Clive Jones

WRITTEN REPRESENTATION

HIGHWAYS ENGLAND'S RESPONSE

ADDITIONAL COMMENTS FROM CLIVE JONES

1. INTRODUCTION

1.0 Position Statement on behalf of Clive Jones On Behalf Of Wokingham Liberal Democrats. In response to Examining Authority Question at Agenda Item 7 f ii of the Agenda for the Compulsory Acquisition Hearing

1.1 First of all, I would like to thank you all for the courtesies that you extended to the interested parties and those who spoke at the public meetings and thank the staff and advisors of Highways England for the professional and courteous way that they dealt with our questions.

1.2 The following summarises the comments that I made to the open Meeting in Reading on the 16th November and comments made at the issue specific hearings at the Radison Blu hotel in Hayes on 17th and 18th November.

1.3 Some comments also relate to the accompanied site visits on 10th November when we visited 10 different sites between junctions 10 and 11.

1.4 In summary, we do not agree that Highways England noise mitigation, air quality