBJ2060 Mr Nathanael Fisher Campaign ‐ RSPB Withdrawn

OBJ2061 Miss Fiona Banham Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2062 Mrs Monica Cussens Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2063 Ms Dianne Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2064 Mrs Christine Harding Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2065 Mrs Shirley Chesson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2066 Mrs Helen Trebble Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2067 Mr David Berry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2068 Miss Rhian Jinny‐Jones Campaign ‐ RSPB

OBJ2069 Mrs Irene Walker Campaign ‐ RSPB Withdrawn

OBJ2070 Mrs Joan How Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2071 Mrs Priscilla Ingram Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2072 Mrs Deborah McGregor Campaign ‐ RSPB Mrs Margaret WG/REB/OBJ0030 ‐ RSPB OBJ2073 Campaign ‐ RSPB Meadows WG/REB/OBJ0030 ‐ RSPB OBJ2074 Mrs Gaynor Slaney Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2075 Mr Anthony Micklam Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2076 Mr Steve Beech Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2077 Miss Sue Rose Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2078 Mrs Natasha Welford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2079 Mr John Johnson Campaign ‐ RSPB

OBJ2080 Mrs Pet Rainer Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 110 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2081 Mrs Pia Plummer Campaign ‐ RSPB

OBJ2082 Mr Dave Perry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2083 Mrs Helen Hinchley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2084 Mrs Sheila Hartrey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2085 Mr Gerald Spencer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2086 Mr Robert Spencer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2087 Ms Sally Murphy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2088 Mrs Anne Powell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2089 Miss Chris Hight Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2090 Mr Alan Baltzars Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2091 Mr Jeremy Lewis Campaign ‐ RSPB

OBJ2092 Miss Marian McGinty Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2093 Mrs Julia Jackson Campaign ‐ RSPB OBJ2094 Mr J Swinford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Barbara OBJ2095 Campaign ‐ RSPB Wadsworth‐Davies

OBJ2096 Ms Jane R Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2097 Mr Kevin Green Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2098 Miss Marilyn Dance Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2099 Mr Keith Moores Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2100 Dr David Matthews Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2101 Mr Paul Shorter Campaign ‐ RSPB

OBJ2102 Mr Steve Carter Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2103 Miss Sandra Gould Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2104 Mrs Janet Bullock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2105 Mrs Barbara Cook Campaign ‐ RSPB OBJ2106 Ms Jean Riley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2107 Ms Renny Wodynska Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2108 Miss Jean Mantle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2109 Miss Alison Bullock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2110 Mrs Gail Cartwright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2111 Mr John Blewett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2112 Miss Mark Doran Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2113 Dr Sharon Patrick Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 111 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2114 Mrs Christine Allen Campaign ‐ RSPB

OBJ2115 Miss G Wyatt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2116 Mrs Marilyn Jarrett Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2117 Mr Phil Thornton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2118 Miss Georgina Sherry Campaign ‐ RSPB

OBJ2119 Mrs Gaynor Slater Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2120 Dr Elizabeth Lees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2121 Miss Christine Dore Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2122 Mr Graham Langston Campaign ‐ RSPB OBJ2123 Mr John Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2124 Miss Jill Hedley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2125 Mrs Sarah Sparrow Campaign ‐ RSPB OBJ2126 Mr Fred Boast Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2127 Miss Amanda Carson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2128 Miss Sara Garcia Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2129 Mrs Joanne Burgin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2130 Mr Vincent Savage Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2131 Mr David Audley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2132 Mrs Linda Gregory Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2133 Ms Angela Coneron Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2134 Mr Matthew Cory Campaign ‐ RSPB Mrs Pam Radford‐ WG/REB/OBJ0030 ‐ RSPB OBJ2135 Campaign ‐ RSPB Lamb OBJ2136 Mr Peter Brimson Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2137 Mr Richard Purcell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2138 Mrs Grettl Hughes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2139 Mr Jonathan Ford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2140 Ms Helen Spencer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2141 Mrs Pat Hayes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2142 Mrs Christine Bennett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2143 Mr Nicholas Kelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Christopher OBJ2144 Campaign ‐ RSPB Edgeley WG/REB/OBJ0030 ‐ RSPB OBJ2145 Miss Emma Thompson Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 112 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2146 Mr David Martens Campaign ‐ RSPB

OBJ2147 Ms Jan Hicks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2148 Miss Lorna Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2149 Miss Jennifer Wynn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2150 Mrs Maureen Shaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2151 Mrs Paula Craib Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2152 Mr Graham Crump Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2153 Mr Tim Kasoar Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2154 Mr Andrew Mackenzie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2155 Mr Julian Thomas Campaign ‐ RSPB

OBJ2156 Mr Peter Carroll Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2157 Mrs Susan Colborne Campaign ‐ RSPB

OBJ2158 Miss Paula Prince Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2159 Mrs Linda Thomson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2160 Mrs Linda McDowell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2161 Ms Jenny Anderson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2162 Miss Adam Hutt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2163 Mrs Linda Klein Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Lucian Warwick‐ OBJ2164 Campaign ‐ RSPB Haller WG/REB/OBJ0030 ‐ RSPB OBJ2165 Mrs Lesley Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2166 Mrs Wendy Wiseman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2167 Miss Linda Sims Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2168 Mr Daniel Winter Campaign ‐ RSPB OBJ2169 Mr Paul White Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2170 Mr Hugh Tunks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2172 Mrs Margaret Houston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2173 Mr Barry Metcalfe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2174 Miss Lisa Scouler Campaign ‐ RSPB Mrs Joanne WG/REB/OBJ0030 ‐ RSPB OBJ2175 Campaign ‐ RSPB Chamberlain WG/REB/OBJ0030 ‐ RSPB OBJ2176 Mr David MeanwellCampaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2177 Mr Jim Dustow Campaign ‐ RSPB OBJ2178 Mr Paul Sutton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 113 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2179 Mrs Jacqueline Roberts Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ2180 Miss Janet Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2181 Mr Alan Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2182 Mrs Margaret Foreman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2183 Ms Annie Gregory Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2184 Mr Richard Kite Campaign ‐ RSPB

OBJ2185 Ms Stephanie Hillier Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2186 Mrs Karen Coombs Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2187 Mr Gareth Vincent Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2188 Mr Barry Harmsworth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2189 Mrs Sandra Leavy Campaign ‐ RSPB

OBJ2190 Mrs Riki Johnson Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2191 Mr Mark Hollinrake Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2192 Ms Catherine Glanfield Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2193 Mr Ray Cottrell Campaign ‐ RSPB

OBJ2194 Mrs Diane Fletcher Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2195 Ms Janet Sherman Campaign ‐ RSPB OBJ2196 Mr Alan Street Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2197 Mrs Joan Buckland Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2198 Ms Freni Chinoy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2199 Mr Robert Dando Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2200 Mr Malcolm Best Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2201 Mrs Carole Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2202 Mrs Lynne Potter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2203 Ms Annie Bowdler Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2204 Miss Shelley Hamilton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2205 Miss Sheila Thurgood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2206 Ms Rosemary Byrde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2207 Mrs Janet Barnby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2208 Mrs Geralyn Crooks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2209 Mrs Barbara Coward Campaign ‐ RSPB

OBJ2210 Mrs Debbie Wilcox Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 114 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2211 Miss Francesca Severn Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ2212 Mrs Sue McDonald Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2213 Ms Judith Dyer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2214 Mrs Pam James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2215 Miss Alana King Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2216 Mrs Suzanne Mattock Campaign ‐ RSPB OBJ2217 Mrs Jill Studd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2218 Mr Trevor Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2219 Ms Trish Davidson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2220 Mr John Grimes Campaign ‐ RSPB

OBJ2221 Ms Judith Newton Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB Mr Christopher OBJ2222 Campaign ‐ RSPB Harrison WG/REB/OBJ0030 ‐ RSPB OBJ2223 Miss David Turner Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2224 Mr James Abbott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2225 Ms Karen Jennings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2226 Mr John Saffrette Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2227 Mrs Barbara Swift Campaign ‐ RSPB OBJ2228 Mr Rui Barros Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2229 Mrs Helen Brockway Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2230 Miss Cheryl Lloyd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2231 Mr Edward Wiseman Campaign ‐ RSPB

OBJ2232 Mrs Simone Higgins Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2233 Ms Laura Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2234 Mrs Margaret Foxcroft Campaign ‐ RSPB Mrs Susan Kneill‐ WG/REB/OBJ0030 ‐ RSPB OBJ2235 Campaign ‐ RSPB Boxley WG/REB/OBJ0030 ‐ RSPB OBJ2236 Mrs Linsay Milne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2237 Mrs Gwyneth Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2238 Miss Mary Jordan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2239 Mrs Stella Westmacott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2240 Mrs Anne Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2241 Mr Philip Edwards Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2242 Mr Haydn Madge Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 115 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2243 Mrs Jean Snelling Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2244 Mr Charles Page Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2245 Mrs Alison Paterson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2246 Ms Alison Reboul Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2247 Mrs Christine Osborne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2248 David Ramsden MBE Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ2249 Miss Steve Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2250 Mr John Mander Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2251 Mrs Hazel Amati Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2252 Miss Maxine Audley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2253 Mr Andrew Budd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2254 Mr Sean Chapman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2255 Mr Peter Thompson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2256 Mr John Gascoyne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2257 Mrs Victoria Green Campaign ‐ RSPB OBJ2258 Mr John Irwin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2259 Mrs Fay Robinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2260 Mrs Chris Edwards Campaign ‐ RSPB OBJ2261 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2262 Mrs Marian Simmonds Campaign ‐ RSPB

OBJ2263 Miss Leanne Seymour Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2264 Ms P J Marshall Campaign ‐ RSPB OBJ2265 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2266 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2267 Mr David Herincx Campaign ‐ RSPB

OBJ2268 Mr John Ramsden Campaign ‐ RSPB Withdrawn

OBJ2269 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2270 Miss J Hinman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2271 Mr Ray Mumford Campaign ‐ RSPB Miss Kerry‐Lynn WG/REB/OBJ0030 ‐ RSPB OBJ2272 Campaign ‐ RSPB Wortley WG/REB/OBJ0030 ‐ RSPB OBJ2273 Mr Ian Cotgrove Campaign ‐ RSPB

OBJ2274 Miss Jane Breeze Campaign ‐ RSPB Withdrawn

OBJ2275 Mr Peter Kirby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2276 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 116 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2277 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2278 Mr Michael Strutt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2279 Mrs Denise Walecka Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2280 Mr Graham Stacey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2281 Mr Michael Hunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2282 Mr David Clark Campaign ‐ RSPB

OBJ2283 Mrs Violet Burchell Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2284 Mrs Janet Widdows Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2285 Mr Quentin Given Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2286 Mrs Elisabeth Bibbings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2287 Mrs Josephine Wallis Campaign ‐ RSPB

OBJ2288 Mr Leslie Weeks Campaign ‐ RSPB Withdrawn

OBJ2289 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2290 Mr Jerry Campbell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2291 Mrs J V McNamara Campaign ‐ RSPB OBJ2292 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2293 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2294 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2295 Ms Anne Wright Campaign ‐ RSPB

OBJ2296 Mr Stephen Drew Campaign ‐ RSPB Withdrawn

OBJ2297 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2298 Mr Richard Green Campaign ‐ RSPB OBJ2299 Philip Bradley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2300 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2301 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2302 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2303 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2304 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2305 K Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2306 John V Boys M.A Campaign ‐ RSPB OBJ2307 D Thomas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2308 Michael Harris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2309 A J Wall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2310 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2311 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2312 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2313 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2314 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2315 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2316 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2317 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2318 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 117 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2320 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2321 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2322 Shirley Fisher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2323 Campaign ‐ RSPB Withdrawn

OBJ2324 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2325 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2326 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2327 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2328 Campaign ‐ RSPB Withdrawn OBJ2329 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2330 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2331 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2332 R B Wall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2333 Campaign ‐ RSPB Withdrawn

OBJ2334 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2335 Campaign ‐ RSPB Withdrawn OBJ2336 Campaign ‐ RSPB Withdrawn OBJ2338 Campaign ‐ RSPB Withdrawn OBJ2339 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2340 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2341 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2342 Mary Kelsey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2343 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2344 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2345 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2346 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2347 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2348 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2349 Ms Helen Hennerley Campaign ‐ RSPB OBJ2350 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2351 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2352 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2353 Ms Caroline Stedman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2354 Miss Judith Worton Campaign ‐ RSPB OBJ2355 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2356 Mrs Helen Dwyer Campaign ‐ RSPB OBJ2357 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2358 Ms Jane Liddiard Campaign ‐ RSPB OBJ2359 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2360 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2361 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2362 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2363 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2364 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2365 Mr Keith Cheasman Campaign ‐ RSPB OBJ2366 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2367 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 118 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2368 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2369 Mrs Lee James Campaign ‐ RSPB OBJ2370 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2371 Mrs Janet Tompsett Campaign ‐ RSPB OBJ2372 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2373 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2374 Dr Stella Goldberg Campaign ‐ RSPB OBJ2375 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2376 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2377 Lesley Wheatley Campaign ‐ RSPB OBJ2378 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2379 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2380 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2381 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2382 Kerry Forkner Campaign ‐ RSPB

OBJ2383 Mr Ronald Allum Campaign ‐ RSPB Withdrawn

OBJ2384 Mr Cyril Mills Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2385 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2386 Mrs Rose Ravenscroft Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2387 Mrs Amanda Roberts Campaign ‐ RSPB OBJ2388 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2389 E Allan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2390 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2391 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2392 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2393 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2394 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Dr Norman WG/REB/OBJ0030 ‐ RSPB OBJ2395 Campaign ‐ RSPB & Woodland Trust Chamberlain WG/REB/OBJ0271 ‐ Woodland Trust OBJ2396 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2397 Anthony Bingham Campaign ‐ RSPB OBJ2398 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2399 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2400 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2401 Chris Teitge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2402 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2403 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2404 P Rosamond Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2405 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2406 Kay A Wardle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2407 Mr L M Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2408 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2409 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2410 Mr Peter Lewis Campaign ‐ RSPB OBJ2411 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2412 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2413 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 119 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2414 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2415 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2416 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2417 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2418 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2419 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2420 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2421 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2422 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2423 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2424 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2425 Campaign ‐ RSPB Withdrawn OBJ2426 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2427 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2428 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2429 N G Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2430 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2431 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2432 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2433 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2434 Campaign ‐ RSPB Withdrawn OBJ2435 Campaign ‐ RSPB Withdrawn OBJ2436 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2437 Mrs D Gosling Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2438 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2439 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2440 Mr Roger Unsworth Campaign ‐ RSPB OBJ2441 Alison Leigh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2442 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2443 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2444 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2445 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2446 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2447 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2448 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2449 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2450 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2451 Miss Maria Scullion Campaign ‐ RSPB OBJ2452 Campaign ‐ RSPB Withdrawn OBJ2453 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2454 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2455 Mrs Angela Guerzoni Campaign ‐ RSPB OBJ2456 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2457 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2458 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2459 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2460 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2461 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2462 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2463 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2464 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 120 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2466 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2467 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2468 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2469 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2470 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2471 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2472 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2473 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2474 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2475 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2476 Jane Campbell Campaign ‐ RSPB OBJ2477 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2478 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2479 Kim Western Campaign ‐ Gwent Wildlife Withdrawn OBJ2480 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2481 Deborah Fiddament Campaign ‐ RSPB OBJ2482 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2483 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2484 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2485 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2486 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2487 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2488 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2489 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2490 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2491 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2492 Miss Linda Jones Campaign ‐ RSPB OBJ2493 Campaign ‐ RSPB Withdrawn OBJ2494 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2495 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2496 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2497 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2498 Mary Robertson Campaign ‐ RSPB

OBJ2499 Campaign ‐ RSPB Withdrawn

OBJ2500 Mark Perry Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2501 Mrs Anna Sandfield Campaign ‐ RSPB OBJ2502 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2503 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2504 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2505 R Crowdy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2506 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2508 Elaine Blackman Campaign ‐ RSPB & Woodland Trust OBJ2509 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2510 Glenmore Slack Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2511 Mrs Gill Thomas Campaign ‐ RSPB OBJ2512 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2513 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 121 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2514 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2515 Campaign ‐ RSPB

OBJ2516 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2517 Jean McGuire Campaign ‐ RSPB OBJ2518 Alan Baltzars Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2519 Miss Lindsey Hodkin Campaign ‐ RSPB OBJ2520 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2521 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2522 Miss Jo Hindley Campaign ‐ RSPB OBJ2523 Campaign ‐ RSPB Withdrawn OBJ2524 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2525 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2526 Miss Mel Wilmott Campaign ‐ RSPB OBJ2527 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2528 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2529 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2530 David Blackman Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2531 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2532 Campaign ‐ RSPB Withdrawn OBJ2533 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2534 Hazel Pears Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2535 Christine Stevenson Campaign ‐ RSPB OBJ2536 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2537 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2538 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2539 Christine Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2540 Ms Janina Pomian Campaign ‐ RSPB OBJ2541 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2542 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2543 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2544 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2545 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2546 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2547 Campaign ‐ RSPB Withdrawn OBJ2548 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2549 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2550 Campaign ‐ RSPB Withdrawn OBJ2551 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2552 Marian Prince Campaign ‐ RSPB Withdrawn

OBJ2553 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2554 Ms Jane Somerville Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2555 Glenys Cartmell Campaign ‐ RSPB OBJ2556 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2557 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 122 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2558 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2559 Miss Louise Hitchen Campaign ‐ RSPB OBJ2560 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2561 Colin Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2562 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2563 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2564 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2565 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2566 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2567 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2568 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2569 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2570 Mrs Sylvia Bain Campaign ‐ RSPB OBJ2571 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2573 Cynthia Legge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2574 Vicky Hunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2575 Campaign ‐ RSPB

OBJ2576 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2577 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2578 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2579 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2580 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2581 Campaign ‐ RSPB Withdrawn

OBJ2583 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2584 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2585 Jane Bowers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2586 Jenny Raggett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2587 Liz Spencer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2588 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2589 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2590 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2591 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2592 Mark Eldridge Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2593 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2594 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2595 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2596 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2597 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2598 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2599 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2600 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2601 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2602 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2603 Stuart Chatwin Campaign ‐ RSPB OBJ2604 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2605 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2606 A D Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2607 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2608 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 123 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2609 Karen Bartlett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2610 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2611 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2612 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2613 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2614 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2615 Josephine Spencer Campaign ‐ RSPB OBJ2616 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2617 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2618 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2620 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2621 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2622 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2623 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2624 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2625 Campaign ‐ RSPB Withdrawn

OBJ2626 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2627 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2628 A J Knight Campaign ‐ RSPB Withdrawn OBJ2629 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2630 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2631 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2632 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2633 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2634 Stephen Jones Campaign ‐ RSPB OBJ2635 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2636 Mr Carey Lodge Campaign ‐ RSPB OBJ2637 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2638 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2639 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2640 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2641 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2642 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2643 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2644 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2645 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2646 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2647 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2648 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2649 Campaign ‐ RSPB Withdrawn

OBJ2650 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2651 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2652 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2653 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2654 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2655 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2656 Campaign ‐ RSPB OBJ2657 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2658 Mr Alan Gomersall Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 124 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2659 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2660 A E Phillips Campaign ‐ RSPB Withdrawn OBJ2661 Mr A Mayall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2662 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2663 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2664 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2665 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2667 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2668 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2669 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2670 Richard Walker Campaign ‐ RSPB OBJ2671 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2672 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2673 Mr John James Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2674 Campaign ‐ RSPB Withdrawn OBJ2675 Campaign ‐ RSPB Withdrawn OBJ2676 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2677 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2678 Campaign ‐ RSPB Withdrawn OBJ2679 Eric G Sage Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2680 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2681 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2682 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2684 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2685 J P Carlile Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2686 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2687 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2688 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2689 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2690 Campaign ‐ RSPB Withdrawn OBJ2691 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2692 Campaign ‐ RSPB Withdrawn OBJ2693 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2694 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2695 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2696 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2697 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2698 John F Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2699 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2700 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2701 Alan Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2702 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2703 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2704 Campaign ‐ RSPB Withdrawn OBJ2705 John Makin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2706 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2707 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2708 Julia Christie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2709 Carol Hancock Campaign ‐ RSPB Withdrawn OBJ2710 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2711 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2712 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 125 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2713 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2714 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2715 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2716 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2718 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2719 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2720 Campaign ‐ RSPB Withdrawn

OBJ2721 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2722 Campaign ‐ RSPB Withdrawn OBJ2723 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2724 Anton Duignan Campaign ‐ RSPB OBJ2725 K Morton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2726 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2727 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2728 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2729 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2730 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2731 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2732 Campaign ‐ RSPB Withdrawn OBJ2733 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2734 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2735 Jason Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2736 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2737 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2738 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2739 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2740 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2741 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2742 Julie Rolls Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2743 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2744 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2745 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2746 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2747 Janet Evans Campaign ‐ RSPB Withdrawn

OBJ2748 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2749 Campaign ‐ RSPB Withdrawn

OBJ2750 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2751 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2752 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2753 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2754 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2755 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2756 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2757 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2758 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2759 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2760 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2761 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 126 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2762 Jane Rosser Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2763 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2764 Campaign ‐ RSPB Withdrawn OBJ2766 G G S Harries Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2767 Ms Ena Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2768 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2769 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2770 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2771 A Postlethwaite Campaign ‐ RSPB OBJ2772 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2773 Harry Wheate Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2774 Ms Sue Dare Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2775 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2776 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2777 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2778 Campaign ‐ RSPB Withdrawn

OBJ2779 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2780 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2781 Mr Derek West Campaign ‐ RSPB OBJ2782 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2783 Rod Robbin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2784 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2785 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2786 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2787 Mrs Susan Drever Campaign ‐ RSPB OBJ2788 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2789 Campaign ‐ RSPB Withdrawn OBJ2790 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2791 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2792 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2793 Paddie Howes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2794 Penny Llewellyn Campaign ‐ RSPB OBJ2795 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2796 Marie Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2797 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2798 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2799 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2800 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2801 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2802 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2803 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2804 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2805 Campaign ‐ RSPB Withdrawn

OBJ2806 K G Charity Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2807 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2808 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2809 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2810 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 127 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2811 Campaign ‐ RSPB Withdrawn OBJ2812 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2813 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2814 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2815 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2816 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2817 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2818 Miss L Swinhoe Campaign ‐ RSPB OBJ2819 Frances Mayo Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2820 Paul McClaughlin Campaign ‐ RSPB OBJ2821 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2822 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2823 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2824 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2825 Campaign ‐ RSPB Withdrawn

OBJ2826 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2827 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2828 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2829 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2830 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2831 Margaret Brett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2832 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2833 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2834 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2835 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2836 Peter John Potts Campaign ‐ RSPB OBJ2837 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2838 Mrs Mary Bowman Campaign ‐ RSPB OBJ2839 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2840 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2841 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2842 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2843 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2844 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2845 Campaign ‐ RSPB Withdrawn OBJ2846 G Blundell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2847 Michelle Moore Campaign ‐ RSPB Withdrawn

OBJ2848 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2849 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2850 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2851 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2852 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2853 Clare Morrice Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2854 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2855 Campaign ‐ RSPB Withdrawn OBJ2856 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2857 Ann Allen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2858 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 128 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2859 Mr Gwynedd Roberts Campaign ‐ RSPB

OBJ2860 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2861 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2862 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2863 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2864 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2865 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2866 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2867 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2868 K L Acton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2869 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2870 Stephen Aubin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2871 Elaine Osmond Campaign ‐ RSPB OBJ2872 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2873 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2874 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2875 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2876 Lisa Pritchard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2877 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2878 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2879 Annie Prosser Campaign ‐ RSPB & Woodland Trust

OBJ2880 Campaign ‐ RSPB Withdrawn

OBJ2881 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2883 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2884 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2885 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2887 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2888 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2889 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2890 Campaign ‐ RSPB Withdrawn

OBJ2891 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2892 Christine Jackson Campaign ‐ RSPB OBJ2893 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2894 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2895 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2896 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2897 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2898 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2899 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2900 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2901 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2902 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ2903 J M Montgomery Campaign ‐ RSPB OBJ2904 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2905 Yvonne Harvey Campaign ‐ RSPB OBJ2906 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 129 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ2907 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2908 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2909 Campaign ‐ RSPB Withdrawn

OBJ2910 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2911 Mr Alan Camfield Campaign ‐ RSPB OBJ2912 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2913 Helen Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2914 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2915 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2916 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2917 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2919 Roy Dale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2920 T M Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2921 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2922 Mrs Margaret Rowan Campaign ‐ RSPB OBJ2923 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2925 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2926 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2927 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2928 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2929 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2930 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2931 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2932 R Yockney Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2933 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2934 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2935 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2936 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2937 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2938 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2939 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2940 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2941 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2942 Mr Adam Wells Campaign ‐ RSPB OBJ2943 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2944 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2945 Mrs Philippa James Campaign ‐ RSPB OBJ2946 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2947 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2948 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2949 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2950 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2951 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2952 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2953 Karen Boardman Campaign ‐ RSPB OBJ2954 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2955 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2956 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2957 Shirley Jukes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 130 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ2958 Mrs Jennifer Andrews Campaign ‐ RSPB

OBJ2959 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2960 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2961 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2962 Campaign ‐ RSPB Withdrawn OBJ2963 Jayne Johnson Campaign ‐ RSPB Withdrawn OBJ2964 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2965 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2966 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2967 Campaign ‐ RSPB Withdrawn

OBJ2968 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2969 Mrs Penelope Newman Campaign ‐ RSPB OBJ2970 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2971 Campaign ‐ RSPB Withdrawn

OBJ2972 Thelma Potts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2973 Mrs P A Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2974 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2975 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2976 Cheryl Cummings Campaign ‐ RSPB & Woodland Trust OBJ2977 Campaign ‐ RSPB Withdrawn OBJ2978 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2979 Mrs Wendy Hatton Campaign ‐ RSPB OBJ2980 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2981 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2982 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2983 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2984 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2985 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2986 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2987 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2988 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ2989 Campaign ‐ RSPB Withdrawn

OBJ2990 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2991 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2992 Raymond Parsons Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ2993 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2994 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2995 Campaign ‐ RSPB Withdrawn OBJ2996 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2997 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2998 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ2999 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3000 Campaign ‐ RSPB Withdrawn OBJ3001 Campaign ‐ RSPB Withdrawn OBJ3002 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3003 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3004 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 131 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3005 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3006 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3007 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3008 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3009 Richard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3010 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3011 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3012 Karen Sellwood Campaign ‐ RSPB OBJ3013 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3014 Campaign ‐ RSPB Withdrawn

OBJ3015 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3016 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3017 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3018 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3019 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3020 John Pibworth Campaign ‐ RSPB Withdrawn OBJ3021 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3022 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3023 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3024 Jan Harding Campaign ‐ RSPB Withdrawn OBJ3025 Anne Digby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3026 Richard Wilton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3027 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3028 Marisa Benjamin Campaign ‐ RSPB

OBJ3029 Campaign ‐ RSPB Withdrawn OBJ3030 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3031 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3032 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3033 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3034 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3035 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3036 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3037 N R Pinde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3038 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3039 Campaign ‐ RSPB Withdrawn OBJ3040 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3041 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3042 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3043 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3044 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3045 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3046 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3047 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3048 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3049 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3050 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3051 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3052 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 132 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ3053 Pamela M Towlson Campaign ‐ RSPB

OBJ3054 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3055 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3056 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3057 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3058 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3059 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3060 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3061 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3062 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3063 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3064 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3065 Campaign ‐ RSPB Withdrawn OBJ3066 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3067 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3068 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3069 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3071 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3072 Tom Coomer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3073 Anne C Shannon Campaign ‐ RSPB OBJ3074 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3075 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3076 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3077 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3078 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3079 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3080 Campaign ‐ RSPB Withdrawn

OBJ3081 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3082 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3083 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3084 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3085 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3086 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3087 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3088 Miss Joanne Maxwell Campaign ‐ RSPB OBJ3089 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3090 Mrs J D Bagnall Campaign ‐ RSPB

OBJ3091 Campaign ‐ RSPB Withdrawn OBJ3092 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3093 Mrs Ruth Griffiths Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3094 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3095 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3096 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3097 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3098 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3099 Jean Prandy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3100 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3101 Pauline Richards Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 133 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3103 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3104 Wayne Carr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3105 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3106 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3107 Kevin Harwood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3108 Rosalind Danks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3109 Mr William Rich Campaign ‐ RSPB OBJ3110 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3111 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3112 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3114 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3115 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3116 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3117 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3118 Campaign ‐ RSPB Withdrawn OBJ3119 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3120 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3121 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3122 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3123 Miss Melissa Dewsbery Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3124 Mrs Christine Knox Campaign ‐ RSPB OBJ3125 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3126 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3127 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3128 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3129 Campaign ‐ RSPB Withdrawn OBJ3130 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3131 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3132 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3133 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3134 Noel Allan Campaign ‐ RSPB Withdrawn OBJ3135 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3136 Campaign ‐ RSPB Withdrawn OBJ3137 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3138 Richard Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3139 Campaign ‐ RSPB Withdrawn OBJ3140 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3141 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3142 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3143 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3144 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3145 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3146 Robert Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3148 Campaign ‐ RSPB Withdrawn

OBJ3149 Campaign ‐ RSPB Withdrawn

OBJ3150 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3151 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 134 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3152 Campaign ‐ RSPB Withdrawn

OBJ3153 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3154 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3155 Campaign ‐ RSPB Withdrawn OBJ3156 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3157 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3158 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3159 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3160 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3161 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3162 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3163 M E Merrells Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3164 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3165 D Marcham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3166 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3167 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3168 Sarah Steer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3169 Jilly Newham Campaign ‐ RSPB OBJ3170 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3171 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3172 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3173 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3174 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3175 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3176 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3177 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3178 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3179 Elaine Plummer Campaign ‐ RSPB OBJ3180 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3181 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3183 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3184 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3185 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3186 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3187 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3188 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3189 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3190 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3191 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3192 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3193 C A Clemson Campaign ‐ RSPB Withdrawn OBJ3194 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3195 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3196 Campaign ‐ RSPB OBJ3197 Mr Trevor Barton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3198 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3199 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3200 Steve Jerrams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3201 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3202 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3203 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 135 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3204 Campaign ‐ RSPB Withdrawn OBJ3205 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3206 Campaign ‐ RSPB OBJ3207 Roderick Lees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3208 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3209 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3210 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3211 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3212 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3213 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3214 Lesley Fleming Campaign ‐ RSPB OBJ3215 Ms Lynne Bartlett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3216 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3217 Campaign ‐ RSPB OBJ3218 Miss Rebecca Appleby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3219 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3220 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3221 Campaign ‐ RSPB Withdrawn OBJ3222 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3223 Ann Turtle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3224 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3225 Campaign ‐ RSPB

OBJ3226 Miss J A Cook Campaign ‐ RSPB Withdrawn

OBJ3227 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3228 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3229 Campaign ‐ RSPB Withdrawn OBJ3230 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3231 R G Spiller Campaign ‐ RSPB Withdrawn

OBJ3232 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3233 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3234 Campaign ‐ RSPB Withdrawn OBJ3235 Helen Arthur Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3236 Stephen Shutt Campaign ‐ RSPB Withdrawn OBJ3238 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3239 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3240 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3241 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3242 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3243 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3244 Campaign ‐ RSPB Withdrawn OBJ3245 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3246 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3247 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3248 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3249 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3250 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3251 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 136 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3252 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3254 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3255 Campaign ‐ RSPB Withdrawn

OBJ3256 Mr John Tyrrell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3257 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3258 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3259 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3260 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3261 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3262 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3263 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3264 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3265 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3266 Jill McKeown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3267 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3268 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3269 Campaign ‐ RSPB Withdrawn OBJ3270 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3271 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3272 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3273 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3274 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3275 Campaign ‐ RSPB OBJ3276 Carolyn Llewellyn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3277 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3278 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3279 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3280 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3281 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3282 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3283 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3284 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3285 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3286 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3287 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3288 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3289 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3290 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3291 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3292 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3293 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3294 Ben Gale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3295 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3296 Campaign ‐ RSPB Withdrawn OBJ3297 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3298 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3299 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3300 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3301 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3302 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3303 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3304 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 137 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3305 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3306 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3307 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3308 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3309 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3310 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3311 Campaign ‐ RSPB Withdrawn OBJ3312 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3313 Campaign ‐ RSPB Withdrawn OBJ3314 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3315 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3316 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3317 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3318 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3319 H J Phillips Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3320 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3321 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3322 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3323 Campaign ‐ RSPB OBJ3324 Miss Tina Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3325 Campaign ‐ RSPB Withdrawn

OBJ3326 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3327 Janet Thorne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3328 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3329 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3330 Campaign ‐ RSPB OBJ3331 Miss Julie Davis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3332 Campaign ‐ RSPB Withdrawn OBJ3333 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3334 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3335 Campaign ‐ RSPB Withdrawn

OBJ3336 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3337 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3338 Mr Hywel Wyn Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3339 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3340 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3341 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3342 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3343 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3344 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3345 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3346 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3347 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3348 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3349 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3350 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3351 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3352 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3353 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 138 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3354 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3355 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3356 S J Livings Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3357 Campaign ‐ Wildlife Trusts Wales Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3358 Pamela Ireland Campaign ‐ RSPB OBJ3359 Miss Jane Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3360 Willie O'Neill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3361 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3362 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3363 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3364 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3365 Campaign ‐ RSPB Withdrawn OBJ3366 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3367 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3368 Phil Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3369 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3370 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3371 S Godwin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3372 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3373 A S Kilmurray Campaign ‐ RSPB Withdrawn OBJ3374 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3375 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3376 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3377 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3378 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3379 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3380 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3381 Revd S Newby Campaign ‐ RSPB OBJ3382 Mrs Christine Stockley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3383 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3384 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3385 Campaign ‐ RSPB Withdrawn OBJ3386 Mary Rice Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3387 Campaign ‐ RSPB Withdrawn OBJ3388 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3389 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3390 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3391 Anthony Hathaway Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3392 Campaign ‐ RSPB Withdrawn

OBJ3393 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3394 R Blocksidge Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3395 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3396 J A Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3397 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3398 Campaign ‐ RSPB OBJ3399 Mr Colin Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3400 Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 139 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3401 Rachel French Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3402 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3403 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3404 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3405 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3406 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3407 Kate Hawkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3408 Campaign ‐ RSPB Withdrawn OBJ3409 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3410 Campaign ‐ RSPB OBJ3411 Miss Leigh Arthur Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3412 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3413 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3414 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3415 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3416 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3417 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3418 Campaign ‐ RSPB Withdrawn

OBJ3419 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3420 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3421 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3422 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3423 J Carroll Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3424 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3425 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3426 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3428 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3429 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3430 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3431 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3432 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3433 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3434 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3435 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3436 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3437 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3438 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3439 Campaign ‐ RSPB OBJ3440 Howard Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3441 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3442 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3443 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3444 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3445 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3446 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3447 Alan Prosper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3448 Campaign ‐ RSPB Withdrawn OBJ3449 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3450 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3451 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 140 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3452 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3453 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3454 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3455 Campaign ‐ RSPB Withdrawn

OBJ3456 M Clark Campaign ‐ RSPB Withdrawn

OBJ3457 Stuart N Taylor Campaign ‐ RSPB Withdrawn OBJ3458 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3459 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3460 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3461 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3462 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3463 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3464 Janet Butt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3465 Campaign ‐ RSPB OBJ3466 Anthony Bundey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3467 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3468 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3469 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3470 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3471 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3472 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3473 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3474 Campaign ‐ RSPB Withdrawn

OBJ3475 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3476 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3477 Campaign ‐ RSPB Withdrawn OBJ3478 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3479 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3480 L Potts Campaign ‐ RSPB OBJ3481 Mrs Sian Howley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3482 Campaign ‐ RSPB OBJ3483 Andrew Warner Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3484 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3485 Kathryn Rhys Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3486 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3487 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3488 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3489 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3490 Campaign ‐ RSPB

OBJ3491 Leonard Jessup Campaign ‐ RSPB Withdrawn OBJ3492 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3493 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3494 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3495 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3496 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3497 Campaign ‐ RSPB Withdrawn OBJ3498 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3499 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 141 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3500 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3501 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3502 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3503 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3504 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3505 Gareth Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3506 Neil Beattie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3507 Campaign ‐ RSPB OBJ3508 Miss Christine Lassam Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3509 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3510 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3511 Campaign ‐ RSPB Withdrawn OBJ3512 E Kay Milburn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3513 Campaign ‐ RSPB Withdrawn OBJ3515 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3516 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3517 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3518 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3519 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3520 Jeremy Spoor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3521 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3522 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3523 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3524 Campaign ‐ RSPB Withdrawn OBJ3525 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3526 Campaign ‐ RSPB Withdrawn OBJ3527 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3528 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3529 Nicola de Val Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3530 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3531 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3532 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3533 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3534 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3535 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3536 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3537 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3538 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3539 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3540 David Gilbert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3541 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3542 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3543 Campaign ‐ RSPB Withdrawn OBJ3544 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3545 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3546 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3547 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3548 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3549 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3550 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3551 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 142 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3552 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3553 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3554 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3555 Campaign ‐ RSPB Withdrawn

OBJ3556 Mrs Annette Stokes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3557 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3558 Campaign ‐ RSPB OBJ3559 Mrs Mona McFarlane Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3560 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3561 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3562 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3563 Alec Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3564 Susan Miller Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3565 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3566 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3567 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3568 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3569 N Wilkinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3570 Campaign ‐ RSPB Withdrawn

OBJ3571 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3572 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3573 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3574 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3575 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3576 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3577 Campaign ‐ RSPB Withdrawn OBJ3578 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3579 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3580 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3581 Campaign ‐ RSPB Withdrawn OBJ3582 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3583 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3584 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3585 Campaign ‐ RSPB Withdrawn OBJ3586 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3587 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3589 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3590 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3591 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3592 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3593 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3594 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3595 Campaign ‐ RSPB Withdrawn OBJ3596 N Duce Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3597 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3598 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3599 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3600 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3601 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3602 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 143 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3603 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3604 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3605 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3606 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3607 Glyn James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3608 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3609 Campaign ‐ RSPB Withdrawn OBJ3610 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3611 Campaign ‐ RSPB Withdrawn OBJ3612 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3613 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3614 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3615 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3616 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3617 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3618 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3619 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3620 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3621 L Rees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3622 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3623 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3624 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3625 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3626 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3627 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3628 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3629 Sarah Morgan Campaign ‐ RSPB Withdrawn OBJ3630 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3631 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3632 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3633 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3634 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3635 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3636 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3637 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3638 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3639 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3640 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3641 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3642 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3643 Campaign ‐ RSPB Withdrawn

OBJ3644 Campaign ‐ RSPB Withdrawn

OBJ3645 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3646 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3647 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3648 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3649 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3650 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3651 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3652 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3653 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3654 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 144 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3655 Bev Khan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3656 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3657 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3658 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3659 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3660 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3661 Roger Lucken Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3662 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3663 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3664 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3665 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3666 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3667 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3668 Campaign ‐ RSPB Withdrawn OBJ3669 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3670 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3671 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3672 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3673 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3674 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3675 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3676 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3677 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3678 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3679 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3680 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3681 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3682 Zoe Buswell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3683 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3684 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3685 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3686 Sophy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3687 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3688 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3689 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3690 J A Bennett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3691 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3692 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3693 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3694 Pauline Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3695 S Warren Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3696 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3697 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3698 Campaign ‐ RSPB OBJ3699 Mr Martin Parsons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3700 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3701 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3702 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3703 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3704 Campaign ‐ RSPB OBJ3705 Gillian Howarth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3706 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 145 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3707 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3708 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3709 Jennie Osborn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3710 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3711 Campaign ‐ RSPB Withdrawn OBJ3712 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3713 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3714 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3715 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3716 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3717 Campaign ‐ RSPB Withdrawn OBJ3718 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3719 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3720 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3721 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3722 Campaign ‐ RSPB OBJ3723 Miss Katie Nethercoat Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3724 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3725 Ben Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3726 Ian Barrett Campaign ‐ RSPB Withdrawn

OBJ3727 Campaign ‐ RSPB Withdrawn

OBJ3728 Miss Faya Patterson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3729 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3730 L Colley Campaign ‐ RSPB OBJ3731 Mr Steve Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3732 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3733 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3734 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3735 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3736 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3737 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3738 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3739 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3740 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3741 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3742 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3743 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3744 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3745 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3746 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3747 Mr Harry Drew Campaign ‐ RSPB OBJ3748 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3749 Laura Warren Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3750 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3751 Miss Josie Hewitt Campaign ‐ RSPB OBJ3752 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3753 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3754 Mr Robert Magee Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 146 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3755 Jennifer Lusty Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3756 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3757 Ms Katie Luxton Campaign ‐ RSPB OBJ3758 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3759 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3760 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3761 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3762 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3763 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3764 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3765 Campaign ‐ RSPB Withdrawn OBJ3766 Nick Barwick Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3767 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3768 Beverley Anne Ockwell Campaign ‐ RSPB OBJ3769 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3770 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3771 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3772 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3773 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3774 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3775 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3776 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3777 jean elliott Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3778 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3779 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3780 Campaign ‐ RSPB Withdrawn

OBJ3781 Allan Dowson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3782 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3783 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3784 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3785 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3786 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3787 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3788 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3789 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3790 Campaign ‐ RSPB Withdrawn OBJ3791 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3792 Judy Impey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3793 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3794 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3795 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3796 Loretta Smart Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3797 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3798 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3799 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3800 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3801 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3802 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3803 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 147 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ3804 Christine Chilton Campaign ‐ RSPB

OBJ3805 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3806 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Bob and Margaret OBJ3807 Campaign ‐ RSPB Marsland

OBJ3808 Campaign ‐ RSPB Withdrawn

OBJ3809 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3810 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3811 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3812 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3813 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3814 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3815 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3816 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3817 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3818 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3819 Campaign ‐ RSPB Withdrawn

OBJ3820 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3821 Mrs R M Bray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3822 Miss Julie Donaldson Campaign ‐ RSPB OBJ3823 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3824 Charlene Davies Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3825 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3826 Campaign ‐ RSPB Withdrawn OBJ3827 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3828 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3829 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3830 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3831 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3832 Pat Haley Campaign ‐ RSPB Withdrawn OBJ3833 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3834 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3835 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3836 Campaign ‐ RSPB Withdrawn

OBJ3837 Campaign ‐ RSPB Withdrawn OBJ3838 Campaign ‐ RSPB Withdrawn OBJ3839 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3840 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3841 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3842 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3843 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3844 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3845 Mrs Michele Harrison Campaign ‐ RSPB Withdrawn

OBJ3846 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3847 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3848 Brian Kemplay Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 148 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3849 Campaign ‐ RSPB Withdrawn OBJ3850 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3851 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3852 K Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3853 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3854 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3855 Sybil Mizon‐Hind Campaign ‐ RSPB Withdrawn

OBJ3856 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3857 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3858 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3859 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3860 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3861 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3862 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3863 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3864 M Seymour Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3865 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3866 Vicky Gaunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3867 Campaign ‐ RSPB Withdrawn OBJ3868 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3869 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3870 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3871 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3872 Miss Carol Jacklin Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ3874 Mrs Sarah Blyth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3875 Mrs Jayne Dunajko Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3876 Mr Robert Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3877 Miss Sylvia Jay Campaign ‐ RSPB OBJ3878 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3879 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3880 Mr John Cook Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3881 Mr John Winder Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3882 Mr Jamie Allan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3883 Mr Murray Orchard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3884 Miss Tim Hughes Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ3885 Miss Chloe Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3886 Miss Sandra Egan Campaign ‐ RSPB OBJ3887 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3888 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3889 Charmaine Hulbert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3890 Mr Michael Welsh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3891 Mrs Sue Dewhurst Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 149 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ3892 Mrs Corinne Ponsford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3893 Mrs Teresa Mitchell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3894 Mr Andrew Bissitt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3895 Miss Joan Potter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3896 Mr Norman Ives Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3897 Mrs Joanne Lowe Campaign ‐ RSPB OBJ3898 Mr John Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3899 Miss G Lewis Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ3900 Miss Sarah Gray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3901 Mr Keith Symonds Campaign ‐ RSPB OBJ3902 Mr J C Rolls Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3903 Mrs Lynne Cornock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3904 Mr Mike Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3905 Mr George Rowden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3906 Mrs Debbie Bardo Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ3907 Miss Katie Parkin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3908 Mr David Graham Campaign ‐ RSPB OBJ3909 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3910 Mr Julian Mitchell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3911 Mrs Diane Emms Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3912 Miss Diane Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3913 Miss Linda Beard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3914 Mrs Rachel Edwards Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3915 Dr Martin Miller Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3916 Miss Terina Notz Campaign ‐ RSPB OBJ3917 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3918 Judith Flynn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3919 Miss Marilyn Jones Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3920 Ms Hilary Rosser Campaign ‐ RSPB OBJ3921 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3922 Keith Rose Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3923 Miss Gemma Simmons Campaign ‐ RSPB OBJ3924 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3925 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Elisabeth WG/REB/OBJ0030 ‐ RSPB OBJ3926 Campaign ‐ RSPB Mulholland OBJ3927 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 150 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3928 Neil Hopkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3929 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3930 Campaign ‐ RSPB Withdrawn OBJ3931 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3932 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3933 Mr David Brear Campaign ‐ RSPB OBJ3934 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3935 Campaign ‐ RSPB Withdrawn OBJ3936 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3937 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3938 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3939 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3940 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3941 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3942 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3943 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3944 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3945 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3946 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3947 Mr Paul Gilbert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3948 Miss Catherine Dawson Campaign ‐ RSPB

OBJ3949 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3950 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3951 Jenny Thomas Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ3952 T P Lewis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3953 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3954 Mrs Janet Blackburn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3955 Miss Nadia Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3956 Mrs Alison Guy Campaign ‐ RSPB OBJ3957 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3958 Mr Roger Lloyd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3959 Miss Rebecca Saunders Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3960 Miss Beth Thoren Campaign ‐ RSPB OBJ3961 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3962 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3963 M Bailey Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3964 Mr John Cawley Campaign ‐ RSPB OBJ3965 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ3966 Campaign ‐ RSPB Withdrawn

OBJ3967 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3968 Mr Tom Biddulph Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3969 Ms Emma Walker Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 151 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ3970 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3971 Jill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3972 Mr David Rees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3973 Mrs Rita Myatt‐Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3974 Mr John Goodwin Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ3975 Mr Neil Gaskin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3976 Miss Lauren Foster Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3977 Mr Christopher Wells Campaign ‐ RSPB

WG/REB/OBJ0030 ‐ RSPB OBJ3978 Dr David Martin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3979 Miss Sue Everett Campaign ‐ RSPB Dr Helen Sims‐ WG/REB/OBJ0030 ‐ RSPB OBJ3980 Campaign ‐ RSPB Coomber WG/REB/OBJ0030 ‐ RSPB OBJ3981 Mrs Val Jackson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3982 Mr Andrew Jenkinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3983 Dr Melissa Dixon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3984 Miss Nadia Shaikh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3985 Mr Fiona Underhill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3986 Ms Jo Williamson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3987 Ms Heather Bridgland Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3988 Mr Chris Hudson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3989 Mr David Petre Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3990 Miss Shani Allan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3991 Ms Lesley Bryson Campaign ‐ RSPB

OBJ3992 Mr Darryl Spittle Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ3993 Mr Daniel Trotman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3994 Mrs Juliet Michael Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3995 Mr Duncan Watson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3996 Miss Flavia Lungu Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3997 Mr Owen Erasmus Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ3998 Ms Sarah Dixon Campaign ‐ RSPB Mrs Prudence WG/REB/OBJ0030 ‐ RSPB OBJ3999 Campaign ‐ RSPB Robinson WG/REB/OBJ0030 ‐ RSPB OBJ4000 Mr David Bateson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Katherine OBJ4001 Campaign ‐ RSPB Lambeth

REVISED M4CAN objections schedule of evidence.xlsm 152 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4002 Mr Ken Maurice Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4003 Mrs Dawn Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4004 Mrs Charlotte Denovan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4005 Mr Mike Skelton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4006 Mr John Badley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4007 Mr Titus Leskov Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4008 Mrs Caroline McManus Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4009 Mr Brian Ashfield Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4010 Mr Des McKenzie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4011 Miss Jennifer Caffrey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4012 Mr David Walker Campaign ‐ RSPB OBJ4013 Mr Ray Roche Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4014 Mr Michael Hogan Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ4015 Mr Oliver Clanford Campaign ‐ RSPB OBJ4016 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4017 Mrs Gill Saunders Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4018 Mrs Elspeth Williams Campaign ‐ RSPB

OBJ4019 Mrs Anthea Unsworth Campaign ‐ RSPB Withdrawn

OBJ4020 Nic Gande Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4021 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4022 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4023 Mrs Jackie Parry Campaign ‐ RSPB OBJ4024 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4025 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4026 Mrs Patricia Gillan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4027 Mrs Martine Sommers Campaign ‐ RSPB

OBJ4028 Mrs Carol Silvers Campaign ‐ RSPB Withdrawn

OBJ4029 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4030 Miss Sally Woolacott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4031 Dr Anthony Temple Campaign ‐ RSPB OBJ4032 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4033 Mrs Kerry Wheatley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4034 Mr David Bevan Campaign ‐ RSPB OBJ4035 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4036 Campaign ‐ RSPB Withdrawn

OBJ4037 Mrs Anne Coker Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 153 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4038 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4039 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4040 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4041 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4042 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4043 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4044 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4045 Miss Susan Bloss Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4046 Mr Mark Cocker Campaign ‐ RSPB

OBJ4047 Mrs Janet Aunins Campaign ‐ RSPB Withdrawn

OBJ4048 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4049 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4050 Mr Wayne Hodges Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4051 Mrs Mary Jamieson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4052 Mr Martin Jefferies Campaign ‐ RSPB

OBJ4053 Mrs Jillian McCauley Campaign ‐ RSPB Withdrawn

OBJ4054 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4055 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4056 Mr David Elias Campaign ‐ RSPB OBJ4057 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4058 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4059 Ms Annie Irving Campaign ‐ RSPB OBJ4060 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4061 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4062 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4063 Miss Mark Waters Campaign ‐ RSPB

OBJ4064 Mrs Suzanne Morris Campaign ‐ RSPB Withdrawn

OBJ4065 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4066 Mrs Linda Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4067 Mr Martin Taylor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4068 Mr Richard Hopkin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4069 Ms Jean Rainey Campaign ‐ RSPB OBJ4071 Mr Tom Gale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4072 Mrs Alison Bevin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4073 Mr Simon Gould Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4074 Mr Terence Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4075 Mr Donald Pugh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4076 Mrs Alice Hardiman Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 154 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4077 Mrs Sheila Corns Campaign ‐ RSPB

OBJ4078 Mr Mike Cleary Campaign ‐ RSPB Withdrawn

OBJ4079 Miss Liz Kerr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4080 Mr Chris Morris Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4081 Mrs Valerie Mann Campaign ‐ RSPB OBJ4082 Mr Tim Corke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4083 Mrs Susan Swift Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4084 Mr David Burns Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4085 Ms Danielle Styles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4086 Dr Guy Anderson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4087 Mr Perry Pericleous Campaign ‐ RSPB OBJ4088 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4089 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4090 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4091 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4092 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4093 Ms F Collier Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4094 Miss Donna Elliott Campaign ‐ RSPB OBJ4095 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4096 Michael Harvey Campaign ‐ RSPB OBJ4097 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4098 Mrs Vivienne Luxton Campaign ‐ RSPB OBJ4099 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4100 Ms Polly Pearshouse Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ4101 Mr Richard Beason Campaign ‐ RSPB OBJ4102 S Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4103 Mr Mark Roske Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4104 Mrs Karen Corley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4105 Mr and Mrs Bewley Campaign ‐ RSPB OBJ4106 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4107 D Green Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4108 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4109 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4110 Mr Peter Collins Campaign ‐ RSPB OBJ4111 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4112 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4113 Sue Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4114 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4115 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4116 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4117 Mr Chris Rose Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 155 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4118 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4119 Diane Griffiths Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4120 Mrs Rebecca Wade Campaign ‐ RSPB OBJ4121 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4122 Ms Adrienne Stratford Campaign ‐ RSPB OBJ4123 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4124 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4125 Mrs Jan Sim Campaign ‐ RSPB Withdrawn

OBJ4126 J Logie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4127 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4128 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4129 Mr Kevin Davies Campaign ‐ RSPB OBJ4130 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4131 Mrs Sarah Bird Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4132 Ms Marguerite Walters Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4133 Mr Paul Squires Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4134 Dr Adam Hudson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4135 Mrs Susan Robinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4136 Mr Shane Enright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4137 Mr Ben Dickinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4138 Mrs Barbara O'Hara Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4139 Dr Mark Fishpool Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4140 Mrs Elsie Keymer Campaign ‐ RSPB OBJ4141 Mr Ralph Lilley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4142 Miss Alison Hope Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4143 Mrs Lyn Snowdon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4144 Dr Susan Rands Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4145 Mrs Valerie Adamson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4146 Mr William Aldred Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4147 Mr Alfie Temple Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4148 Mr Geraint Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4149 Mr Les Stretton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4150 Mrs Ros Hammerton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4151 Mr Colin Barthorpe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4152 Mr Jeffrey Wragg Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4153 Mr Michael Butler Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 156 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4154 Dr Michael Fogden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4155 Miss Katy Fielding Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4156 Mrs Alison Hartley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4157 Mr Stephen Proctor Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4158 Miss Salma Haidrani Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4159 Ms Gail Clarke Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4160 Mr Sean Browne Campaign ‐ RSPB OBJ4161 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4162 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4163 Miss Sarah Owen Campaign ‐ RSPB OBJ4164 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4165 Kevin Henry Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ4166 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4167 Mr Gareth Brookfield Campaign ‐ RSPB OBJ4168 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4169 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4170 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4171 Mrs Jill Dunnett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4172 Mrs Elizabeth Higman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4173 Miss Sophie PonsfordCampaign ‐ RSPB OBJ4174 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4175 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4176 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4177 Mr Richard Hutt Campaign ‐ RSPB OBJ4178 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4179 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4180 Sheila Gardner Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4181 Mr Douglas Landman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4182 Mr Mark Bannister Campaign ‐ RSPB OBJ4183 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4184 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4185 Miss Miranda Michels Campaign ‐ RSPB OBJ4186 Mrs Rita Carr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4187 Mr James Foster Campaign ‐ RSPB OBJ4188 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4189 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4190 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4191 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4192 Catherine Waddington Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 157 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4193 Mrs Ann Southern Campaign ‐ RSPB

OBJ4194 Mr Carl Ward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4195 Mr Anthony Pawson Campaign ‐ RSPB OBJ4196 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4197 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4198 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4199 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4200 Mrs Clare Mullaney Campaign ‐ RSPB OBJ4201 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4202 Campaign ‐ RSPB Withdrawn OBJ4203 Campaign ‐ RSPB Withdrawn OBJ4204 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4205 Miss Susan Monteiro Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4206 Miss Janet Palmer Campaign ‐ RSPB OBJ4207 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4208 Helen Jackson Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ4209 Malcolm Waters Campaign ‐ RSPB

OBJ4210 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4211 Mr Paul Pearson Campaign ‐ RSPB OBJ4212 Elaine Cooper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4213 Mr Jeff Clarke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4214 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4215 Mr Roger Dunn Campaign ‐ RSPB OBJ4216 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4217 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4218 Sheila Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4219 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4220 Miss Hilary Parker Campaign ‐ RSPB OBJ4221 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4222 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4223 Mr David Perrow Campaign ‐ RSPB OBJ4224 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4225 Miss Elizabeth Jones Campaign ‐ RSPB OBJ4226 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4227 Mr Stephen Grubb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4228 Mr Stuart Bechares Campaign ‐ RSPB OBJ4229 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4230 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4231 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4232 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4233 Mr Graham Piner Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 158 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4234 Mrs Carol Eyden Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4235 Mrs Jennifer Western Campaign ‐ RSPB OBJ4236 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4237 Miss Roslyn Swanston Campaign ‐ RSPB OBJ4238 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4239 Mr Howard Thomas Campaign ‐ RSPB OBJ4240 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4241 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4242 Mr Tim Suggitt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4243 Miss Jan Hunter Campaign ‐ RSPB OBJ4244 Jo Humphreys Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4245 Ms Diane Ward Campaign ‐ RSPB OBJ4246 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4247 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4248 H Prabucki Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4249 Mr John Linnell Campaign ‐ RSPB OBJ4250 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4252 Mr Guy Lawrence Campaign ‐ RSPB OBJ4253 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4254 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4255 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4256 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4257 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4258 Mr Ian Dobson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4259 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4260 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4261 M D Dixon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4262 Ms Catriona Gray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4263 Mr Thomas Adams Campaign ‐ RSPB OBJ4264 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4265 Campaign ‐ RSPB Withdrawn OBJ4266 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4267 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4268 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4269 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4270 Mr Robert Tunstall Campaign ‐ RSPB OBJ4271 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4272 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4273 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB / OBJ4274 Mr Mark Wildman Campaign ‐ RSPB Keith Jones WG1.18 PID‐43 OBJ4275 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4276 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4277 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4278 Dr Paul Gale Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 159 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4279 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4280 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4281 Mr Keith Sharman Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4282 Miss Sallu Conyers Campaign ‐ RSPB OBJ4283 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4284 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4285 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4286 Mr James Bevin Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ4287 Ms Elizabeth McGowan Campaign ‐ RSPB OBJ4288 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4289 Mr Gareth Roberts Campaign ‐ RSPB OBJ4290 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4291 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4292 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4293 Mrs Claire Hogg Campaign ‐ RSPB OBJ4294 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4295 Miss Patricia Speed Campaign ‐ RSPB OBJ4296 B Wootton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4297 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4298 Mrs Jennifer Wilson Campaign ‐ RSPB OBJ4299 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4300 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4301 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4302 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4303 Miss Eleri Wynne Campaign ‐ RSPB OBJ4304 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4305 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4306 John Waldon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4307 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4308 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4309 Carol D Fordy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4310 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4311 Miss Margaret Rhodes Campaign ‐ RSPB OBJ4312 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4313 Dr Gillian Lang Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4314 Ms Sara Goodwin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4315 Robert Chappell Campaign ‐ RSPB OBJ4316 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4317 Mr Craig Leitch Campaign ‐ RSPB OBJ4318 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4319 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4320 Mr Robert Maher Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 160 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4321 Campaign ‐ RSPB Withdrawn

OBJ4322 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4323 Miss Paula Redmond Campaign ‐ RSPB Withdrawn

OBJ4324 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4325 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4326 D A Davies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4327 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4328 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4329 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4330 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4331 Mr Michael Ledlie Campaign ‐ RSPB OBJ4332 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4333 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4334 Miss Beth Wild Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4335 Mrs Elaine Pleasance Campaign ‐ RSPB OBJ4336 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4337 Mr Michael Rook Campaign ‐ RSPB OBJ4338 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4339 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4340 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4341 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4342 Mr Fred Chance Campaign ‐ RSPB OBJ4343 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4344 Mrs Pam Young Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4345 Mrs Mary Maidment Campaign ‐ RSPB OBJ4346 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4347 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4348 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4349 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4350 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4351 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4352 Miss Jasmine Buckle Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4353 Dr Maya James Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ4354 Mr Mark Wells Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4355 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4356 Mrs Judy Jones Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4357 Mr Steve Smith Campaign ‐ RSPB OBJ4358 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4359 Mrs Sera Parry Campaign ‐ RSPB

OBJ4360 Beverley Banyard Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4361 Miss Sara Rees Campaign ‐ RSPB OBJ4362 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 161 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4363 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4364 Anthony J Attwood Campaign ‐ RSPB OBJ4366 Karla Elms Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4367 Campaign ‐ RSPB Withdrawn OBJ4368 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4369 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4370 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4372 Dr Helen Beardsell Campaign ‐ RSPB OBJ4373 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4374 Mr Mike Burdekin Campaign ‐ RSPB OBJ4375 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4376 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4377 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4378 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4379 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4380 Mr Andrew Barnett Campaign ‐ RSPB OBJ4381 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4382 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4383 Mr Llyr Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4384 Mrs Mo Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4385 Mr Ian Barthorpe Campaign ‐ RSPB OBJ4386 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4387 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4388 Mrs Diane Jefferies Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4389 Miss Tamsin Leah Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4390 Mr Samuel Whitfield Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Amelia Bennett OBJ4391 Campaign ‐ RSPB Margrave

OBJ4392 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4393 Mrs Sue Belcher Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4394 Mrs Monica Taylor Campaign ‐ RSPB OBJ4395 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4396 Mr Alan Pennells Campaign ‐ RSPB OBJ4397 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4398 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4399 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4400 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4401 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4402 Mrs Wendy Flockton Campaign ‐ RSPB OBJ4403 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4404 Mrs Eveline Clarke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4405 Mrs Margaret Brett Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 162 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4406 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4407 Jill Abell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4408 Miss Gloria Pearce Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4409 Miss Dafydd Pleming Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4410 Mrs Amanda Hatter Campaign ‐ RSPB OBJ4411 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4412 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4413 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4414 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4415 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4416 Mrs Alexandra Coopey Campaign ‐ RSPB OBJ4417 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4418 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4419 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4420 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4421 Mrs Jennifer Bignall Campaign ‐ RSPB OBJ4422 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4423 Mrs Sue Large Campaign ‐ RSPB Withdrawn OBJ4424 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4425 Miss Carol Johnston Campaign ‐ RSPB OBJ4426 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Lorraine WG/REB/OBJ0030 ‐ RSPB OBJ4427 Campaign ‐ RSPB Llewellyn OBJ4428 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4429 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4430 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4431 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4432 Dr Sarah Money Campaign ‐ RSPB OBJ4433 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4434 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4435 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4436 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4437 Mrs Natalie Brunt Campaign ‐ RSPB OBJ4438 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4439 Campaign ‐ RSPB Withdrawn OBJ4440 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4441 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4442 Miss Jackie Day Campaign ‐ RSPB OBJ4443 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4444 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4445 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4446 Campaign ‐ RSPB Withdrawn OBJ4447 Campaign ‐ RSPB & Woodland Trust Withdrawn OBJ4448 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4449 Roy Hambleton Campaign ‐ RSPB OBJ4451 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 163 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4452 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4453 Ms Elizabeth Hanson Campaign ‐ RSPB OBJ4454 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4455 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4456 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4457 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4458 Mrs Rosemary Fisher Campaign ‐ RSPB OBJ4459 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4460 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4461 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4462 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4463 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4464 Ms Samantha Baker Campaign ‐ RSPB OBJ4465 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4466 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4467 Janine Wimhurst Campaign ‐ RSPB OBJ4468 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4469 D R Keeling Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4470 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4471 Mrs Wendy Kennison Campaign ‐ RSPB OBJ4472 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4473 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4474 Mr Toby Branston Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4475 Elizabeth Brazier Campaign ‐ RSPB OBJ4476 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4477 Ms Catherine Best Campaign ‐ RSPB OBJ4478 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4479 Marylyn Bothamley Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ4480 Mr Noah Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4481 Mrs Josnna Matthew Campaign ‐ RSPB OBJ4482 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4483 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4484 Mr Robert Eade Campaign ‐ RSPB OBJ4485 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4486 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4487 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4488 Campaign ‐ RSPB Withdrawn

OBJ4489 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4490 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4491 Mrs Diane Gillborn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4492 Mrs Alison Vaspe Campaign ‐ RSPB OBJ4493 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4494 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4495 Dr Olly Watts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 164 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4496 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4497 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4498 Mr David Andrew Campaign ‐ RSPB OBJ4499 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4500 Miss Carmel Oakton Campaign ‐ RSPB OBJ4501 Barry Atkinson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4502 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4503 Mrs Penny Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4504 Robert Edwards Campaign ‐ RSPB

OBJ4505 Mrs Awel‐Haf Elias Campaign ‐ RSPB Withdrawn

OBJ4506 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4507 Mr Michael Casey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4508 Mr Stephen Lipscombe Campaign ‐ RSPB

OBJ4509 Mrs Alicia Holliday Campaign ‐ RSPB Withdrawn

OBJ4510 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4511 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4512 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4513 Mrs Anne Thackray Campaign ‐ RSPB OBJ4514 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4515 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4516 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4517 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4518 Ms Joan Adamson Campaign ‐ RSPB Withdrawn

OBJ4519 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4521 Dr James Hrastelj Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Nicholas OBJ4522 Campaign ‐ RSPB Pomiankowski

OBJ4523 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4524 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4525 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4526 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4527 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4528 Mr Antony Edwardes Campaign ‐ RSPB OBJ4529 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4530 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4531 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4532 Mr Roger Luxton Campaign ‐ RSPB OBJ4533 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4534 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4535 Steve penny Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ4536 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4537 Mrs Polly Donaldson Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 165 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4538 J Cottam Campaign ‐ RSPB Withdrawn OBJ4539 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4540 Mr Peter Tams Campaign ‐ RSPB

OBJ4541 Campaign ‐ RSPB Withdrawn OBJ4542 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4543 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4544 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4545 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4546 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4547 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4548 Mrs Julie White Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4549 Mrs Sharon Lord Campaign ‐ RSPB OBJ4550 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4551 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4552 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4553 Miss Cath Harris Campaign ‐ RSPB OBJ4554 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4555 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4556 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4557 Mr Andy Butler Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4558 Mrs Helen Crow Campaign ‐ RSPB OBJ4559 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4560 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4561 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4562 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4563 Barbara Reeves Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4564 Mrs Philippa Ward Campaign ‐ RSPB OBJ4565 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4566 Mr Andrew Bunting Campaign ‐ RSPB OBJ4567 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4568 Mrs Zoe Foster Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Mr William John WG/REB/OBJ0030 ‐ RSPB OBJ4569 Campaign ‐ RSPB Harding OBJ4570 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4571 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Stephanie OBJ4572 Campaign ‐ RSPB Landymore

OBJ4573 Mr Brian Collins Campaign ‐ RSPB Withdrawn

OBJ4574 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4575 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4576 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4577 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4578 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4579 Mr Ian Boyle Campaign ‐ RSPB Withdrawn OBJ4580 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4581 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 166 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4582 Mrs Beverley Thomas Campaign ‐ RSPB

OBJ4583 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4584 Campaign ‐ RSPB Withdrawn OBJ4585 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4586 Mrs Gillian Cook Campaign ‐ RSPB

OBJ4587 Shirley Webb Campaign ‐ RSPB Withdrawn OBJ4588 Mr Bob Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4589 Mrs Nicola Brown Campaign ‐ RSPB

OBJ4590 Campaign ‐ RSPB Withdrawn OBJ4591 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4592 Mr Terry Sibley Campaign ‐ RSPB OBJ4594 Mr John Ward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4595 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4596 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4597 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4598 Mr Steven Conroy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4599 Prof Oliver Fulton Campaign ‐ RSPB OBJ4600 Janet Coles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4601 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4602 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4603 Mr Huw Roberts Campaign ‐ RSPB OBJ4605 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4606 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4607 Miss Emma Roberts Campaign ‐ RSPB OBJ4608 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4609 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4610 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4611 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4612 Mr Rhys Davies Campaign ‐ Wildlife Trusts Wales Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4613 Mr James Cooper Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4614 Rosemary Waters Campaign ‐ RSPB

OBJ4615 Campaign ‐ RSPB Withdrawn OBJ4616 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4617 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4618 Ms Barbara Drummond Campaign ‐ RSPB OBJ4619 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4620 Steve Slack Campaign ‐ RSPB Withdrawn

OBJ4621 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4622 Campaign ‐ RSPB Withdrawn OBJ4623 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4624 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4625 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 167 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4626 Mrs Laura Wright Campaign ‐ RSPB

OBJ4627 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4628 Campaign ‐ RSPB Withdrawn OBJ4629 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4630 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4631 Mrs Sarah Reed Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4632 Ms Shirley Broughton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4633 Ms Gillian Parrish Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4634 Mrs Janet Sherwood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4635 Mrs Sarah Mitchell Campaign ‐ RSPB OBJ4636 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4637 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4638 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4639 Ms Ann Thompson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4640 Mr Philip Jones Campaign ‐ RSPB OBJ4641 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4642 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4643 Ms Ann Nutley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4644 Hermione Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4645 Mr Colin Neale Campaign ‐ RSPB OBJ4646 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4647 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4648 Sara Rees Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4649 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4650 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4651 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4652 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4653 Mr Eric Beard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4654 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Andrew WG/REB/OBJ0030 ‐ RSPB OBJ4655 Campaign ‐ RSPB Cunningham WG/REB/OBJ0030 ‐ RSPB OBJ4656 Mrs Barbara Miles Campaign ‐ RSPB OBJ4657 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4658 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4659 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4660 Gwynneth Flitters Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4661 Mrs Val Thompson Campaign ‐ RSPB

OBJ4662 Miss Sara Salvatore Campaign ‐ RSPB Withdrawn

OBJ4663 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4664 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4665 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4666 Campaign ‐ RSPB OBJ4667 Nicola Brophy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 168 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4668 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4669 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4670 Mrs Laurinda Luffman Campaign ‐ RSPB OBJ4671 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4672 Mrs Helen Strong Campaign ‐ RSPB OBJ4673 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4674 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4675 Thomas Martin Campaign ‐ RSPB OBJ4676 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4677 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4678 Ms Ann Dixon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4679 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4680 Miss Jill Calvert Campaign ‐ RSPB OBJ4681 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4682 Mr Edward Crabtree Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4683 Miss Elizabeth Clipson Campaign ‐ RSPB OBJ4684 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4685 Mr Adrian Cash‐James Campaign ‐ RSPB

OBJ4686 Mrs Diane Slaughter Campaign ‐ RSPB Withdrawn Miss Annette WG/REB/OBJ0030 ‐ RSPB OBJ4687 Campaign ‐ RSPB Waddington OBJ4688 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4689 Mr Chris Gee Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4690 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4691 Ms Susan Sutton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4692 Mrs Stella Procter Campaign ‐ RSPB OBJ4693 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4694 Miss Judith Riches Campaign ‐ RSPB OBJ4695 J Read Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4696 Mrs Judith Bambridge Campaign ‐ RSPB OBJ4697 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4698 Mrs Janet Hamon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4699 Anna‐Marie Clear Campaign ‐ RSPB OBJ4700 Campaign ‐ RSPB Withdrawn OBJ4701 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4702 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4703 Ms Zoe Davies Campaign ‐ RSPB OBJ4704 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4705 Campaign ‐ RSPB Withdrawn OBJ4706 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4707 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4708 Miss Kate Newman Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 169 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4709 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4710 Philip Plummer Campaign ‐ RSPB OBJ4711 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4712 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4713 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4714 Mr Spike Webb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4715 Ann Green Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ4716 Miss Bryony Thomson Campaign ‐ RSPB OBJ4717 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Jacqueline OBJ4718 Campaign ‐ RSPB Parkinson WG/REB/OBJ0030 ‐ RSPB OBJ4719 Ms Elaine Dunn Campaign ‐ RSPB OBJ4720 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4721 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4722 Paul McCarthy Campaign ‐ Wildlife Trusts Wales Withdrawn

OBJ4723 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4724 Mr Robert Williams Campaign ‐ RSPB OBJ4725 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4726 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4727 Campaign ‐ RSPB Withdrawn OBJ4728 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4729 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4730 Mr Robert Taylor Campaign ‐ RSPB OBJ4731 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4732 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4733 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4734 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4735 Miss Amy Vanstone Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4736 Mr Hugh Baggaley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4737 Miss Louise Secker Campaign ‐ RSPB OBJ4738 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4739 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4740 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Carolyn WG/REB/OBJ0030 ‐ RSPB OBJ4741 Campaign ‐ RSPB Scantlebury OBJ4742 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4743 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4744 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4745 Mr James Craigie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4746 Miss Andrea Valentine Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4747 Ms Tracey Field Campaign ‐ RSPB OBJ4748 Nikki Browne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4749 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 170 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

Miss Rosalind WG/REB/OBJ0030 ‐ RSPB OBJ4750 Campaign ‐ RSPB Launchbury OBJ4751 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4752 Mr Nick Folkard Campaign ‐ RSPB OBJ4753 Mrs D Alsford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4754 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4755 Mr Michael Frost Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Belinda Jane OBJ4756 Campaign ‐ RSPB Markham WG/REB/OBJ0030 ‐ RSPB OBJ4757 Mrs Vicky Bernays Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4758 Mr Andrew Rock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4759 Miss Jackie Buckle Campaign ‐ RSPB OBJ4760 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4761 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4762 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4763 Campaign ‐ RSPB Withdrawn OBJ4764 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4765 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4766 Mrs Lynn Loader Campaign ‐ RSPB Withdrawn

OBJ4767 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4768 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4769 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4770 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4771 Campaign ‐ RSPB OBJ4772 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4773 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4774 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4775 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4776 Mrs Natalie Thomas Campaign ‐ RSPB Prof Gruffydd Aled WG/REB/OBJ0030 ‐ RSPB OBJ4777 Campaign ‐ RSPB Williams OBJ4778 Mr Ian Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4779 Pauline Dillworth Campaign ‐ RSPB Withdrawn

OBJ4780 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4781 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4782 Campaign ‐ RSPB Withdrawn OBJ4783 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4784 Ms Bethan Lloyd Campaign ‐ RSPB OBJ4785 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4786 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4787 Campaign ‐ RSPB Withdrawn OBJ4788 Roger Moon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4789 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4790 Mrs Elizabeth Ackroyd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4791 Mr Gordon Haycock Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 171 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4792 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4793 Mr Michael Birley Campaign ‐ RSPB Withdrawn

OBJ4794 Mrs Rae Cecil Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4795 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4796 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4797 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4798 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4799 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4800 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4801 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4802 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4803 Mrs Sandra Payne Campaign ‐ RSPB OBJ4804 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4805 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4806 Mrs Sarah Jackson Campaign ‐ RSPB Withdrawn

OBJ4807 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4808 Miss Sarah Chilton Campaign ‐ RSPB OBJ4809 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4810 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4811 Miss Eleanor Wise Campaign ‐ RSPB OBJ4812 Peter Gaunt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4813 Mr Ken Maurice Campaign ‐ RSPB OBJ4814 Prof Bill Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4815 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4816 Mrs Hannah Brightman Campaign ‐ RSPB OBJ4817 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4818 Campaign ‐ RSPB Withdrawn OBJ4819 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4820 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4821 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4822 Mr Alfred Clarke Campaign ‐ RSPB OBJ4823 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4824 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4825 Mrs Gillian Duffy Campaign ‐ RSPB OBJ4826 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4827 Miss Sam Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4828 Mrs Lisa Morgan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4829 Miss Sian Wilks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4830 Mr Richard Jeynes Campaign ‐ RSPB

OBJ4831 Campaign ‐ RSPB Withdrawn Mr Raymond WG/REB/OBJ0030 ‐ RSPB OBJ4832 Campaign ‐ RSPB Sanderson OBJ4833 Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 172 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4834 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4835 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4836 Mr Kevin Rylands Campaign ‐ RSPB OBJ4837 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4838 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4839 Mr Erroll Dowman Campaign ‐ RSPB OBJ4840 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4841 Mrs Norma Kinnison Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4842 Miss Elisabeth Baker Campaign ‐ RSPB

OBJ4843 Campaign ‐ RSPB Withdrawn OBJ4844 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4845 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4846 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4847 Campaign ‐ RSPB Withdrawn

OBJ4848 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4849 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4850 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4851 Ms H Simmonds Campaign ‐ RSPB OBJ4852 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4853 Mrs Ann Lee Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4854 Mrs Caroline Irwin Campaign ‐ RSPB OBJ4855 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4856 Mrs Moyra Galliford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4857 Roger J Daniel Campaign ‐ RSPB OBJ4858 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Helen Amanda WG/REB/OBJ0030 ‐ RSPB OBJ4859 Campaign ‐ RSPB Lubin OBJ4860 Mr Mark Bould Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4861 Mr David Nursaw Campaign ‐ RSPB OBJ4862 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4863 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4864 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4865 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4866 Dawn Sprake ‐Follett Campaign ‐ RSPB Withdrawn

OBJ4867 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4868 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4869 Diana Hayman‐Joyce Campaign ‐ RSPB

OBJ4870 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4871 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4872 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4873 Mr Geoff Harding Campaign ‐ RSPB OBJ4874 P M Harris Campaign ‐ RSPB Withdrawn OBJ4875 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 173 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4876 Miss Alison Young Campaign ‐ RSPB

OBJ4877 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4878 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ4879 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4880 Mr David Frost Campaign ‐ RSPB OBJ4881 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4882 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4883 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4884 Miss Gina Thomson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4885 Amanda Collins Campaign ‐ RSPB OBJ4886 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4887 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4888 Ms Sally MacEachern Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4889 Mrs Helen Richards Campaign ‐ RSPB OBJ4890 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4891 Nikki Barnett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4892 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4893 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4894 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4895 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4896 Lynne Cook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4897 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4898 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4899 Miss Angela Joyce Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4900 Mr Richard Brown Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4901 Mr Peter Basterfield Campaign ‐ RSPB OBJ4902 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4903 Mrs Elizabeth Cornish Campaign ‐ RSPB OBJ4904 Campaign ‐ RSPB Withdrawn OBJ4905 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4906 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4907 Mrs Susan Moizer Campaign ‐ RSPB OBJ4908 Mr Ken Blake Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4909 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4910 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4911 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4912 Mr Raymond Critchley Campaign ‐ RSPB OBJ4913 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4914 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4915 Miss Valerie Jarrett Campaign ‐ RSPB OBJ4916 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4917 Mrs Alyson Bartlett Campaign ‐ RSPB

OBJ4918 Ms Shusha Lamoon Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 174 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ4919 Mr Julian French Campaign ‐ RSPB

OBJ4920 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4921 Mr Graham Allcock Campaign ‐ RSPB OBJ4922 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4923 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4924 Mr David Williams Campaign ‐ RSPB OBJ4925 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4926 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4927 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4928 Mr Roger Gibbs Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4929 Prof Nicholas Keep Campaign ‐ RSPB OBJ4930 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4931 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4932 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ4933 Dr David Burnett Campaign ‐ RSPB OBJ4934 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4935 Mrs Frances Tilbrook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4936 Mr Henry Cook Campaign ‐ RSPB OBJ4937 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4938 Mr Philip Burnham Campaign ‐ RSPB OBJ4939 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4940 Mrs Janet Scott Campaign ‐ RSPB OBJ4941 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4942 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4943 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4944 Mrs Margaret Boyes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4945 Mr Steve Howells Campaign ‐ RSPB OBJ4946 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4947 Mr Ray Allden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4948 Miss Wayne Watkins Campaign ‐ RSPB OBJ4949 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4950 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4951 Mrs Judith Roseblade Campaign ‐ RSPB OBJ4952 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4953 Miss Kirsty Osman Campaign ‐ RSPB OBJ4954 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4955 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4956 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4957 Campaign ‐ RSPB Withdrawn

OBJ4958 Mrs S Aindow Campaign ‐ RSPB Withdrawn

OBJ4959 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 175 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ4960 Lizzie Cork Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4961 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4962 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4963 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4964 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4965 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4966 Dr Joanna Crawshaw Campaign ‐ RSPB

OBJ4967 Campaign ‐ RSPB Withdrawn

OBJ4968 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4969 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4970 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4971 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4972 Mr Josh Petzoldt Campaign ‐ RSPB OBJ4973 Colin Morris Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4974 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4975 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4976 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4977 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4978 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4979 Mr A H McCoy Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4980 Mr Ray Reedman Campaign ‐ RSPB OBJ4981 Linda Osborn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4982 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4983 Mrs Sandra Aulton Campaign ‐ RSPB

OBJ4984 Mr Martin Kerby Campaign ‐ RSPB Withdrawn

OBJ4985 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4986 Campaign ‐ RSPB Withdrawn OBJ4987 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4988 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4989 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4990 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4991 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4992 Miss Emma McCauley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4993 Miss Gaynor Aston Campaign ‐ RSPB OBJ4994 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4995 Mrs Helen Kavanagh Campaign ‐ RSPB OBJ4996 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4997 Tim Pye Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4998 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ4999 T Dola Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5000 Mrs Lois Bradberry Campaign ‐ RSPB OBJ5001 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5002 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5003 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5004 Mrs Laura Curtis‐Moss Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 176 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5005 Mr Alan Postlethwaite Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5006 Mrs Mary Hayward Campaign ‐ RSPB OBJ5007 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5008 Mr Anthony Hopkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5009 Mr Brian Tooze Campaign ‐ RSPB OBJ5010 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5011 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5012 Mr Julian Weeks Campaign ‐ RSPB OBJ5013 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5014 Ms Pat Williams Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5015 Sylvia Collingwood Campaign ‐ RSPB OBJ5016 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5017 Mrs Liz Albert Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5018 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5019 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5020 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5021 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5022 Mrs Laura Thornley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5023 Mr Fred Towers Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5024 Mr Colin Slator Campaign ‐ RSPB OBJ5025 Andy Marshall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5026 Mr Robert Stephens Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Christophe OBJ5027 Campaign ‐ RSPB Patterson

OBJ5028 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5029 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5030 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5031 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5032 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5033 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5034 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5035 Ms Bev Maxwell Campaign ‐ RSPB OBJ5036 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5037 Mr Brian Lancastle Campaign ‐ RSPB OBJ5039 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5040 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5041 Mr Lyn Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5042 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5043 Mr Malcolm Curtis Campaign ‐ RSPB OBJ5044 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5045 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5046 Mrs Vicki James Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 177 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5047 Mr Gavin Jacobsen Campaign ‐ RSPB

OBJ5048 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5049 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5050 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5051 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5052 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5053 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5054 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5055 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Jeanette and Roger WG/REB/OBJ0030 ‐ RSPB OBJ5056 Campaign ‐ RSPB Bethell WG/REB/OBJ0030 ‐ RSPB Mr Christopher OBJ5057 Campaign ‐ RSPB Gerrans

OBJ5058 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5059 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5060 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5061 Miss Alice Tribe Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5062 Mr Nicholas Goulden Campaign ‐ RSPB OBJ5063 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5064 Miss Sally Nicholls Campaign ‐ RSPB OBJ5065 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5066 Mr Chris Grocock Campaign ‐ RSPB Withdrawn

OBJ5067 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5068 Mrs Robert Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5069 Elizabeth Sampson Campaign ‐ RSPB OBJ5070 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5071 Jane Gulliver Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Elizabeth OBJ5072 Campaign ‐ RSPB Withdrawn Armstrong OBJ5073 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5074 Campaign ‐ RSPB Withdrawn OBJ5075 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5076 Mr Malcolm Pike Campaign ‐ RSPB OBJ5077 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5078 Mr Mike Levett Campaign ‐ RSPB OBJ5079 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5080 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5081 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5082 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5083 Campaign ‐ RSPB Withdrawn

OBJ5084 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5085 Miss Danielle Roberts Campaign ‐ RSPB

OBJ5086 Campaign ‐ RSPB Withdrawn OBJ5087 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 178 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5088 Mrs Jean Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5089 Mr Robin Sandham Campaign ‐ RSPB OBJ5090 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5091 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5092 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5093 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5094 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5095 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5096 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5097 Dr Gerard Harris Campaign ‐ RSPB OBJ5098 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5099 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5100 D Knowles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5101 Alan Ashmead Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5102 Dr Brian Sutton Campaign ‐ RSPB OBJ5103 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5104 Miss Melanie Fryer Campaign ‐ RSPB Withdrawn

OBJ5105 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5106 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5107 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5108 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5109 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5110 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5111 Mrs Fiona Sharp Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5112 Mr David Denney Campaign ‐ RSPB OBJ5113 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5114 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5115 Ms Sally Johns Green Campaign ‐ RSPB OBJ5116 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5117 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5118 Mr Richard Andrews Campaign ‐ RSPB OBJ5119 Mrs Fiona Yuill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5120 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5121 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5122 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5123 Mr Keith Aldersley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5124 Miss Michelle Merrill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5125 Miss Glen O'Connell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5126 Miss Andrew Dove Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5127 Dr Christine Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5128 Mrs Celia Rickers Campaign ‐ RSPB OBJ5129 Campaign ‐ RSPB Withdrawn OBJ5130 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 179 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5131 Mr Dominic Cox Campaign ‐ RSPB

OBJ5132 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5133 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5134 Miss Jill Leason Campaign ‐ RSPB OBJ5135 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5136 Mrs Emma Price Campaign ‐ RSPB OBJ5137 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5138 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5139 Mrs Eileen Covill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5140 Mr Simon Rose Campaign ‐ RSPB Miss Christine WG/REB/OBJ0030 ‐ RSPB OBJ5141 Campaign ‐ RSPB Goodchild OBJ5142 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5143 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5144 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5145 John Eastaugh Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5146 Mr Michael Hinks Campaign ‐ RSPB OBJ5147 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5148 Dr Alan Cushway Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5149 Miss Rachel Carless Campaign ‐ RSPB

OBJ5150 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5151 Ms Claire Ritchie Campaign ‐ RSPB OBJ5152 Campaign ‐ RSPB Withdrawn OBJ5153 Mr Andy Moss Campaign ‐ RSPB Withdrawn OBJ5154 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5155 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5156 James D Suart Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5157 Mr Steven Ward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5158 Miss Lena Kusztelska Campaign ‐ RSPB OBJ5159 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5160 Mr Don Manhire Campaign ‐ RSPB OBJ5161 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5162 Mrs Mary Earp Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5163 Miss Penny Insole Campaign ‐ RSPB OBJ5164 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5165 Mr Kim Hughes Campaign ‐ RSPB OBJ5166 Campaign ‐ RSPB Withdrawn OBJ5167 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5168 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5169 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5170 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 180 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5171 Campaign ‐ RSPB Withdrawn OBJ5172 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5173 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5174 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5175 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5176 M J Richards Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5177 Mrs Julie Hughes Campaign ‐ RSPB OBJ5178 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5179 Mrs Rowena Quantrill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5180 Miss Lyn Ibbitson‐Elks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5181 Mr Alastair Wilson Campaign ‐ RSPB OBJ5182 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5183 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5184 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5185 Mr Jonathan Clark Campaign ‐ RSPB OBJ5186 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5187 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5188 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5189 Mr Hugh Rattray Campaign ‐ RSPB OBJ5190 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5191 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5192 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5193 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5194 Miss Sioned Jones Campaign ‐ RSPB OBJ5195 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5196 Miss Claire Jones Campaign ‐ RSPB OBJ5197 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5198 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5199 Mr Howard Jones Campaign ‐ RSPB OBJ5200 Jean Florence Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5201 Miss Betty Day Campaign ‐ RSPB OBJ5202 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5203 Mrs Leonie Shepherd Campaign ‐ RSPB Withdrawn

OBJ5204 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5205 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5206 Mrs Jennifer Rowlands Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5207 Mr Peter Hickman Campaign ‐ RSPB OBJ5208 P Loukes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5209 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5210 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5211 Campaign ‐ RSPB Withdrawn OBJ5212 Barbara Kelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5213 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5214 Miss Ali Evans Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 181 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5216 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5217 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5218 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5219 Mr Michael Langtree Campaign ‐ RSPB OBJ5220 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5221 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5222 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5223 Leslie Brooks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5224 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5225 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5226 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5227 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5228 Mr Ian Hartrey Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5229 Mr Graham Sutton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5230 Mr Stuart Bartlett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5231 Mrs Betty Maton Campaign ‐ RSPB OBJ5232 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5233 Miss Sheila Ryan Campaign ‐ RSPB OBJ5234 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5235 Jo Dando Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5236 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5237 Miss Debbie Lawson Campaign ‐ RSPB OBJ5238 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5239 Alex Wood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5240 Cedwyn Davies Campaign ‐ RSPB OBJ5241 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5242 Mr Kevin Cox Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5243 Janet Noall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5244 Mr Michael Jones Campaign ‐ RSPB

OBJ5245 Mrs Dorothy Joyce Cox Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5246 Mrs Margaret Ruston Campaign ‐ RSPB OBJ5247 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5248 Mr David Watkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5249 Miss Patricia Loukes Campaign ‐ RSPB OBJ5250 Campaign ‐ RSPB Withdrawn

OBJ5251 Mrs Sarah Francis Campaign ‐ RSPB Withdrawn

OBJ5252 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5253 Mrs Carol Peacock Campaign ‐ RSPB OBJ5254 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5255 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5256 Pamela Cook Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5257 Mrs Pauline Colsell Campaign ‐ RSPB OBJ5258 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 182 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5259 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5260 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5261 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5262 Mr Mark Piper Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5263 Mr Joseph Marshall Campaign ‐ RSPB

OBJ5264 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5265 Louise Wilkinson Campaign ‐ RSPB OBJ5266 Campaign ‐ RSPB Withdrawn OBJ5267 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5268 Miss Evelyn Marshall Campaign ‐ RSPB OBJ5269 Phil Rock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5270 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5271 Miss Fiona Deighton Campaign ‐ RSPB OBJ5272 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5273 Mr Tim Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5274 Campaign ‐ RSPB & Woodland Trust Withdrawn OBJ5275 Mr Alex Pilling Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5276 Mrs Jenny Wright Campaign ‐ RSPB OBJ5277 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5278 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5279 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5280 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5281 Ms Marion Bader Campaign ‐ RSPB OBJ5282 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5283 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5284 Mrs Ann Gray Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5285 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5286 Mr James Kelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5287 Dr Timothy Maberly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5288 Miss Jane Birch Campaign ‐ RSPB OBJ5289 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5290 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Martin Hastings‐ OBJ5291 Campaign ‐ RSPB Herbert WG/REB/OBJ0030 ‐ RSPB OBJ5292 Ms Susan Allen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5293 Ms Kay Hall Campaign ‐ RSPB OBJ5294 Mrs Pat Limb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5295 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5296 Helen S Hayward Campaign ‐ RSPB OBJ5297 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5298 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5299 Miss Pauline Evans Campaign ‐ RSPB Withdrawn

OBJ5300 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 183 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5301 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5302 Mr Nigel James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5303 Mr Neil Robinson Campaign ‐ RSPB OBJ5304 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5305 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5306 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5307 Miss Alison Goodhew Campaign ‐ RSPB OBJ5308 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5309 Mrs Gillian Hudson Campaign ‐ RSPB OBJ5310 C E Cotter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5311 Ms Verna Akers Campaign ‐ RSPB

OBJ5312 Miss Alice Groom Campaign ‐ RSPB Withdrawn

OBJ5313 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5314 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5315 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5316 Ms Lynn Leverett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5317 Miss Elizabeth Else Campaign ‐ RSPB

Mr Iain Alasdair OBJ5318 Campaign ‐ RSPB Withdrawn Gordon

OBJ5319 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5320 mary johnson Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ5321 Mrs Carolyn Robertson Campaign ‐ RSPB

OBJ5322 Mr Ian Bond Campaign ‐ RSPB Withdrawn

OBJ5323 A Kennett Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5324 Ms Daphne Llewellyn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5325 Mrs Eileen Wiggins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5326 Mrs Janet Budd Campaign ‐ RSPB OBJ5327 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5328 Mr Roger Puxley Campaign ‐ RSPB OBJ5329 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5330 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5331 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5332 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ5333 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5334 Mr Michael Davis Campaign ‐ RSPB OBJ5335 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5336 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5337 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5338 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5340 Mr Daniel Hulmes Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 184 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5341 Campaign ‐ RSPB & Woodland Trust Withdrawn

OBJ5342 Sue Netherton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5343 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5344 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5345 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5346 Dr Jennifer Woodward Campaign ‐ RSPB OBJ5347 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5348 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5349 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5350 Mr Lee Lockett Campaign ‐ RSPB OBJ5351 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5352 Mr Craig Reed Campaign ‐ RSPB OBJ5353 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5354 Mr Alan Cobb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5355 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5356 Campaign ‐ RSPB Withdrawn OBJ5357 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5358 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5359 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5360 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5361 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5362 Steve Kelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5363 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5364 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5365 Mr Neil Benham Campaign ‐ RSPB Withdrawn

OBJ5366 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5367 Mr Simon Allan‐Smith Campaign ‐ RSPB OBJ5368 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5369 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5370 Mr Norman Hooks Campaign ‐ RSPB OBJ5371 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5372 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5373 Mrs Hilary May Campaign ‐ RSPB OBJ5374 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5375 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5376 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5377 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5378 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5379 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5380 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5381 Mr Martin Green Campaign ‐ RSPB OBJ5382 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5383 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5384 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5385 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5386 Miss Mary Ledlie Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 185 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5387 Dr Eirian Dafydd Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5388 Cliff Carnell Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ5389 Mr John Ingram Campaign ‐ RSPB OBJ5390 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5391 Mr Stefan Majer Campaign ‐ RSPB OBJ5392 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5393 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5394 Mr Jonni Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5395 Ms Roberta Goodall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5396 Miss Christina Paddock Campaign ‐ RSPB OBJ5397 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5398 Mrs Margaret Storr Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5399 Mr Rob Macklin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5400 Mr David Parker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5401 Miss Jill Abbott Campaign ‐ RSPB

OBJ5402 Campaign ‐ RSPB Withdrawn OBJ5403 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5404 Christine Harding Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ5405 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5406 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5407 Dr Julie Light Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5408 Miss Yvonne Boles Campaign ‐ RSPB OBJ5409 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5410 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5411 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5412 Mr A Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5413 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5414 Mr Cellan Michael Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5415 Mr Geoffrey Cranwell Campaign ‐ RSPB

OBJ5416 Campaign ‐ RSPB Withdrawn

OBJ5417 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5418 Mr John Turton Campaign ‐ RSPB OBJ5419 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5420 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5421 Miss Sandra Palme Campaign ‐ RSPB OBJ5422 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5423 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5424 Wendy Cottis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5425 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5426 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5427 Mr Derek Flockton Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 186 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5428 Mr Andrew Sutherland Campaign ‐ RSPB

OBJ5429 Mr Andrew Bladon Campaign ‐ RSPB Withdrawn

OBJ5430 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5431 Mr Jay Beirne Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5432 Mr Stephen Bishop Campaign ‐ RSPB OBJ5433 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5434 Miss Beryl Bashford Campaign ‐ RSPB OBJ5435 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5436 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5437 Campaign ‐ RSPB Withdrawn OBJ5438 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5439 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5440 Mr Brad Rosentritt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5441 Mr Chris Jones Campaign ‐ RSPB OBJ5442 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5443 Miss Nicole Loh Campaign ‐ RSPB OBJ5444 Sally Beynon Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5445 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5446 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5447 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5448 Mr Peter Cartwright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5449 Miss Claire Pritchard Campaign ‐ RSPB OBJ5450 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5451 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5452 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5453 Miss Chris Larkin Campaign ‐ RSPB OBJ5454 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5455 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5456 Miss Carys Edwards Campaign ‐ RSPB

OBJ5457 Mr Richard Jones Campaign ‐ RSPB Withdrawn

OBJ5458 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5459 Dr Jeremy Smallwood Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5460 Mr Jonathan Ball Campaign ‐ RSPB OBJ5461 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5462 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5463 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5464 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5465 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5466 Mr Daniel Barrett Campaign ‐ RSPB OBJ5467 Mrs Jane Hill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5468 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5469 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5470 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 187 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5471 Mr Chris Hogg Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5472 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5473 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5474 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5475 C A Mitchell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5476 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5477 Mr Mark Hucket Campaign ‐ RSPB OBJ5478 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5479 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5480 Mr Andrew Lambeth Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5481 Ms Madelaine Morris Campaign ‐ RSPB OBJ5482 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5483 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5484 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5485 Campaign ‐ RSPB Withdrawn Mrs Margaret WG/REB/OBJ0030 ‐ RSPB OBJ5486 Campaign ‐ RSPB Hamerton OBJ5487 Mrs Valerie Pericleous Campaign ‐ RSPB Withdrawn

OBJ5488 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5489 Miss S Malden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5490 Mr Antony Pooles Campaign ‐ RSPB OBJ5491 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5492 Mrs Geraldine Rowland Campaign ‐ RSPB OBJ5493 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5494 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5495 Mr John Topham Campaign ‐ RSPB OBJ5496 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Rosemary WG/REB/OBJ0030 ‐ RSPB OBJ5497 Campaign ‐ RSPB Sprenger WG/REB/OBJ0030 ‐ RSPB OBJ5498 Miss Kim Fenton Campaign ‐ RSPB OBJ5499 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5500 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5501 Celia Busby Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5502 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5503 Mrs Helen Harman Campaign ‐ RSPB OBJ5504 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5505 Natalie Wrangham Campaign ‐ RSPB OBJ5506 Helen Nienow Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5507 Dr Gillian Davies Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5508 Miss Elizabeth Green Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5509 Mr Stephen Coker Campaign ‐ RSPB OBJ5510 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5511 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 188 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

Miss Alexandra OBJ5512 Campaign ‐ RSPB Withdrawn Osborne

OBJ5513 Mr Peter Riley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5514 Mrs Brenda Hadley Campaign ‐ RSPB OBJ5515 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5516 Mrs Jill Pike Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5517 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5518 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5519 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5520 Mr Adrian Halliday Campaign ‐ RSPB OBJ5521 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5522 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5523 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5524 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5525 Mrs Karen Sweet Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5526 Miss Bethan Kean Campaign ‐ RSPB OBJ5527 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5528 Jane Clarke Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5529 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5530 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5531 Miss Rosy Pearce Campaign ‐ RSPB OBJ5532 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5533 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5534 Mr David Lowe Campaign ‐ RSPB OBJ5535 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5536 Mr Robert Badcock Campaign ‐ RSPB OBJ5537 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5538 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5539 Mr Richard Walden Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5540 Mr Ernie Scales Campaign ‐ RSPB OBJ5541 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5542 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5543 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5544 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5545 Mr Peter Thomas Campaign ‐ RSPB OBJ5546 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5547 Mrs Susan Helm Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5549 Mrs Christine Astbury Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5550 Miss Rebekah Davies Campaign ‐ RSPB OBJ5552 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5553 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5554 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5555 Mr Leonard Seelig Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 189 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5556 D Mottershead Wright Campaign ‐ RSPB

OBJ5557 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5558 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5559 Miss Charlotte Painter Campaign ‐ RSPB OBJ5560 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5561 Mr Keith Ballard Campaign ‐ RSPB OBJ5562 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5563 Ms Claire O'Kell Campaign ‐ RSPB OBJ5564 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5565 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5566 M J Bartrop Campaign ‐ RSPB Withdrawn OBJ5567 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5568 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5569 Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ5570 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5571 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5572 Mrs Susanne Renshaw Campaign ‐ RSPB

OBJ5573 Mrs Jan Green Campaign ‐ RSPB Withdrawn

OBJ5574 R V Llewellyn Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5575 Ms Lorraine Pooley Campaign ‐ RSPB OBJ5576 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5577 Andrew M Thomas Campaign ‐ RSPB OBJ5578 P W Adams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5579 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5580 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5581 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Sam Devine‐ WG/REB/OBJ0030 ‐ RSPB OBJ5582 Campaign ‐ RSPB Turner OBJ5583 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5584 Mr Mark Farmaner Campaign ‐ RSPB OBJ5585 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5586 Miss Sadie Ezard Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5587 Mr Robert Laughton Campaign ‐ RSPB OBJ5588 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5589 Mr Luke Klein Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5590 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Miss Rosanna WG/REB/OBJ0030 ‐ RSPB OBJ5591 Campaign ‐ RSPB Rapacchietta WG/REB/OBJ0030 ‐ RSPB OBJ5592 Miss Kate Williamson Campaign ‐ RSPB OBJ5593 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5594 Mr John Earp Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5595 Campaign ‐ RSPB Withdrawn

OBJ5596 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 190 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5597 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5598 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5599 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5600 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5601 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5602 Mrs Emma Cornish Campaign ‐ RSPB OBJ5603 Sian Watkin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5604 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5605 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5606 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5607 Anna N Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5608 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5609 Dr Nicola Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5610 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5611 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5612 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5613 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5614 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5615 Mrs Sarah Groenendijk Campaign ‐ RSPB OBJ5616 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5617 Ms Ruth Coulthard Campaign ‐ RSPB OBJ5618 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5619 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5620 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5621 Mrs Susan Palmer Campaign ‐ RSPB OBJ5622 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5623 Pam Mercer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5624 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5625 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5626 Steve Edwards Campaign ‐ RSPB OBJ5627 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5628 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5629 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5630 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5631 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5632 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5633 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5634 Ms F Owen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5635 Miss Gabrielle Norton Campaign ‐ RSPB OBJ5636 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5637 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5638 Mr Ralph Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5639 Bernard Picton Campaign ‐ RSPB OBJ5640 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5641 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5642 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5643 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 191 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5644 Mr Mark Thornber Campaign ‐ RSPB

OBJ5645 D Woodroffe Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5646 Mr Robert Hopson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5647 David Parsons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5648 Mrs Sarah Pagdin Campaign ‐ RSPB

OBJ5649 Dr Sean Perkins Campaign ‐ Wildlife Trusts Wales Withdrawn

OBJ5650 Jane Porter Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5651 Margaret Wright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5652 Charlotte Guillain Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5653 Mrs Jane Knight Campaign ‐ RSPB OBJ5654 R M Price Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5655 Steve Walker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5656 Mrs Ann MacSorley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5657 Mr Cameron Quigley Campaign ‐ RSPB

OBJ5658 Campaign ‐ RSPB Withdrawn

OBJ5659 Mr John Light Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5660 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5662 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5663 Mr Thomas Roberts Campaign ‐ RSPB OBJ5664 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5665 Campaign ‐ RSPB Withdrawn OBJ5666 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5667 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5668 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5669 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5670 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5671 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5672 Mrs Julie Balaam Campaign ‐ RSPB OBJ5673 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5674 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5675 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5676 Mrs Rachel Mattey Campaign ‐ RSPB OBJ5677 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5678 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5679 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5680 Kate Samuels Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5681 Mr R A Heal Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5682 Campaign ‐ RSPB Withdrawn OBJ5683 Natalie Mills Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5684 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5685 Miss Lucy Kelly Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5686 Carol Sootheran Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 192 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5687 Simon Cull Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Bethan Wynne‐ WG/REB/OBJ0030 ‐ RSPB OBJ5688 Campaign ‐ RSPB Cattanach WG/REB/OBJ0030 ‐ RSPB OBJ5689 Catherine Evans Campaign ‐ RSPB OBJ5690 Matt Postles Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5691 Amanda Jones Campaign ‐ RSPB

OBJ5692 Katie Trent Campaign ‐ RSPB Withdrawn OBJ5693 Rob Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5694 Emma Robertshaw Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5695 Sarah Coulstock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5696 Mr Barry O'Dowd Campaign ‐ RSPB OBJ5697 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5698 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5699 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5700 C Owen Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5701 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5702 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5703 Z Kristel Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5704 Mrs Lindsey Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5705 Susanna McIntyre Campaign ‐ RSPB OBJ5706 Cyrene Powell Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5707 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5708 Miss Holly Booker Campaign ‐ RSPB OBJ5709 Louisa Mills Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5710 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5711 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5712 Mrs Pam Peacock Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5713 Mr David Hughes Campaign ‐ RSPB OBJ5714 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5715 Patrick Driscall Campaign ‐ RSPB OBJ5716 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5717 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5718 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5719 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5720 Mr V A Gregory Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5721 Oliver Kennedy Campaign ‐ RSPB OBJ5722 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5723 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5724 Peter Wright Campaign ‐ RSPB Withdrawn OBJ5725 Jo Webb Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5726 Rachael Hopley Campaign ‐ RSPB OBJ5727 Clare Catto Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5728 Al Reeve Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 193 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5729 Gwyneth Jones Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5730 Jeanette Jones Campaign ‐ RSPB OBJ5731 Linda Newton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5732 Samantha Elson Campaign ‐ RSPB OBJ5733 Sandra Evans Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5734 Rose Revera Campaign ‐ RSPB Withdrawn OBJ5735 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5736 Mr Anthony Kavanagh Campaign ‐ RSPB OBJ5737 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5738 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5739 Giles Alder Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5740 Mr Paul Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5741 Dr Peter Tilbrook Campaign ‐ RSPB OBJ5742 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5743 Darren Kempson Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5744 Mary Ann Brocklesby Campaign ‐ RSPB OBJ5745 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5746 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5747 Jane Leicester Campaign ‐ RSPB

OBJ5748 Zelah Pengilley Campaign ‐ Wildlife Trusts Wales Withdrawn

OBJ5749 Campaign ‐ RSPB Withdrawn

OBJ5750 Cheryl Cummings Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5751 Mr Philip Palmer Campaign ‐ RSPB

OBJ5752 Ella Nia Morgan Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5753 Mrs Judith Mair Campaign ‐ RSPB OBJ5754 Alan Orange Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Dr Samantha WG/REB/OBJ0030 ‐ RSPB OBJ5755 Campaign ‐ RSPB Horsburgh OBJ5756 Cleo Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5757 Mrs Jean Brill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5758 Andrew McDermid Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5759 Penny Powdrill Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Gillian Stevens and OBJ5760 Campaign ‐ RSPB Dylan Fowler WG/REB/OBJ0030 ‐ RSPB OBJ5761 Margaret Barford Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5762 Phillip Graham Campaign ‐ RSPB OBJ5763 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5764 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5765 Miss Emily Cluer Campaign ‐ RSPB OBJ5766 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 194 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5767 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5768 Jannine Parkhouse Campaign ‐ RSPB Withdrawn

OBJ5769 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5770 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5771 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5772 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5773 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5774 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5775 Mr John Bright Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5776 Anthony Hall Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5777 Sarah Davis Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5778 Malcolm Wright Campaign ‐ RSPB OBJ5779 Gillian Brooks Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5780 Faye Mear Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5781 Janet Broadway Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5782 Richard Bakere Campaign ‐ RSPB OBJ5783 Linda Newton Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5784 Campaign ‐ RSPB Withdrawn OBJ5785 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5786 Dana Barringham Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5787 Matthew Pitman Campaign ‐ RSPB OBJ5788 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5789 Gwydion Kempson Campaign ‐ RSPB Withdrawn

OBJ5790 R Alley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5791 Caroline Wynn Campaign ‐ RSPB Withdrawn

OBJ5792 Andrew Baker Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5793 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5794 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5795 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5796 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5797 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5798 Lesley Cannon Campaign ‐ RSPB OBJ5799 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5800 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5801 Laura Arillotta Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5802 Mrs Helen Mears Campaign ‐ RSPB

OBJ5803 Campaign ‐ RSPB Withdrawn OBJ5804 Mr Paul Knight Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5805 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5806 Miss Kate Sullivan Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5807 Mr Steve Jeggo Campaign ‐ RSPB OBJ5808 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5809 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5810 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5811 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 195 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5812 Campaign ‐ RSPB Withdrawn

OBJ5813 Andy Hodge Campaign ‐ RSPB Withdrawn OBJ5814 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5815 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5816 Mr Richard Tyler Campaign ‐ RSPB OBJ5817 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5818 Mr Stefan Majer Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5819 Mrs Jinny Hayward Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5820 Mrs Julia Thynne Campaign ‐ RSPB OBJ5821 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5822 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5823 Ms Robyn Caldecott Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5825 Mr David Jones Campaign ‐ RSPB OBJ5826 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5827 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5829 David S Roberts Campaign ‐ RSPB Withdrawn

OBJ5830 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5831 Campaign ‐ RSPB Withdrawn OBJ5832 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5833 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5834 Miss Jan Fowler Campaign ‐ RSPB OBJ5835 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5836 Miss Alison Mawdsley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5837 Mr James Adams Campaign ‐ RSPB OBJ5838 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5839 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5840 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5841 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5842 Gavin Vella Campaign ‐ Gwent Wildlife Withdrawn OBJ5843 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5844 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5845 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5846 Rhiannon Williams Campaign ‐ RSPB OBJ5847 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5848 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5849 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5850 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5851 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5852 Mr Steven Anstey Campaign ‐ RSPB OBJ5853 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5854 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5855 Mr Peter Holt Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5856 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5857 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 196 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5858 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5859 Sparkie Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5860 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5861 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5862 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5863 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5864 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5865 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5866 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5867 Mr Ian Mossop Campaign ‐ RSPB OBJ5868 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5869 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5870 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5871 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5872 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5873 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5874 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5875 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5876 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5877 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5878 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5879 Dr Sylvia Davidson Campaign ‐ RSPB Withdrawn

OBJ5880 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5881 Les Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5882 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5883 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5884 Mr Richard Doore Campaign ‐ RSPB

OBJ5885 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5886 Mr Gareth Ellis Campaign ‐ RSPB OBJ5887 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5888 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5889 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mrs Maureen WG/REB/OBJ0030 ‐ RSPB OBJ5890 Campaign ‐ RSPB Buckingham OBJ5891 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5892 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5893 B Hulmes Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5894 Rebecca Goss Campaign ‐ RSPB

OBJ5895 Mrs Sue Morris Campaign ‐ RSPB Withdrawn

OBJ5896 Campaign ‐ RSPB Withdrawn

OBJ5897 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5898 Mr Malcolm Clarke Campaign ‐ RSPB OBJ5899 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5900 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Mr Dominic WG/REB/OBJ0030 ‐ RSPB OBJ5901 Campaign ‐ RSPB Templeman WG/REB/OBJ0030 ‐ RSPB OBJ5902 Mrs Nahara Hanson Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 197 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ5903 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5904 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5905 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5906 Mr Roy Betts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5907 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5908 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5909 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5910 Mrs Rosalind Collier Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5911 Mrs Siwan Thomas Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5912 Laurence Pearce Campaign ‐ RSPB OBJ5913 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5914 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5915 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5916 Mrs Gail Pickett Campaign ‐ RSPB OBJ5917 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5918 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5919 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5920 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5921 Helen Williamson Campaign ‐ RSPB Mrs Margaret WG/REB/OBJ0030 ‐ RSPB OBJ5922 Campaign ‐ RSPB Rosentritt OBJ5923 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5924 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5925 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5926 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5927 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5928 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5929 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5930 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5931 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5932 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5933 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5934 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5935 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5936 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5937 Mrs Sonja Browne Campaign ‐ RSPB OBJ5938 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5939 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5940 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5941 Mrs Heather Walton Campaign ‐ RSPB

OBJ5942 Campaign ‐ RSPB Withdrawn OBJ5943 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5944 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5945 Campaign ‐ RSPB Withdrawn OBJ5946 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5947 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5948 Mrs Gill Hirons Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 198 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5949 Ms Deb Hewlett Campaign ‐ RSPB

OBJ5950 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5951 L James Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5952 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5953 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5954 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5955 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5956 Campaign ‐ RSPB & Woodland Trust Withdrawn

OBJ5957 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5958 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5959 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5960 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5961 John Wilde Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5962 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5963 Elaine David Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5964 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5965 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ5966 Ms Briony Baxter Campaign ‐ RSPB & Woodland Trust Withdrawn

OBJ5967 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5968 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5969 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5970 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5971 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5972 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5973 Dr Alison Searl Campaign ‐ RSPB OBJ5974 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5975 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5976 Campaign ‐ RSPB Withdrawn OBJ5977 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5978 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5979 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5980 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5981 Marian Ashwell Campaign ‐ RSPB OBJ5982 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5983 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5984 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5985 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5986 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5987 Irene Bound Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5988 Mr Jeremy Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5989 Mr James Bear Campaign ‐ RSPB OBJ5990 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5991 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5992 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5993 Mr Leslie Dubery Campaign ‐ RSPB OBJ5994 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5995 Campaign ‐ RSPB Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 199 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ5996 Mrs Lindsey Jenkins Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ5997 Campaign ‐ RSPB

OBJ5998 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ5999 Ms Yvonne Griffiths Campaign ‐ RSPB

OBJ6000 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6001 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6002 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6003 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ6004 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ6005 Mr Gordon McQueen Campaign ‐ RSPB OBJ6006 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6007 Rebecca Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6008 Mr Peter North Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6009 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6010 Mrs C Schaffer Campaign ‐ RSPB Withdrawn OBJ6011 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6012 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6013 Mr Richard Chapman Campaign ‐ RSPB OBJ6014 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6015 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6016 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6017 Peter Wright Campaign ‐ RSPB & Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6018 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ6019 Mrs Marie Eyres Campaign ‐ RSPB Withdrawn

OBJ6020 Nigel Polding Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

Dr Patricia Anne OBJ6021 Campaign ‐ RSPB Withdrawn Appleyard

OBJ6022 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6023 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6024 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6025 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6026 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6027 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ6028 Dean Pepperell Campaign ‐ RSPB Withdrawn

OBJ6029 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6030 Ms Vanessa BrysonCampaign ‐ RSPB OBJ6031 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6032 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6033 Mrs Sylvia Smith Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6034 Mr Michael Walters Campaign ‐ RSPB OBJ6035 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6036 Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 200 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0030 ‐ RSPB OBJ6037 Mr Francis Lawson Campaign ‐ RSPB

OBJ6038 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6039 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6040 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6041 Susan R Brittain Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6042 Miss Layla Haidrani Campaign ‐ RSPB OBJ6043 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6044 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ6045 Mrs Faye Boswell Campaign ‐ RSPB OBJ6046 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6047 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6048 Campaign ‐ RSPB Withdrawn OBJ6050 Campaign ‐ RSPB Withdrawn OBJ6051 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6052 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6053 Mrs Janice Minich Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6054 Ms Sally Kemp Campaign ‐ RSPB OBJ6055 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6056 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6057 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6058 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6059 Ms Sandra Veasey Campaign ‐ RSPB Withdrawn OBJ6060 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6061 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6062 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6063 Lisa Williams Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6064 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6065 Campaign ‐ RSPB Withdrawn OBJ6066 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6067 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6068 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

OBJ6069 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ6070 Miss Jessica Wheatley Campaign ‐ RSPB OBJ6071 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6072 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6073 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6074 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6075 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6076 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6077 Jackie Clark Campaign ‐ RSPB and Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust WG/REB/OBJ0030 ‐ RSPB OBJ6078 Ms Ruth Roberts Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6079 Mr Kerry Douce Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6080 Mr Gareth Richards Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6081 Mr David Hobbs Campaign ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 201 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ6082 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6083 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6084 Miss Sarashka King Campaign ‐ RSPB

OBJ6085 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6086 Mr Andy Field Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6088 Mr Graham Barker Campaign ‐ RSPB OBJ6089 M Daniel Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6090 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6091 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6092 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6093 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6094 Campaign ‐ RSPB Withdrawn OBJ6095 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6096 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6097 Campaign ‐ RSPB Withdrawn OBJ6098 M Fairbrother Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Sarah Isherwood‐ OBJ6100 Campaign ‐ RSPB Harris

OBJ6101 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6102 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6103 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6104 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6105 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6106 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6107 Mr M Puxley Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6108 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6109 Campaign ‐ RSPB Withdrawn OBJ6110 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6111 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6112 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6113 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6114 Mr Edric Ovens Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6115 Rosemary Jeffery Campaign ‐ RSPB OBJ6116 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6117 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6118 Campaign ‐ RSPB Withdrawn WG/REB/OBJ0030 ‐ RSPB OBJ6119 Miss S Gleeson Campaign ‐ RSPB OBJ6120 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6121 Mr Nick Clark Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6122 Campaign ‐ RSPB

OBJ6123 Gavin Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6124 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6125 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB OBJ6126 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB Ms Christine Yana WG/REB/OBJ0030 ‐ RSPB OBJ6127 Campaign ‐ RSPB Goode OBJ6128 Campaign ‐ RSPB WG/REB/OBJ0030 ‐ RSPB

REVISED M4CAN objections schedule of evidence.xlsm 202 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ6129 Pat Jones‐Jenkins Campaign ‐ RSPB Withdrawn

OBJ6130 Mr Allan Cowhig Campaign ‐ RSPB Withdrawn

OBJ6131 Pam Webb Campaign ‐ RSPB Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6132 Susan Simmonds Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6133 Ann James Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6134 alan pearson Campaign ‐ Woodland Trust

OBJ6135 alison bevin Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6136 Graham Cox Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6137 adrian corless Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6138 Andris Erglis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6139 Hilary Kehoe Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6140 Allan Hopkins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6141 Anne Hordley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6142 Aideen Stacey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6143 Anne Collie Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6144 Angharad Westmore Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6145 Anne Kurmos Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6146 Alan Hagan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6147 Alan Williamson Campaign ‐ Woodland Trust

OBJ6148 Alan Prosper Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6149 Alex Harris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6150 Alexandra Paterson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6151 Rebecca Kellaway Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6152 Alice Thomas Campaign ‐ Woodland Trust

OBJ6153 Alice Hayes Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6154 Alisha Brown Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6155 Alison Broughton Campaign ‐ Woodland Trust

OBJ6156 Alison Morse Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6157 Alison Holland Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6158 Christina Allen Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6159 Alun Lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6160 Alyson Cairns Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 203 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6161 AMAL OUAHANI Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6162 Amanda John Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6163 Amanda Cozens Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6164 Andrew Hamblin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6165 andrew cotterill Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6166 Andrew Middleton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6167 Andrew Darke Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6168 Andy Smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6169 Andy Tyler Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6170 Andy Lambie Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6171 Andy Green Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6172 ANGELA ALI Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6173 Angela Mawle Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6174 Angela Griffiths Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6175 Anja Stracey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6176 Ann Savage‐Lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6177 Anna Trotman Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6178 Anne Davies Campaign ‐ Woodland Trust

OBJ6179 Christine Harding Campaign ‐ Woodland Trust Withdrawn

OBJ6180 Ann Green Campaign ‐ Woodland Trust Withdrawn

OBJ6181 Ann Leeuwerke Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6182 Ann Roberts Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6183 Anthony McCaffrey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6184 Antoinette Hookway Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6185 Andrew Michie Campaign ‐ Woodland Trust

OBJ6186 Annie Prosser Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6187 Avril Lord Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6188 Richard Greenwood Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6189 Barbara Court Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6190 Linda Batsleer Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6191 Rebecca Gibbins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6192 belinda glascoed Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 204 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6193 Ann Pritchard Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6194 Elizabeth Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6195 Bethan Morris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6196 Bethan Mosley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6197 Betsan Rosser Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6198 Beverly Horrell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6199 Beverley Roche Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6200 joseph berry Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6201 Brett Harrison Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6202 Patricia Birch Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6203 Pauline Tomkins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6204 Barbara Jamieson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6205 Kate Boddington Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6206 Martin Boyett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6207 Bernadette Purnell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6208 Brenda Nicholas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6209 Mandi Dunlop Ferraro Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6210 Bronwen Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6211 Sheila Manning Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6212 Bryan Dillon Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6213 Sarah Caunt Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6214 Charles Kingsley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6215 Andrew Caine Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6216 David Callaghan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6217 camilla newton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6218 carol smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6219 Carole Turner Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6220 Caroline Hill Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6221 Caroline Smyth Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6222 Caroline Mason Campaign ‐ Woodland Trust

OBJ6223 Caroline Prince Campaign ‐ Woodland Trust Withdrawn

OBJ6224 Steve penny Campaign ‐ Woodland Trust Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 205 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6225 Carys Rogers Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6226 Linda Castle Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6227 C E O Shaw Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6228 Cate Hargreaves Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6229 Catherine Abbott Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Catherine Hipperson OBJ6230 Campaign ‐ Woodland Trust Barker WG/REB/OBJ0271 ‐ Woodland Trust OBJ6231 Catherine Williams Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6233 Catrin Hanks‐Doyle Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6234 Caroline Juler Campaign ‐ Woodland Trust

OBJ6235 Mark Eldridge Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6236 Ceinwen Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6237 Catherine Lea Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6238 Barbara Hetherington Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6239 Richard Eade Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6240 Chantal Cumming Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6241 carla vickers Campaign ‐ Woodland Trust

OBJ6242 Charlene Davies Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6243 c alexander Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6244 Charlotte Vigar Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6245 Charlotte Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6246 Charlotte Copik Campaign ‐ Woodland Trust

OBJ6247 Cheryl Cummings Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6248 Cheryl Brown Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6249 Christopher Fray Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6250 Chris Ramus Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6251 Chris Baillie Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6252 chris bird‐jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6253 Chris Edwards Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6254 Christine Farthing Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6255 Christine Wiltshire Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6256 Christopher Beynon Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 206 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ6257 Colin Lougher Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6258 Carol Oakes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6259 Claire Kingman Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6260 Claire Taylor Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6261 Clare Burns Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6262 clare conway Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6263 Clare Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6264 Clare Russell Campaign ‐ Woodland Trust

OBJ6265 Cliff Carnell Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6266 Clive Hodged Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6267 clive atkinson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6268 Clyde Watkins Campaign ‐ Woodland Trust

OBJ6269 e mainwaring Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6270 Meirion Rees Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6271 lynette dubery Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6272 Mr & Mrs C.B. Sim Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6273 Colin Sim Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6274 connor Flewitt Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6275 clare Saunders Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6276 Peter Reynolds Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6277 Cori Ryan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6278 annie craze Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6279 clare m Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6280 Deb Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6281 David Morgan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6282 Denise Williams Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6283 Daniel Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6284 Daniel Boyce Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6285 Daphne Smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6286 Emma Darling Campaign ‐ Woodland Trust

OBJ6287 Darryl Spittle Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6288 Dave Carron Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 207 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6289 David Livingstone Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6290 D P O'Shea Campaign ‐ Woodland Trust

OBJ6291 David Blackman Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6292 Dave Bannister Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6293 David Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6294 david Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6295 Dave Stacey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6296 David and Eva Moy Campaign ‐ Woodland Trust

OBJ6297 David Shapland Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6298 Enfys Rennie Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6299 Diane Davies Campaign ‐ Woodland Trust

OBJ6300 Kevin Blackmore Campaign ‐ Woodland Trust Withdrawn

OBJ6301 Dean Pepperell Campaign ‐ Woodland Trust Withdrawn

OBJ6302 Debbie Bardo Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6303 Debbie Tamplin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6304 DEL PAGE Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6305 Sarah Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6306 Denise Laurent Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6307 Denise Baker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6308 Derek Burston Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6309 Rhys Michael Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6310 Delyth Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6311 David Hytch Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6312 Hywel Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6313 Diana Grimwood‐Jones Campaign ‐ Woodland Trust

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6314 Diana Gordon Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6315 Jeanette Dobson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6316 Jude Powell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6317 Dominic North Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6318 Douglas Hatton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6319 David Ryder Owen Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 208 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6320 Dave Noble Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6321 Leonora Matthews Campaign ‐ Woodland Trust

OBJ6322 Euron Davies Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6323 Emma Karidian Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6324 Edward Baker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6325 Esther Buckley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Edmund McMahon OBJ6326 Campaign ‐ Woodland Trust Turner WG/REB/OBJ0271 ‐ Woodland Trust OBJ6327 Karl Blom Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6328 Eileen Pritchard Campaign ‐ Woodland Trust

OBJ6330 Elaine Blackman Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6331 elaine masci Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6332 eliot baron Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6333 Elizabeth Owens Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6334 Elizabeth Milner Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6335 Elizabeth Talboys Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6336 Elle Trevitt Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6337 Eleanor Hughes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6338 Elsa Harflett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6339 Myles Bidder Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6340 Arthur Brooker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6341 elyssa noble hook Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6342 Emma Cram Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6343 Emma Creasey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6344 emma lloyd Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6345 Emma Hipkiss Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6346 Emma Ross Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6347 Emma Alabaster Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6348 Emma Spacey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6349 Enys Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6350 eric fletcher Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6351 Esther Phillips Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 209 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6352 Eve Merrick‐Williams Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6353 Faith Williams Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6354 Phil Panton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6355 Stephen Finch Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6356 Findlay Wilde Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6357 Fiona Bailey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6358 Francis Buxton Campaign ‐ Woodland Trust

OBJ6359 Frances Ballin Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6360 gareth beynon Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6361 Gareth Marston Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6362 Gary Cowell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6363 Gary Northeast Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6364 Gawain Barnard Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6365 Gaynor Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6366 Gaynor Ball Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6367 Gareth Bowen Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6368 Gareth Clubb Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6369 Gregory Page Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6370 Geraint Jones Campaign ‐ Woodland Trust

OBJ6371 Zoe Foster Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6372 Gwen Macnair Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6373 Gemma Dickson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6374 meg spiers Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6375 Amanda Skull Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6376 Rhisiart ap Gwilym Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6377 Geoffrey Lincoln Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6378 Carol Jackson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6379 George Lawrance Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6380 Georgia Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6381 Gerald Francis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Gerwyn Caradoc ap OBJ6382 Campaign ‐ Woodland Trust Glanmor Williams

REVISED M4CAN objections schedule of evidence.xlsm 210 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6383 Gethin Sugar Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6384 JAMES WILLIAMS Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6385 Aimee Lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6386 Gordon Allison Campaign ‐ Woodland Trust

OBJ6387 Godfrey Bradshaw Campaign ‐ Woodland Trust Withdrawn

OBJ6388 Julie Rolls Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6389 Gordon Watson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6390 Graham Hart Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6391 Justin George Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6392 Gregory Spittle Campaign ‐ Woodland Trust

OBJ6393 Carl Griffiths Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6394 Gillian Tennant‐Eyles Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Graham Thomas OBJ6395 Campaign ‐ Woodland Trust Thorne WG/REB/OBJ0271 ‐ Woodland Trust OBJ6396 Gary Loch Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6397 Gwydion ap Wynn Campaign ‐ Woodland Trust

OBJ6398 G Lewis Campaign ‐ Woodland Trust Withdrawn

OBJ6399 HELEN Varney Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6400 Haraldur Bjornsson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6401 Helen Hawkins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6402 Hannah Sharp Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6403 Kevin Hargreaves Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6404 Simon Harlock Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6405 Donna Harvey Campaign ‐ Woodland Trust

OBJ6406 Kate Hawkins Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6407 Hayley Farthing Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6408 Hayley Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6409 Heidi Traunecker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6410 Heini Evans Campaign ‐ Woodland Trust

OBJ6411 Helen Jackson Campaign ‐ Woodland Trust Withdrawn

OBJ6412 Helen Collis Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6413 Helen Richards Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 211 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6414 Roy Scourfield Campaign ‐ Woodland Trust

OBJ6415 Kevin Henry Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6416 Berni Cavanagh Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6417 Gwynfor Roberts Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6418 Holger Burkhardt Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6419 David Hands Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6420 Honor Maughan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6421 Howard Martin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6422 Hsiujung Lee Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6423 Hugh Mackay Campaign ‐ Woodland Trust

OBJ6424 Hugo Perks Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6425 HUGO PETTINGELL Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6426 Peter Hunt Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6427 michelle Penny Campaign ‐ Woodland Trust

OBJ6428 Hywel Wyn Morgan Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6429 Ian Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6430 Ian Rae Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6431 Ian Armer Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6432 Roger Lougher Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6433 Amy Jackson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6434 clare parry Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6435 Brian Burnett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6436 ian sellick Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6437 Ingrid Maugham Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6438 Julia Francis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6439 Julie Roberts Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6440 Ian Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6441 Ismene Cole Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6442 Isobel Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6443 Jenny Rogers Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6444 j watts Campaign ‐ Woodland Trust

OBJ6445 Jonathan Stone Campaign ‐ Woodland Trust Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 212 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ6446 Jackie Clark Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6447 James D'sa Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6448 James Roden Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6449 Jan Neary Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6450 Jane McIntyre Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6451 Jane Read Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6452 jane sinclair Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6453 Janert Hrbury Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6454 Janet Lilley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6455 Jan Harris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6456 Janice Waight Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6457 Jason Latham Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6458 John Spencer Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6459 Jennifer Protheroe Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6460 Julie Englefield Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6461 James Clark Campaign ‐ Woodland Trust

OBJ6462 jean elliott Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6463 Jeane Smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6464 Jessica King Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6465 Janet Diamond Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6466 Jeff Bartlett Campaign ‐ Woodland Trust

OBJ6467 Jenny Thomas Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6468 Rebecca Dewsbury Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6469 Jennifer Lock Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6470 Jennine Morgan Campaign ‐ Woodland Trust

OBJ6471 Jenny Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6472 Jennifer Tetlow Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6473 Jenny Stevens Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6474 jennifer penney Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6475 J inglis Campaign ‐ Woodland Trust

OBJ6476 Jess Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6477 Jayne Greenwood Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 213 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6478 John Hughes Campaign ‐ Woodland Trust

OBJ6479 james bevin Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6480 Julia BARTLETT Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6481 Josephine Burrells Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6482 Joanna Taylor Campaign ‐ Woodland Trust

OBJ6483 Joseph Fleming Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6484 John Deering Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6485 Jihn Dewsbury Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6486 John Higgon Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6487 John Keates Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6488 John Probert Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6489 Jackie Lewis Campaign ‐ Woodland Trust

OBJ6490 John Goodwin Campaign ‐ Woodland Trust Withdrawn

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6491 john park Campaign ‐ Woodland Trust

OBJ6492 John Powell Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6493 Jonathan Butcher Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6494 jonathan mead Campaign ‐ Woodland Trust

OBJ6495 Keith Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6496 Lesley Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6497 Josephine Bishop Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6498 Josie Thomas Campaign ‐ Woodland Trust

OBJ6499 Jane Rosser Campaign ‐ Woodland Trust Withdrawn

OBJ6500 John Davis Campaign ‐ Woodland Trust Withdrawn

OBJ6501 julia Barrell Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6502 Jessica Stokes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6503 Jude Aldridge Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6504 Judith Pendrous Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6505 Phil Bennett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6506 julie maffey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6507 Julian Langston Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6508 Emma Jackson Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 214 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6509 June and John Bowler Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6510 Louise Burrows Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6511 Dawn Billett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6512 Jeanie Gray Campaign ‐ Woodland Trust

OBJ6513 Keith Roylance Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust Karen Carmichael‐ OBJ6514 Campaign ‐ Woodland Trust Timson WG/REB/OBJ0271 ‐ Woodland Trust OBJ6515 Karen Frere‐Smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6516 Karis Dunford Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6517 Kate Blair Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6518 Kathryn Faulkner Campaign ‐ Woodland Trust

OBJ6519 Kathleen Mailer Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6520 Katherine Pritchard Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6521 Katy Powell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6522 kayleigh williams Campaign ‐ Woodland Trust

OBJ6523 karen ridout Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6524 Karen Collins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6525 Kevin Knowles Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6526 keith vaughton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6527 keith Mountain Campaign ‐ Woodland Trust

OBJ6528 Kenneth Brewer Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6529 Kerry Andrews Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6530 Kerryann Peat Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6531 Kevin Donovan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6532 Kevin Wood Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6533 Katie Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6534 Keith Gregory Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6535 Kim Dewsbury Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6536 Kim Westcott Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6537 Kirstin Chapman Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6538 Kit Waring Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6539 Kit Warwick Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 215 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6540 Kevin Stables Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6541 Tessa Roberts Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6542 Kylie Jones Mattock Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6543 Lila Cahue Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6544 Lucy Greenwood Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6545 ELAINE OREILLY Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6546 Laura Griffiths Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6547 Lauren Clark Campaign ‐ Woodland Trust

OBJ6548 Lewis Thomson Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6549 Lea Connelly Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6550 Lee Haskins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6551 Leighann Briggs Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6552 Lesley Doggett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6553 Lesley Mullan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6554 Lesley Morgan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6555 vaughan lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6556 Libby Tucker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6557 Linda Booth Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6558 lindsey Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6559 Lisa Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6560 Lis Parsons Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6561 Christine Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6562 Elizabeth Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6563 Mike Ronan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6564 Elizabeth Roberts Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6565 Llewellyn James Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust

Gerhard Lohmann‐ OBJ6566 Bond Campaign ‐ Woodland Trust

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6567 Louise Harvey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6568 Louise Fitzpatrick Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6569 Louise Cook Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 216 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6570 Louise Redfearn Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6571 Louise Hughes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6572 Irene Goldie Campaign ‐ Woodland Trust

OBJ6573 Bob Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6574 Lucia Doni Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6575 Lucie Sporle Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6576 Lucinda Bailey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6577 lucy campbell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6578 lorraine ward Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6579 Lyn McFarlane Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6580 Lynda Barnes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6581 Lynda Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6582 Lynda Hickling Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6583 Lynda Gripton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6584 Lynette Green Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6585 Lyn Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6586 Margred Scholey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6587 Michaela Hollyfield Campaign ‐ Woodland Trust

OBJ6588 mary johnson Campaign ‐ Woodland Trust Withdrawn

OBJ6589 Maria Teresa Agozzino Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6590 Madeleine Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6591 madeline warhurst Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6592 Maeve Caplin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6593 Maggie Powell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6594 Ian HOPKIN Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6595 elizabeth sandeman Campaign ‐ Woodland Trust

OBJ6596 Polly Pearshouse Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6597 Mal DELAMARE Campaign ‐ Woodland Trust

OBJ6598 malcolm hughes Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6599 Murray MacFarlane Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6600 Marc Harries Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6601 Margaret Cannings Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 217 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6602 margaret renshaw Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6603 MARGARET THOMAS Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6604 Maria Kloess Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6605 Mark Blackburn Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6606 Audrey Keppie Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6607 Mark Prina Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6608 Mark Watson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6609 Martin Fry Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6610 Martin Hughes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6611 Mary Wallis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6612 Mary Chances Campaign ‐ Woodland Trust

OBJ6613 Marylyn Bothamley Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6614 Mathew McCall Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6615 Matt Powell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6616 Matthew Esh Campaign ‐ Woodland Trust

OBJ6617 Maya James Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6618 Melissa Wilkins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6619 Meg Radley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6620 Megan Hayhurst Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6621 melissa compton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6622 Russell Halliday Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6623 Merryn Tully Campaign ‐ Woodland Trust

OBJ6624 Melanie Fritz Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6625 Mary Fiona Jones Campaign ‐ Woodland Trust

OBJ6626 Michael Hogan Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6627 MICHAEL THOMAS Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6628 mike benjamin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6629 mike benjamin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6630 Michael White Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6631 Michael Alexander Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6632 Michael Heminsley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6633 Mike Hamblett Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 218 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6634 Gwyneth Grahame Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6635 Michael McKenzie Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust Marilyn Everrson‐ OBJ6636 Campaign ‐ Woodland Trust Davis WG/REB/OBJ0271 ‐ Woodland Trust OBJ6637 Angela Porter Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6638 miranda mugford Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6639 Maureen Paterson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6640 Alison Rigg Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6641 Clare Morgan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6642 Aaron Pascall‐Willis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6643 Ed Lord Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6644 jason hill Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6645 Kate Dunning Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6646 Emma Buckley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6647 Sarah McCarthy Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6648 Brian Murphy Campaign ‐ Woodland Trust

OBJ6649 Miranda Whitten Campaign ‐ Woodland Trust Withdrawn Dr Norman OBJ6650 Campaign ‐ Woodland Trust Withdrawn Chamberlain WG/REB/OBJ0271 ‐ Woodland Trust OBJ6651 Nathalie Yonow Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6652 ANN YOUNG Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6653 Nigel Douglas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6654 Nell Bridges Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6655 Richard Power Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6656 nerys jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6657 Annette Brown Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6658 nicola Blackburn Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6659 Nicky Jevon Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6660 Nicola Rossiter Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6661 Nicola Bradbear Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6662 Nigel Devlin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6663 Norman Lowe Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6664 Yvonne Allan Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 219 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6665 Neil Ryding Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6666 Catherine John Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6667 Natalie Curtis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6668 kate leigh‐powell Campaign ‐ Woodland Trust

OBJ6669 Adrian Deere‐Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6670 Peter Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6671 Elaine Olsen Campaign ‐ Woodland Trust

OBJ6672 Osian Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6673 Owain Grant Campaign ‐ Woodland Trust

OBJ6674 Joan Davies Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6675 Brian Palmer Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6676 Pam Wesson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6677 pam lightfoot Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6678 Clare Smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6679 Jemma Thompson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6680 Stephen Parker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6681 PAT MCKENNA Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6682 Patricia Prabhu Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6683 Paul Wimpory Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6684 Paul Swann Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6685 PAULA HUNT Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6686 Paula Hughes Campaign ‐ Woodland Trust

OBJ6687 Paula Keen Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6688 Paula Harris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6689 Paul Phillips Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6690 Paul Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6691 Paul Gilhooley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6692 paul standley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6694 Lara Peachey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6695 Pete Bushell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6696 tom moses Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6697 Penny Johnson Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 220 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6698 penny Lyttle Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6699 Angela Thomas‐Collins Campaign ‐ Woodland Trust

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6700 Peta Yapp Campaign ‐ Woodland Trust

OBJ6701 Peter Wright Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6702 Katherine Jezukiewicz Campaign ‐ Woodland Trust

OBJ6703 Peter Ainsworth Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6704 Peter Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6705 Peter Martin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6706 Annie Thompson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6707 Philip Pritchard Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6708 Wendy Phillips Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6709 Karen Picton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6710 Hannah Phillips Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6711 Paul Seligman Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6712 Pippa Stanier‐Moore Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6713 Helen Okines Campaign ‐ Woodland Trust

OBJ6714 Janet Phillips Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6715 Richard Podger Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6716 Jeff Thomas Campaign ‐ Woodland Trust

OBJ6717 Sandra veasey Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6718 Daf Rogers Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6719 Craig Fergus‐jones Campaign ‐ Woodland Trust

OBJ6720 Amanda Price Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6722 paul webster Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6723 Paul Summerside Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6724 Tony Pullen Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6725 Rosemary Howell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6726 Ellen Routley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6727 Rachel Oram Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6728 Robert Dennison Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6729 Rhiannon Jones Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 221 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6730 Rhian welham Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6732 Sarah Habersberger Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6733 Rhys Aram Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6734 Sue Fudge Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6735 Richard Evans Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6736 Richard Goss Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6737 Richard Jenkins Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6738 Richard Chainey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6739 Richard Menmuir Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6740 rob rowe Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6741 Rob Edwards Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6742 Julia Bourne Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6743 Rod Walters Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6745 Roger Bennett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6746 roger brown Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6747 Caroline Hernon‐Biggs Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6748 Rory Francis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6749 Rosalind Foskett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6750 kathryn hayler Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6751 Rosemary Lang Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6752 Rosella D'Alesio Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6753 sue rose‐martin Campaign ‐ Woodland Trust ROSEMARY OBJ6754 Campaign ‐ Woodland Trust Withdrawn BASHFORD WG/REB/OBJ0271 ‐ Woodland Trust OBJ6755 Madeline Sadler Campaign ‐ Woodland Trust

OBJ6756 Rosemary Parkhouse Campaign ‐ Wildlife Trusts Wales Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6757 Rosey Mitchell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6758 Roshan Devonish Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6759 Rosemarie Whitley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6760 Rachel Owens Campaign ‐ Woodland Trust

OBJ6761 Raymond Parsons Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6762 Russell Amos Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6763 Ruth Bastawy Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 222 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

OBJ6764 Ruth Griffiths Campaign ‐ Woodland Trust Withdrawn

OBJ6766 Ruth Lovell Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6767 Sally Parker Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6768 samantha williams Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6769 Samantha Kay Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6770 Samantha West Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6771 Sam Bull Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6772 Sam Strong Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6773 Sandra Beynon Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6774 Sara Davis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6775 Sarah Cox Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6776 sarah attwood Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6777 sarah reece Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6778 Sarah Mills Campaign ‐ Woodland Trust

OBJ6779 Saran Allott‐Davey Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6780 Sawsan Bastawy Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6781 Sarah Willey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6782 Susan Harrison Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6783 Scott Lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6784 Selena Brenchley Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6785 Jayne Turner Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6786 Sheelagh Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6787 Susanne Eidens Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6788 Sherrie pember Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6789 Shirley Elwell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6790 Shona Roach Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6791 Cathrine Plumridge Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6792 Steve Hughes Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6793 Siani Palfrey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6794 Siany Humphries Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6795 Simon Hession Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6796 Simon Lewis Jones Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 223 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6797 Rebecca Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6798 Glenn Ibbitson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6799 Sonia Kiernan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6800 Nik Southwell Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6801 Amie Desmond Campaign ‐ Woodland Trust

OBJ6802 Jon Scott Campaign ‐ Woodland Trust Withdrawn

OBJ6803 Sarah Rowlands Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6804 D Driends Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6805 Susan Stubbs Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6806 Stan Townsend Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6807 Steffan Ellis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6808 Stephanie Lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6809 Stephanie Burgess Campaign ‐ Woodland Trust

OBJ6810 Stephen Redpath Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6811 stephen mullard Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6812 Steve Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6813 steve attwood‐wright Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6814 Steve Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6815 Steve Bennett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6816 Stuart Laslett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6817 susan wakefield Campaign ‐ Woodland Trust

OBJ6818 Susan Thomas Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6819 Sue Fellows Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6820 susan Furber Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6822 Susan Fisher Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6823 Susan Jones Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6824 susan lowe Campaign ‐ Woodland Trust

OBJ6825 Jennifer West‐Jones Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6826 Sue harris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6827 Loraine Surringer Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6829 Susan Squire Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6830 Steve Brown Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 224 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6831 Simon Walpole Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6832 Jenny Monteiro‐Ryan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6833 Susan Woodland Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6834 Michelle Waldman Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6835 Talat Chaudhri Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6836 Tav Ratcliffe Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6837 Terry Wells Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6838 terry abraham Campaign ‐ Woodland Trust

OBJ6839 John James Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6840 Fiona Clark Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6841 Alexis Gorton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6842 Robert Iles Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6843 Greg Robinson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6844 Darryl Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6845 Margaret Iggulden Campaign ‐ Woodland Trust

OBJ6846 Tim Hughes Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6847 Timm Frenzel Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6848 Tina Thomas Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6849 Tina martin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6850 Mark Jennings Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6851 Tiffany Emmett Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6852 Tracy Hanks Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6853 Muriel Harris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6854 Tony Comley Campaign ‐ Woodland Trust

OBJ6855 Anthony Hathaway Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6856 Robert Peel Campaign ‐ Woodland Trust

OBJ6857 O‐Dzin Tridral Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6858 Tristan Morgan Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6859 Teresa Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6860 Sandra Plaister Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6861 Laura Shewring Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6862 Valerie Brooker Campaign ‐ Woodland Trust

REVISED M4CAN objections schedule of evidence.xlsm 225 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

WG/REB/OBJ0271 ‐ Woodland Trust OBJ6863 John Davies Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6864 Val Short Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6865 vanessa thornton Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6866 Vanessa Elphick Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6867 R. Williams Campaign ‐ Woodland Trust

OBJ6868 justin vickery Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6870 Vanessa Mordin Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6871 William Maidlow Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6872 Sharon Chapman Campaign ‐ Woodland Trust

OBJ6873 lisa davies Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6874 Wendy Furminger Campaign ‐ Woodland Trust

OBJ6875 Clare Thomas Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6876 Leila Kiersch Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6877 William Smith Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6878 E Wilson Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6879 karen malvisi Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6880 william harris Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6881 Hugh Parry Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6882 roger houghton Campaign ‐ Woodland Trust

OBJ6883 Wendy Beever Campaign ‐ Woodland Trust Withdrawn WG/REB/OBJ0271 ‐ Woodland Trust OBJ6884 Wendy Bates Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6885 Sophie Lewis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6886 John Ellis Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6887 Andrew Bailey Campaign ‐ Woodland Trust WG/REB/OBJ0271 ‐ Woodland Trust OBJ6888 Ramunas Grabauskas Campaign ‐ Woodland Trust • Ecology and nature conservation Keith Jones WG1.18 • Alternatives Nicholas Rowson WG1.8 OBJ6889 Katie May Matthew Jones WG1.1.1 (Chapter 9) Document 4.7.2 WG/REB/OBJ0247

• Ecology and nature conservation Matthew Jones WG1.1.1 (Chapter 23) • Environment Document 4.7.2 • Alternatives OBJ6890 Dr & Mrs N H Williams

REVISED M4CAN objections schedule of evidence.xlsm 226 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Water quality Julia Tindale WG 1.10.1 (Paragraph 8.92) • Sustainable development Ben Sibert WG 1.5.1 (Paragraph 5.237‐5.240) • Economics Matthew Jones WG1.1.1 • Ecology and nature conservation Michael Bull 1.12

OBJ6891 Statutory Mr M Waters

• Alternatives Matthew Jones WG1.1.1 (Chapter 23) OBJ6892 Mr Arthur Cook Document 4.7.2

• Alternatives Matthew Jones WG1.1.1 (Chapter 23) OBJ6893 Frank Crockett Document 4.7.2 • Economics Matthew Jones WG1.1.1 (Chapter 23) OBJ6894 Ian Warren • Alternatives (also part of OBJ0206 Rogiet CC). Document 4.7.2

• Traffic Bryan Whittaker WG1.2.6 (Chapter 9.6) • Alternatives Matthew Jones WG1.1.1 (Chapter 23) Document 4.7.2 OBJ6895 Rhydian Lewis WG/REB/OBJ6895‐1–LEWIS

WG/REB/OBJ0270 - Gwent Wildlife Trust OBJ6896 Matthew Parry Campaign ‐ Gwent Wildlife Trust

Not an objection OBJ6897 Statutory Openreach ‐ BT Withdrawn

• Economics Matthew Jones WG1.1.1 (Chapter 24) OBJ6898 Tom Evans • Alternatives OBJ6899 Christine Stitfall Withdrawn Gwent Ornithological Same as OBJ0297 OBJ6900 Society Withdrawn Trevor Russell • Alternatives WG/REB/OBJ6901 ‐ Light Rail Transit Association (Alan Wilkins) Light Rail Transit PIQ/040 OBJ6901 Association (LRTA) PIQ/120 Alan Douglas Wilkins ID/073 Marshfield Community • General WG/REB/OBJ6902 ‐ Marshfield Community Council Council OBJ6902 Chairman: Mr Mathew Taylor Llangattock • Environment WG/REB/OBJ6903 ‐ Llangattock Community Council OBJ6903 Community Council Wentlooge Community • General WG/REB/OBJ6904 ‐ Wentlooge Community Council OBJ6904 Council Richard S Dean Pace Transportation • General WG/REB/OBJ6905 ‐ PACE OBJ6905 Ltd ID/073 Jenny Rathbone AM • Alternatives WG/REB/OBJ6906 ‐ Jenny Rathbone AM and Steve OBJ6906 and Steve Howell Howell OBJ6907 Cllr Brian Miles • General WG/REB/OBJ6907 ‐ Cllr Brian Miles • Alternatives WG/REB/OBJ6908 John Evans OBJ6908 Mr John Evans • Alternatives OBJ6909 Alwyn Jenkins Withdrawn

REVISED M4CAN objections schedule of evidence.xlsm 227 27/03/2018 Company / Respondent Statutory Objection Organisation / Topics Raised by Respondent EVIDENCE RESPONSE Number Objector withdrawn Respondent Name

• Sustainable development WG/REB/OBJ6910 ‐ Jane Blank ID/073 OBJ6910 Jane Blank ID/195 ID/222 WG/REB/OBJ6910‐3 • Economics WG/REB/OBJ6911 ‐ Louise Davies OBJ6911 Louise Davies • Ecology and nature conservation WG/REB/OBJ6911 ‐ Supplementary Rebuttal to Louise • Environment Davies OBJ6912 Matthew Williams Unsuitable for numerous reasons Withdrawn OBJ6913 Victoria Yeates No statement received Withdrawn OBJ6914 John Robertson • Ecology ‐ birds WG/REB/OBJ6914 ‐ John Robertson The Representative • Land use Supplementary (no.2) CPO Body of the Church in Statutory Wales OBJ6915 Neil Connor OBJ6916 John Holiday • Alternatives Matthew Jones WG1.1.1 Benjamin Potts‐ • Traffic WG/REB/OBJ6917 ‐ Mr Potts Johnson OBJ6917 Johnson • Alternatives • Environment WG/REB/OBJ6918 ‐ Catherine Grady Catherine Grady • Economics OBJ6918 • Alternatives • Flood consequence assessment WG/REB/OBJ6919 ‐ Dr Callaghan Dr Diana Callaghan OBJ6919 PIQ/113 OBJ6920 Phil James • Traffic WG/REB/OBJ6920 ‐ Phil James • General WG/REB/OBJ6921 ‐ Jeremy Randles and Jane Blank Jeremy Randles OBJ6921 OBJ6922 Elwyn Richards • Ecology and Nature conservation Correspondence Response Ref: qA1174612/OBJ6922 Future Generations • Sustainable development WG/REB/ISU0024/2 Commissioner for ID/033 Wales ID/072 Eurgain Powell/Sophie OBJ6923 Howe OBJ6924 D M Price • Alternatives Correspondence Response Ref: qA1174612/OBJ6924 • Environment Correspondence Response Ref: qA1174612/OBJ6925 Moth Foster • Noise & Vibration OBJ6925 • Economics OBJ6926 Nerys Lloyd‐Pierce • Ecology and nature conservation Correspondence Response Ref: qA1174612/OBJ6926 OBJ6927 Alastair McDougall • Alternatives WG/REB‐OBJ6927 ‐ Alastair McDougall OBJ6928 Lisa Buchholz • Ecology and nature conservation The Welsh Government's rebuttal was issued as ID181 Campaign Against the • Economics The Welsh Government's rebuttal was issued as ID182 Levels Motorway • Environment (CALM) OBJ6929 Catherine Linstrum

REVISED M4CAN objections schedule of evidence.xlsm 228 27/03/2018 Annex 2 - Table of Statutory Objectors whose rights under Protocol 1 Article 1 and/or Article 8 of the European Convention on Human Rights are engaged

Company / Description of land or Respondent Organisation / Property interest interfered Evidence Response Number Respondent Name with Private Means of Access. Proposed closure of one of two Julia Tindale WG 1.10.1 (Paragraphs 8.59-8.62) OBJ0003 Jeff Neale Tyn-y-Brwyn Farm access routes to his Barry Woodman WG 1.6.1 (Paragraphs 10.2-10.5 & 10.8- property. A 10.11) maintenance right taken over the other. WG/REB/OBJ0026 - Rebuttal to Simon Turl WG/REB/OBJ0026 - Rebuttal to Mke Axon - by Dr P Ireland WG/REB/OBJ0026 - Rebuttal to Mike Axon - by Bryan Whittaker WG/REB/OBJ0026 ; OBJ0292 BWo Rebuttal - Roadchef & Rontec - Construction WG/REB/OBJ0026 ; OBJ0292 Bwo Erratum Rebuttal - Roadchef & Rontec - Construction WG/REB/OBJ0026 ; OBJ0292 JD Rebuttal - Roadchef & Road Chef Magor Services. J23 Rontec - Planning Simon Turl, Woodland areas within OBJ0026 M4, Caldicot, NP26 WG/REB/OBJ0026 ; OBJ0292 MJ Rebuttal - Roadchef & Chief Executive, the Roadchef Freehold 3YL Rontec - Decision Making and Policy RoadChef WG/REB/OBJ0026 ; OBJ0292 SB Rebuttal - Roadchef & Rontec - Economics WG/REB/OBJ0026 ; OBJ0292 SB Supplementary Rebuttal - Roadchef & Rontec - Economics WG/REB/OBJ0026 ; OBJ0292 BS Rebuttal - Roadchef & Rontec - Engineering PIQ/123 ID/078 ID/091 ID/094 (Statement of Common Ground) Part of Golf Course Parc Golf Club (commercial OBJ0049 Parc Golf Club WG/REB/OBJ0049 - Parc Golf Club TG Hicks enterprise) taken as title. Industrial Part of internal access Matthew Jones WG 1.1.1 (Paragraph 3.18-20 and Chapter IAC Systems Automations and OBJ0068 route for commercial 23) Peter Lewis Control (IAC) property. Ben Sibert WG 1.5.1 (Paragraph 5.13-5.16) Holdings Limited Commercial operations WG/REB/OBJ0031 - ABP Port Security (Newport Docks). Land PIQ/012 OBJ0095 Authority Newport Docks and rights acquired PIQ/032 Ian Meredith over Newport Docks. PIQ/039

Agricultural land taken Michael Vaughan WG 1.17.1 (Paragraphs 4.46-4.58) as title mitigation. Julia Tindale WG 1.10.1 (Paragraghs 8.4-8.9) Mr John Watts-Baker Agricultural land is Ben Sibert WG 1.5.1 (Paragraphs 5.30-5.32) OBJ0145 & Mr Peter Watts- Maerdy Farm away from place of Peter Ireland WG 1.7.1 (Paragraph 10.17) Baker home (which is Great Paul Canning WG 1.16.1 (Paragraph 7.1 & Chapter 4 & Osbaston Farm, 5) Monmouth). Julia Tindale WG 1.10.1 (Paragraph 8.116) Footpath / cycleway Railway Paths Ltd Title and rights taken to Ben Sibert WG 1.5.1 (Paragraph 5.33-5.36) adjacent to OBJ0148 Howard Jones (on footpath over which Bryan Whittaker WG 1.2.6 (Paragraph 3.3.1-3.3.8 & 4.1- Corporation Road, behalf of Sustrans) Sustrans have a right. 4.9) Newport. Ben Sibert WG 1.5.1 (Paragraphs 4.124-4.127) Barry Woodman WG 1.6.1 (Paragraphs 10.13-10.24) Green Farm, Agricultural land taken Bryan Whittaker WG 1.2.6 (Paragraph 4.1-4.9) OBJ0152 Mrs S E Phillips Llanfihangel Rogiet. as title Matthew Jones WG 1.1.1 (Chapter 13) Mick Rawlings, 1.9.1 Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & Nicholas Victor Access to property Whitecross Farm, St. 10.3.4-10.3.5) OBJ0207 Clarke included for tying in to Brides, Wentloog Ben Sibert WG 1.5.1 (Paragraph 5.37-5.41) Rebecca Jane Clarke new overbridge Barry Woodman WG 1.6.1 (Paragraphs 10.82) Company / Description of land or Respondent Organisation / Property interest interfered Evidence Response Number Respondent Name with Title & Essential Daffodil Lodge & Unit Licence taken to part of WG/REB/OBJ0209 - Mr Rabbitt, Daffodil Lodge OBJ0209 Clive William Rabbitt 3 Knollbury Business back garden of ID/086 Park residential property Whole of residential OBJ0211 T.C. F . Allen Myrtle Cottage Ben Sibert WG 1.5.1 (Paragraph 5.45-5.49) property and garden Agricultural farmland R.P Richardson taken as title. Julia Tindale WG 1.10.1 (Paragraphs 8.10-8.11) 45 Ffos y Fran, OBJ0212 (Agricultural land is Ben Sibert WG 1.5.1 (Paragraph 5.50-5.52) Mrs D. Alred located away from Peter Ireland WG 1.7.1 (Paragraph 10.18) place of residence) Agricultural holding taken as title for Julia Tindale WG 1.10.1 (Paragraphs 8.12-8.17) building road & Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & associated 10.3.4-10.3.5) OBJ0213 JS & RE Anstey Old Court Farm infrastructure. Part of Ben Sibert WG 1.5.1 (Paragraph 5.53-5.59) access track leading to Barry Woodman WG 1.6.1 (Paragraphs 10.82) the home taken as Peter Ireland WG 1.7.1 (Paragraph 10.22) easement for discharge pipe maintenance

Agricultural holding taken as title for building road & Barry Woodman WG 1.6.1 (Paragraphs 10.82) associated Julia Tindale WG 1.10.1 (Paragraphs 8.18-8.23) OBJ0214 SG Anstey Court Farm infrastructure. Part of Philip Evans WG 1.14.1 (Paragraphs 4.8.1 - 4.8.9 & access track leading to 10.3.4-10.3.5) the home taken as Ben Sibert WG 1.5.1 (Paragraphs 5.60-5.69) easement for discharge pipe maintenance

Agricultural field taken for essential mitigation OBJ0215 D Colley Great House, Undy ID191 Field not located near the property. Agricultural land taken as title, front garden taken as essential Mr Derek Trevor Fair Orchard Farm, St. OBJ0216 licence, & amendment Modification 30 David Brides, Wentloog to one of his points of access into his farm holding. Huw Richard Agricultural land taken Edwards as title. New means of Julia Tindale WG 1.10.1 (Paragraphs 8.36-8.41) OBJ0217 New Dairy Farm access provided to Ben Sibert WG 1.5.1 (Paragraph 5.83-5.88) Brenda Kathleen severed land. Barry Woodman WG 1.6.1 (Paragraphs 10.82) Edwards Commercial farmland.

Agricultural field taken Barry Woodman WG 1.6.1 (Paragraphs 10.82) Land lying next to as title for motorway Julia Tindale WG 1.10.1 (Paragraph 8.43) OBJ0219 Exectors of DG Harris Green Moor Lane, and title mitigation Not Ben Sibert WG 1.5.1 (Paragraph 5.90-5.95) Magor part of home. Not next Peter Ireland WG 1.7.1 (Paragraph 10.28) to home.

Part of agricultural field taken as title for the Barry Woodman WG 1.6.1 (Paragraphs 10.82) new highway. Rights Cefn Henllan, Julia Tindale WG 1.10.1 (Paragraph 8.44) OBJ0220 M.D.W Hazell taken over same field Caerleon Ben Sibert WG 1.5.1 (Paragraph 5.96-5.100) for maintenance of Peter Ireland WG 1.7.1 (Paragraph 10.29) environmental fencing. Not near to home. Company / Description of land or Respondent Organisation / Property interest interfered Evidence Response Number Respondent Name with Title taken over agricultural land (under both freehold and Barry Woodman WG 1.6.1 (Paragraphs 10.82) tenanted) for North Court Farm, Julia Tindale WG 1.10.1 (Paragraph 8.45-8.47) OBJ0223 David Howard James construction of new North Row Ben Sibert WG 1.5.1 (Paragraph 5.102-106) motorway and Peter Ireland WG 1.7.1 (Paragraphs 10.30) associated infrastructure. Not by the home. Trustees of

FH James Joyce Doubleday Agricultural fields taken Frank Jones as title for new Diane Price Barry Woodman WG 1.6.1 (Paragraphs 10.82) Penterry Farm, motorway and for OBJ0224 Heather Richards Ben Sibert WG 1.5.1 (Paragraph 5.107-5.112) environmental Kathleen Harris Peter Ireland WG 1.7.1 (Paragraphs 10.31-10.33) mitigation. Not near the Rosemary Ballard home. Janet Corbett Judith Parry Trustees of FH James Partnership Barry Woodman WG 1.6.1 (Paragraphs 10.82) Agricultural fields taken Julia Tindale WG 1.10.1 (Paragraph 8.48-49) as title for new Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & Red House Farm, motorway and for OBJ0225 R.M Jenkins 10.3.4-10.3.5) Llandevenny environmental Ben Sibert WG 1.5.1 (Paragraph 5.113-5.117) mitigation. Not near the Peter Ireland WG 1.7.1 (Paragraphs 10.34 & 11.24- home. 11.30)

Roger Jones Agricultural fields and Gillian Jones part of rear garden New Park Farm, WG/REB/OBJ0277 - New Park Farm OBJ0227 Kate Jones taken as environmental Castleton Matthew Jones mitigation. Rear garden Rhiannon Jones of family home.

Agricultural field taken as essential licence (i.e. temporary). Right taken over part of field for PID191 maintenance of Julia Tindale WG 1.10.1 (Paragraph 8.59-8.62) OBJ0228 William David Jones Carrowhill Farm drainage pipe, and title Ben Sibert WG 1.5.1 (Paragraph 5.129-5.135) taken for a drainage Barry Woodman WG 1.6.1 (Paragraphs 10.8-10.11) headwall. Not in immediate vicinity of farm.

Agricultural paddocks Barry Woodman WG 1.6.1 (Paragraphs 10.82) taken for attenuation Michael Bull WG 1.12.1 (Chapter 3 & paragraph 5-5.5) OBJ0229 John & Joan Major Langley Villa, Magor ponds. Part of rear Julia Tindale WG 1.10.1 (Paragraph 8.118-8.119) garden taken as Ben Sibert WG 1.5.1 (Paragraph 5.136-5.140) dedication for footpath Peter Ireland WG 1.7.1 (Paragraphs 11.40-11.46) Barry Woodman WG 1.6.1 (Paragraphs 10.82) Agricultural land taken Julia Tindale WG 1.10.1 (Paragraph 8.63-8.65) as title and title Philip Evans WG 1.14.1 (Paragraphs 4.8.1 - 4.8.9 & Cefn Llogell Fach, OBJ0230 Laura Neville mitigation.Not in 10.3.4-10.3.5) immediate vicinity of Ben Sibert WG 1.5.1 (Paragraph 5.141-5.146) house. Peter Ireland WG 1.7.1 (Paragraphs 10.38 & 11.47- 11.53)

Agricultural land taken as title mitigation on Nicholas Simon Park Caldicot Levels, and part of agricultural field PID191 Alicia Sarah White House Farm, OBJ0231 taken as essential WG/REB/OBJ0231 - Mr N S Park Sophie Rebecca licence (i.e. temporary) Verity Lydia for access route to Ifton Adam Brandon Quarry. Land not near the home. Company / Description of land or Respondent Organisation / Property interest interfered Evidence Response Number Respondent Name with PID191 WG/REB/OBJ233 - Phillips Agricultural land taken PIQ/117 Christine Margaret Green Farm, OBJ0232 as title Agricultural land Julia Tindale WG 1.10.1 (Paragraph 8.69-8.76) Phillips Llanfihangel Rogiet. surrounding the home Ben Sibert WG 1.5.1 (Paragraph 5.151-5.154) Peter Ireland WG 1.7.1 (Paragraphs 11.54-11.61)

PID191 Agricultural land taken Stephen Charles Green Farm, WG/REB/OBJ0233 - Mr S C Phillips OBJ0233 as title Agricultural land Phillips Llanfihangel Rogiet. PIQ/112 surrounding the home PIQ/117

Agricultural land taken as essential licence (i.e. temporary) for works. Title taken to Llewellyn Morgan agricultural field for PID191 OBJ0235 The Beeches, Magor Pritchard new highway. Title WG/REB/OBJ0235 - Mr L Pritchard - The Beeches taken to rear garden for provision of new private means of access for use by Mr Pritchard.

Agricultural fields taken Julia Tindale WG 1.10.1 (Paragraph 8.81) as title for new 16 Highfield, Ben Sibert WG 1.5.1 (Paragraph 5.172-5.176) OBJ0236 William Reece motorway and for Caerwent, Monmouth Peter Ireland WG 1.7.1 (Paragraphs 10.43 & 11.66- environmental 11.67) mitigation

Agricultural field taken as title for building new Bencroft Lane Land between M48 Julia Tindale WG 1.10.1 (Paragraph 8.69-8.76) OBJ0237 Jane Renton Overbridge. Ms Renton and B4245 Ben Sibert WG 1.5.1 (Paragraph 5.163-5.166) lives in Weymouth, but ownes this parcel of land.

Agricultural fields taken as title for new side Julia Tindale WG 1.10.1 (Paragraph 8.82-8.84) road alignment. Title Philip Evans WG 1.14.1 (paragraphs 4.8.1 - 4.8.9 & Mitigation taken for 10.3.4-10.3.5) OBJ0238 Arthur George Smith Orchard Farm sheltering building Ben Sibert WG 1.5.1 (Paragraph 5.177-5.181) from motorway. Title Barry Woodman WG 1.6.1 (Paragraphs 10.2 & 5.8-5.10 taken for new PMA for & 5.16-5.19 & 10.82) use by Mr Smith Not near to home. Title taken over agricultural land (under both freehold and Messrs. J.J. & A.D. Church Farm, St. tenanted) for OBJ0239 Ben Sibert WG 1.5.1 (Paragraph 5.182-5.184) Turner & Sons Brides construction of new motorway and associated infrastructure. Agricultural fields taken Barry Woodman WG 1.6.1 (Paragraphs 10.82) Hendrew Farm, OBJ0240 Alan James Williams as title and title Ben Sibert WG 1.5.1 (Paragraphs 5.185-5.190) Llandeuvad mitigation. Peter Ireland WG 1.7.1 (Paragraph 10.44) PID191 Agricultural field taken Barry Woodman WG 1.6.1 (Paragraphs 10.82) as easement for the Lyndon James Michael Bull WG 1.12.1 (Paragraph 11.1) OBJ0241 right to flood Not Williams Julia Tindale WG 1.10.1 (Paragraph 8.85-90) immediately adjacent to Ben Sibert WG 1.5.1 (Paragraph 5.191-5.197) home. Peter Ireland WG 1.7.1 (Paragraphs 11.68-11.69) Company / Description of land or Respondent Organisation / Property interest interfered Evidence Response Number Respondent Name with WG-REB-OBJ0270.1 - Prof Marsden WG-REB-OBJ0270.2 - Prof Calvin Jones WG-REB-OBJ0270.2 – Prof Calvin Jones Addendum WG-REB-OBJ0270.3 – Prof John Whitelegg WG-REB-OBJ0270.4 - Prof Kevin Anderson WG-REB-OBJ0270.4 - Errata to Rebuttal to Prof Kevin Anderson WG-REB-OBJ0270.5 - Prof Lorrain Whitmarsh WG-REB-OBJ0270.6 – Prof John Altringham WG-REB-OBJ0270.6 - Prof John Altringham Environmental land Addendum Gwent Wildlife Trust (marshland) taken as WG-REB-OBJ0270.7 – David Boyce OBJ0270 Magor Marsh Ian Rappel title for construcion of WG-REB-OBJ0270.8 - Richard Bakere new highway. WG-REB-OBJ0270.11 - Geoff Liles WG-REB-OBJ0270.11 - Geoff Liles Erratum WG-REB-OBJ0270.12 - Prof John Lawton WG-REB-OBJ0270.13 - Lindi Rich WG-REB-OBJ0270.14 - Neil Ward WG-REB-OBJ0270.15 – Mike Webb WG-REB-OBJ0270.17 - Iolo Williams PIQ/055 ID/051 ID/068 ID/073 Private Means of Access. Proposed closure of one of 2 Ben Sibert WG1.5.1 (Paragraphs 4.217-8 OBJ0273 Claire Rose Ty'n y Brwyn access routes to his Julia Tindale WG1.10.1 (Paragraphs 8.59-62) property. A maintenance right taken over the other. Part of commercial premises taken for ne Origin UK Operations OBJ0291 Newport Docks waccess way for ABP & WG/REB/OBJ0031 - ABP Ltd all associated tenants / leaseholders WG/REB/OBJ0026 - Rebuttal to Simon Turl WG/REB/OBJ0026 - Rebuttal to Mke Axon - by Dr P Ireland WG/REB/OBJ0026 - Rebuttal to Mike Axon - by Bryan Whittaker WG/REB/OBJ0026 ; OBJ0292 BWo Rebuttal - Roadchef & Rontec - Construction WG/REB/OBJ0026 ; OBJ0292 Bwo Erratum Rebuttal - Roadchef & Rontec - Construction WG/REB/OBJ0026 ; OBJ0292 JD Rebuttal - Roadchef Rontec Roadside Woodland areas within & Rontec - Planning OBJ0292 Newport Docks retail the Roadchef Freehold WG/REB/OBJ0026 ; OBJ0292 MJ Rebuttal - Roadchef & Rontec - Decision Making and Policy WG/REB/OBJ0026 ; OBJ0292 SB Rebuttal - Roadchef & Rontec - Economics WG/REB/OBJ0026 ; OBJ0292 SB Supplementary Rebuttal - Roadchef & Rontec - Economics WG/REB/OBJ0026 ; OBJ0292 BS Rebuttal - Roadchef & Rontec - Engineering ID/078 ID/089 ID/091 Par of commercial building required to WE Dowds Shipping OBJ0302 Newport Docks route new means of WG/REB/OBJ0031 - ABP Ltd access for ABP and associated tenants Part of commercial Stephenson Street Barry Woodman WG 1.6.1 (Paragraphs 10.27-10.29) operational equipment OBJ0305 Hanson Uk Industrial Site, Ben Sibert WG 1.5.1 (Paragraph 5.210-5.213) required as land for Newport Matthew Jones WG1.1.1 (Chapter 24) temporary works. Company / Description of land or Respondent Organisation / Property interest interfered Evidence Response Number Respondent Name with Commercial leasehold Ben Sibert WG 1.5.1 (Paragraph 5.278-5.284) Leasehold at Eastway OBJ0312 CJN Engineering Ltd premises required Matthew Jones WG1.1.1 (Chapter 19) Road, Newport Docks during construction WG/REB/OBJ0031 - ABP

Jewson Ltd & Saint Leasehold off Commercial storage Ben Sibert WG 1.5.1 (Paragraph 5.285-5.291) OBJ0313 Gobain Building Road, land required during Jonathan Vine WG 1.22.1 (Paragraphs 8.3.1-8.3.9) Distribution Limited Newport Docks construction WG/REB/OBJ0031 - ABP

Bulk hauliers UK & Commercial operations Ben Sibert WG 1.5.1 (Paragraph 5.292-5.298) OBJ0316 Europe Newport Docks leasehold within Port of Matthew Jones WG1.1.1 (Chapter 19) Ronnie Evans Newport Title taken over Burnt House Farm, Ben Sibert WG 1.5.1 (Paragraph 5.224-5.227) OBJ0317 Technoplan Anstalt potential Residential Newport Peter Ireland WG 1.7.1 (Paragraphs 10.47-10.48) Development Land. Julia Tindale WG 1.10.1 (Paragraph 8.91) Mark Williams Ben Sibert WG 1.5.1 (Paragraph 5.228-5.232) Mark Skinner Title taken over part of Agricultural land at Barry Woodman WG 1.6.1 (Paragraphs 10.74-10.76 & OBJ0322 Mark Williams Agricultural holding Castleton 10.82) Pension Fund Not near the home(s) Matthew Jones WG1.1.1 (Chapter 24) Clive Coulthard Document 4.7.2 Essential Licence taken WG/REB/OBJ0329 - Marshall's Marshalls Group OBJ0329 Newport Docks over commercial WG/REB/OBJ0329 - Erratum to Marshall's Rebuttal Andrew Johnson enterprise and works ID/216 Barry Woodman WG 1.6.1 (Paragraphs 10.2-10.5, 10.8- Private Means of 10.11 & 5.8-5.10 & 5.16-5.19) Access. Proposed Matthew Jones WG 1.1.1 (Paragraph 3.18-20 & 22.28- closure of one of 2 Christopher & Wendy Ty'n y Brywn, 22.30 & 22.33-22.36 and Chapter 9 OBJ0330 access routes to his Perkins Castleton Phil Evans WG1.14 property. A Tim Chapman WG1.13 maintenance right Document 4.7.2 taken over the other. WG/REB/OBJ0247

Rights for maintenance of environmental UK Health Care Bryn Ivor Lodge Care OBJ0339 fencing taken over Ben Sibert WG 1.5.1 (Paragraph 5.233-5.236) Property 1 LLP Home gardens of Residential Care Home

Title taken to leasehold Julia Tindale WG 1.10.1 (Paragraph 8.92) agricultural land for the Ben Sibert WG 1.5.1 (Paragraph 5.237-5.240) Great House Farm, construction of a new OBJ6891 Mr M Waters Matthew Jones WG1.1.1 Nash attenuation pond. Land Michael Bull 1.12 not located near residential home

Title taken to property The Representative known as Woodland Body of the Church in Woodland House / OBJ6915 House / Magor Supplementary (no.2) CPO Wales Magor Vicarage Vicarage, as well as Neil Connor surrounding land.

ANNEX 3

Note on Habitats Directive, Regulations and Waddenzee C-127/02

1. Council Directive 92/43/EEC on the Conservation of Natural Habitats and of wild Fauna and Flora

1.1 The Directive broadly covers 2 topics of ecological significance – protected sites (Natura Sites – in the UK, SACs, SPAs and RAMSAR sites) and protected habitats and species.

1.2 The objectives of the Directive in respect of each are connected but the provisions relating to them are distinct and, of course, different considerations arise in relation, on the one hand, to large areas of land or water and, on the other, an extensive list of individual habitat types and faunal/plant species. Its main aim, however, is described in the Recitals as “to promote the maintenance of biodiversity, taking account of economic, social, cultural and regional requirements” making a contribution to the “general objective of sustainable development”.

1.3 With regard to protected species, the objective is “to conserve them”.

1.4 Art. 1 definitions include :

“‘Conservation’ means a series of measures required to maintain or restore the natural habitats and the populations of species of wild fauna and flora at a favourable status as defined [below]”

“‘Conservation status of a species’ means the sum of the influences acting on the species concerned that may affect its long-term distribution and abundance of its populations within the territory referred to in Art. 2”

“The ‘conservation status’ will be taken as ‘favourable’ when:

- population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats, and

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- the natural range of the species is neither being reduced nor is it likely to be reduced for the foreseeable future, and

- there is and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.” (Emphasis added).

1.5 Art. 2 provides:

1.“The aim of this Directive shall be to contribute towards ensuring biodiversity through the conservation of natural habitats and of wild fauna and flora in the European territory of the Member States to which the Treaty applies.

2. Measures taken pursuant to this Directive shall be designed to maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest.

3. Measures taken pursuant to this Directive shall take account of economic, social and cultural requirements and regional and local characteristics.” (Emphasis added).

1.6 Arts. 3 to 11 are headed “Conservation of natural habitats and habitats of species.” These Articles deal with the Natura 2000 Sites – i.e. SACs and designations of similar status such as SPAs. They relate to habitat and species types set out in Annexes I and II to the Directive. Art. 6 is the provision which was in issue in the Waddenzee case (C-127/02).

1.7 Arts. 12 to 16 are headed “Protection of Species”.

1.8 The Commission’s guidance on the Directive refers to these two parts as two closely interlinked “pillars” of protection and points out that the Natura sites pillar requires positive maintenance, restoration/ improvement, whereas the second pillar concerning species is of a preventative character.1

1 ‘Guidance document on the strict protection of animal species of Community interest under the Habitats Directive 92/43/EEC’ (February 2007) produced by the Commission in close consultation with Member States

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1.9 Art. 12 provides for the compulsory introduction of measures for the strict protection of certain species of fauna, as follows:

1. “Member States shall take the requisite measures to establish a system of strict protection for the animal species listed in Annex IV (a) in their natural range, prohibiting:

(a) all forms of deliberate capture or killing of specimens of these species in the wild;

(b) deliberate disturbance of these species, particularly during the period of breeding, rearing, hibernation and migration;

(c) deliberate destruction or taking of eggs from the wild;

(d) deterioration or destruction of breeding sites or resting places.

2. For these species, Member States shall prohibit the keeping, transport and sale or exchange, and offering for sale or exchange, of specimens taken from the wild, except for those taken legally before this Directive is implemented.

3. The prohibition referred to in paragraph 1(a) and 1(b) and paragraph 2 shall apply to all stages of life of the animals to which this Article applies.

4. Member States shall establish a system to monitor the incidential capture and killing of the animal species listed in Annex IV (a). In the light of the information gathered, Member States shall take further research or conservation measures as required to ensure that incidental capture and killing does not have a significant negative impact on the species concerned”.

1.10 Art. 13 makes equivalent provision in relation to plants listed in Annex 4b.

1.11 Arts. 13 to 15 provide for the discretionary qualified protection of other lists of plants and species listed in Annex V. They are species which are regularly hunted in Europe for example wolves, salmon and hares. The Commission guidance refers to the Annex V list as including species which

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may be “exploited”, subject to such exploitation not jeopardising their conservation status. Art. 15 prohibits certain means of killing, taking etc species listed in Annex V or Annex IVa species in respect of which there has been a derogation granted under Art. 16 these are, broadly speaking, methods which might be deemed unnecessarily cruel or “unsporting” or indiscriminate or invasive.

1.12 Art. 16 provides for derogations from the provisions of Arts. 12–15 and reporting on them as follows; (Emphasis added).

1. “Provided that there is no satisfactory alternative and the derogation is not detrimental to the maintenance of the populations of the species concerned at a favourable conservation status in their natural range, Member States may derogate from the provisions of Articles 12, 13, 14 and 15 (a) and (b):

(a) in the interest of protecting wild fauna and flora and conserving natural habitats;

(b) to prevent serious damage, in particular to crops, livestock, forests, fisheries and water and other types of property;

(c) in the interests of public health and public safety, or for other imperative reasons of overriding public interest, including those of a social or economic nature and beneficial consequences of primary importance for the environment;

(d) for the purpose of research and education, of repopulating and re-introducing these species and for the breedings operations necessary for these purposes, including the artificial propagation of plants;

(e) to allow, under strictly supervised conditions, on a selective basis and to a limited extent, the taking or keeping of certain specimens of the species listed in Annex IV in limited numbers specified by the competent national authorities.

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2. Member States shall forward to the Commission every two years a report in accordance with the format established by the Committee on the derogations applied under paragraph 1. The Commission shall give its opinion on these derogations within a maximum time limit of 12 months following receipt of the report and shall give an account to the Committee.

3. The reports shall specify:

(a) the species which are subject to the derogations and the reason for the derogation, including the nature of the risk, with, if appropriate, a reference to alternatives rejected and scientific data used;

(b) the means, devices or methods authorized for the capture or killing of animal species and the reasons for their use;

(c) the circumstances of when and where such derogations are granted;

(d) the authority empowered to declare and check that the required conditions obtain and to decide what means, devices or methods may be used, within what limits and by what agencies, and which persons are to carry but the task;

(e) the supervisory measures used and the results obtained.”

1.13 Art. 16 provides for the reports to specify: the species in respect of which derogations are granted, and the reason for it, including “if appropriate…..scientific data used”. (Emphasis added)

1.14 Art. 6, dealing with Natura 2000 sites, provides as follows:

1. “For special areas of conservation, Member States shall establish the necessary conservation measures involving, if need be, appropriate management plans specifically designed for the sites or integrated into other development plans, and appropriate statutory, administrative or contractual measures

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which correspond to the ecological requirements of the natural habitat types in Annex I and the species in Annex II present on the sites.

2. Member States shall take appropriate steps to avoid, in the special areas of conservation, the deterioration of natural habitats and the habitats of species as well as disturbance of the species for which the areas have been designated, in so far as such disturbance could be significant in relation to the objectives of this Directive.

3. Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.

4. If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.”

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1.15 Pausing there, we should note the following points:

(a) that the Natura sites are intended to form a European ecological network and are therefore areas which are of sufficient substance, individually, to operate, as it were, in a transboundary way.

(b) That Art. 6(3) sets up a two-stage process, as has been recognised and developed in the UK in the wake of Waddenzee – an initial threshold stage (likely to have a significant effect on the Euro site, alone or in combination) and a determination stage (after Appropriate Assessment (AA)) if necessary, having applied the threshold test). In our case, we have decided that the threshold test was not passed and have therefore gone on to do the AA, which is uncontroversial as between Welsh Government and Natural Resources Wales.2

(c) That, in the event that a plan or project fails both the Art. 6(3) tests and Art. 6(4) permits a derogation for IROPI, with an attendant duty on the Member State to take relevant compensatory measures.

(d) Waddenzee related to the Art. 6(3) process, not the Art. 6(4) derogation process; the question arose at the Art. 6(3) stage – should there have been an AA and, if so, what standard of proof should have applied to it before the competent authority could properly decide that it had “ascertained” that the plan or project would not adversely affect the integrity of the SAC? Derogation was not considered in the decision.

2 GWT has a separate objection to the SIAA on the basis of otters

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(e) Art. 16, on the other hand, starts from the position that there will be a contravention of Art. 12. For example that there will be some form of relevant impact on a feature [in this case, a species or habitat] which is the subject of the Directive’s protection; in other words, if one is comparing it to Art. 6, it starts at a stage equivalent to Art. 6(4) (not the subject of Waddenzee) rather than Art. 6(3) (the threshold and post AA stages, devoted to asking and answering the question whether or not there will be relevant harm to a feature [in that case, a site] which is the subject of the Directive’s protection).

(f) Waddenzee is silent on the question of derogation generally.

(g) The Art. 6(3) questions are:

- whether the plan or project is likely to have a significant effect on the site in view of the site’s conservation objectives? (The threshold stage).

- whether it has been ascertained that the plan or programme will not adversely affect the integrity of the site?

Waddenzee established that these questions are to be asked and answered on the basis of exclusion of reasonable scientific doubt (a very high standard of proof involving the establishment of a negative). We must remember that each of the individual sites in question is, by definition, of international significance and that Art. 6(3) is not concerning itself with the separate question of a derogation.

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(h) No question of whether or not the conservation status of any species is favourable arises under Art. 6. The Art. 6 questions are related to significant effects upon and the integrity of Natura sites; the terms “significant effects” and “integrity”, unlike “favourable conservation status” are not defined in the Directive.

(i) The ecological precondition to be established under Art. 16 is that the derogation would not be detrimental to the maintenance of the populations of the species concerned at a favourable conservation status in their natural range; the causal test, therefore, links the effect of the activity authorised by the relevant derogation to the conservation status of the relevant species.3

(j) Returning to the definitions in Art. 1, we can note the following:

- conservation status of a species relates to relates to the territory of the Member States in Europe; this must either mean the status of that species across all the Member States or the relevant Member State; the wording is not entirely clear but, given the objectives of the Directive, the better view would appear to be that it means the territory of all the Member States. Arts 16(3) and 17 require Member States to forward information on derogations and also implementation of measures generally under the Directive to the Commission, which is consistent with a pan-Europe approach to interpreting Art. 2; however, the Commission’s guidance at para 50 states:

3 Since Annex IV specifies “all species” under Microchiroptera ( ‘microbats’, an old fashioned term now taken to mean bats generally (Wikipedia), as opposed to the more general term ‘chiroptera’ used in Annex II), the relevant tests are to be applied individually to each species of bat, eg. Lesser Horseshoe, Common Pipistrelle etc rather than collectively to bats in general

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(50) Considering the first question, it should be recognised that the conservation status of the (local) population of a species in a certain geographical area might well be different from the overall conservation status of populations in the biogeographic region in the Member State (or even the range). Both situations should be considered and taken into account in any decision.

That guidance would suggest, (in my view, contrary to the wording of Art. 2) that we are dealing here with a smaller series of areas which will be different for each relevant species concerned.

Favourable conservation status is to be judged by reference to 3 factors: population dynamics data, natural range neither being reduced or likely to be reduced for the foreseeable future and present and probable future existence of sufficiently large habitat to maintain populations on a long-term basis.

Therefore, it would appear that the context or metric within which the favourable conservation status question is to be judged under Art 16. is either Europe- wide – “the European territory of the Member States” - or UK-wide – the particular Member State in question. 4

The third element of the favourable conservation status question asks whether “there is and will PROBABLY continue to be a sufficiently large habitat to maintain its populations on a long-term basis” (emphasis added).

(k) The third element (emboldened) above is, clearly, highly pertinent to the issue of whether or not the Waddenzee standard of proof employed for the Art. 6(3) questions also applies to Art. 16; the fact that the Art. 16 question about favourable conservation status includes within it a limb framed in terms of probability makes it clear that

4 Allowing for fn.1 re Brexit – ie. one continues to apply provisions on the basis of UK’s being a MS

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the test is to be applied on the conventional ‘civil’ standard of proof of balance of probabilities, rather than the higher Waddenzee standard of exclusion of reasonable scientific doubt.

(l) The fact that the reporting duty in Art. 16(3) envisages that scientific data will not inevitably or always be required (only “if appropriate”) is consistent with the application of a lesser standard of proof than in the case of Art 6(3).

(m) The Precautionary Principle applies as a general principle of European environmental law and was relied upon by the Court in Waddenzee as part of its justification for ruling that the very high standard of proof applied to Art. 6; but that is not to say that this same standard of proof applies to every single question or test which falls to be determined under the Habitats Directive and the Court did not so decide.

The Commission’s guidance explicitly states that the severity of the “tests” or “conditions” varies depending on the severity of the impact on the population; this is only guidance, but such a “sliding scale” approach is inconsistent with a uniformly very high standard of proof.5 This approach is also much closer to what Professor Altringham said in his oral evidence about the standard of proof he regards as appropriate than the “no reasonable scientific doubt” set out in Charles Streeten’s opening preliminary legal submissions, though not repeated in GWT’s closing.

(n) Art 12(1)(b) - deliberate disturbance – is to be contrasted with (d) – deterioration or destruction of

5 Chapter III.1.2 para.11

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breeding sites or resting places; in domestic law terms, the difference is between the absolute requirement or strict liability with regard to (d) as opposed to the qualified requirement or liability with regard to (b). This distinction is replicated in the transposing Regulations.6

“Deliberate” is not defined but the Commission suggests that it means: “actions by a person who knows, in the light of the relevant legislation that applies to the species involved and the general information delivered to the public, that his action will most likely lead to an offence against a species but intends this offence of, if not, consciously accepts the foreseeable results of his action.”7

(o) “Disturbance” is not defined. The guidance deals with it as follows: 8

(37) Disturbance (e.g. by noise, source of light) does not necessarily directly affect the physical integrity of a species but can nevertheless have an indirect negative effect on the species (e.g. by forcing them to use lots of energy to flee; bats, for example, when disturbed during hibernation, heat up as a consequence and take flight, so are less likely to survive the winter due to high loss of energy resources). The intensity, duration and frequency of repetition of disturbances are important parameters when assessing their impact on a species. Different species will have different sensitivities or reactions to the same type of disturbance, which has to be taken into account in any meaningful protection system. Factors causing disturbance for one species might not create disturbance for another. Also, the sensitivity of a single species might be different depending on the season or on certain periods in its life cycle (e.g. breeding period). Article 12(1)(b) takes into

6 Now the 2017 Regulations 7 Chapter II.3.1 para. 33 8 Chapter II.3.2a paras. 37-39

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account this possibility by stressing that disturbances should be prohibited particularly during the sensitive periods of breeding, rearing, hibernation and migration. Again, a species-by-species approach is needed to determine in detail the meaning of “disturbance”.

(38) The disturbance under Article 12(1)(b) must be deliberate (see chapter II.3.1) and not accidental. On the other hand, while “disturbance” under Article 6(2) must be significant, this is not the case in Article 12(1), where the legislator did not explicitly add this qualification. This does not exclude, however, some room for manoeuvre in determining what can be described as disturbance. It would also seem logical that for disturbance of a protected species to occur a certain negative impact likely to be detrimental must be involved.

(39) In order to assess a disturbance, consideration must be given to its effect on the conservation status of the species at population level and biogeographic level in a Member State (see also chapter III.2.3.a on “Scale of assessment”). For instance, any disturbing activity that affects the survival chances, the breeding success or the reproductive ability of a protected species or leads to a reduction in the occupied area should be regarded as a “disturbance” in terms of Article 12. On the other hand, sporadic disturbances without any likely negative impact on the species, such as for example scaring away a wolf from entering a sheep enclosure in order to prevent damage, should not be considered as disturbance under Article 12. Once again, it has to be stressed that the case-by-case approach means that the competent authorities will have to reflect carefully on the level of disturbance to be considered harmful, taking into account the specific characteristics of the species concerned and the situation, as explained above.

It is not entirely clear from the guidance, or from the Directive, what constitutes disturbance for these purposes. The guidance was examined and discussed in Morge (FC) v Hampshire County Council [2011] UKSC 2 but no clear

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conclusion was reached - the Supreme Court saying that it was a matter of fact and degree in each case.

(p) “Disturbance” is not defined. 9 The guidance deals with it as follows:

Art. 12(4) deals with the “incidental capture or killing” of Annex IV species. Member States are under monitoring duties with a view to considering further measures to ensure that such activities do not have a significant adverse effect on Annex 4a species. The guidance gives as an example of incidental killing bat road and wind turbine deaths.10 Whilst this is only guidance, the conclusion seems entirely logical and, if right, would mean that deaths of individual bats or other Annex IV species from the operation of the new road would not count as “disturbance”.

2. The Conservation of Habitats and Species Regulations 2017

2.1 These are the current transposing instrument for Wales and England. They consolidate earlier Regulations dating originally from 1994, but substantially amended in 2007 as a result of a decision of the European Court to the effect that they had not properly transposed the Directive because a former system in place under the old Regulations to protect dwellings from the rigours of the requirements for bats based on the concept of incidental harm was incompatible with the provisions of Arts. 12 and 16

2.2 By Reg 9(1), the Welsh Ministers and Natural Resources Wales are required to exercise their functions under the enactments relating to nature conservation so as to secure compliance with the requirements of the Habitats Directive and by Reg 9(3), the Welsh Ministers and any

9 Chapter II.3.2a paras. 37-39 10 Chapter II.3.6 para. 83

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person holding a public office must, as competent authority, have regard to the requirements of the Directive in the exercise of any of their functions, so far as they may be affected by the exercise of those functions. 11 The Regulation contains a non-exhaustive list of relevant enactments including s.28G Wildlife and Countryside Act 1981, NERC Act 2006 and these Regulations. The Regulations do not expressly list the recent Welsh environmental statutes but these would be included.

2.3 Protection of species is dealt with in Part 3.

2.4 Reg 43 creates criminal offences reflecting the provisions of Art. 12 of the Directive. The offence of disturbance under Reg 43(1)(b) imposes qualified liability because such disturbance must be caused “deliberately”, whereas the offence under para (1)(d) of damaging or destroying a breeding site or resting place is an offence of strict liability.

2.5 Para (2) provides:

(2) For the purposes of paragraph (1)(b), disturbance of animals includes in particular any disturbance which is likely— (a) to impair their ability— (i) to survive, to breed or reproduce, or to rear or nurture their young, or (ii) in the case of animals of a hibernating or migratory species, to hibernate or migrate; or (b) to affect significantly the local distribution or abundance of the species to which they belong.

This provision is not an exclusive definition of disturbance.

2.6 No criminal offence is committed if relevant activities have been authorised by derogation licence under Reg 55. This Regulation mirrors Art. 16.

2.7 In Morge, the Supreme Court considered:

11 As defined in Reg.7

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(a) the meaning of “disturbance” in the Directive and the 1994 Regulations (which were the same as the current ones so far as relevant), and;

(b) the extent of the duty upon Local Planning Authorities to have regard to the provisions of the Directive and Regulations.

2.8 Lord Brown gave the leading judgment and dealt with disturbance at paras. 2-25 (attached). As noted above, the Court declined to attempt a definition of the term and held that it was to be interpreted and applied on a case by case basis. The Court recognised that there was a spectrum, declining to adopt either a de minimis approach or to hold that disturbance could only occur when there would be harm to the conservation status of the species. The matter is one of judgment for the decision maker – ultimately the enforcing or licensing body which, in Wales, is NRW.

2.9 The second point in Morge concerned the role of the LPA when granting planning permission, in the light of the obligation to have regard to the Habitats Directive. It had previously been held in Woolley v Cheshire East Borough Council that the Local Planning Authority could only grant planning permission if it was certain that a derogation licence would definitely be granted. The Supreme Court rejected that approach. They held that there was no reason why planning permission should be withheld unless the LPA was satisfied:

(a) that the proposed development would be likely to offend Art. 12; and

(b) that it was unlikely to be licensed as a derogation.

2.10 Although there is no specific duty in the Highways Act 1980 akin to the duty in the Town and Country Planning legislation, Regs 9(1) and 9(3) have the same effect. Therefore the Inspectors and the Welsh Ministers, in deciding about the Orders, should apply the principles laid down in Morge.

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2.11 With regard to highly mobile species such as bats, it is clearly a rather complicated question whether or not a road scheme would constitute disturbance. Interestingly, the development in question in Morge was a guided busway, the route of which ran through regenerated vegetation on an old railway line, which included a known flight path for pipistrelles. There were no roosts on the site, but it contained foraging areas. Some form of mitigation was proposed, but it is not clear from the judgment what it was. English Nature initially objected, but, followed a further report, withdrew their objection and apparently accepted that no disturbance would be caused, notwithstanding that it appears to have been accepted in the Court of Appeal that some bats would be killed by colliding with buses from time to time.

2.12 Reg 53 sets up a system for monitoring the incidental capture or killing of relevant species, as required by the Directive.

3. The M4 CaN and Objections from GWT

3.1 In this case, Professor Altringham’s real concern appears to be with the construction and operational phases, rather than landtake.

3.2 Landtake will involve the destruction of a number of tree and building roosts and Mr Green has given very clear evidence to the effect that there will be effective mitigation/compensation by provision of artificial roosts at ratios of 2/3:1. He has also explained that this is a tried and tested approach, approved by NRW and NE. In this regard, there is no reason to suppose that derogation licences would not be forthcoming under Reg 55(2)(e) in the event of a favourable determination on the Orders, as the Ministers will have satisfied themselves as to need, public interest and absence of satisfactory alternatives. For reasons set out above, GWT’s submission that there must be certainty such that there is no room for reasonable scientific doubt that 90% of bats which would otherwise have used the removed roosts would use the new roosts is misconceived. In addition to all the reasons set out in Section 1 of this Note which demonstrate that GWT’s submission is wrong, such a position is

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inconsistent with the Morge approach of professional judgment applied on a spectrum and the advice to the Court from DEFRA that the judgment as to whether or not activities constitute disturbance will vary depending on the conservation status of the particular species under consideration.12 NRW do not suggest that a licence would be unlikely to be granted.13

12 Lord Brown’s judgment, para.22 13 ID/104 SoCG on Bats, paras 2.1.11 and 2.1.24

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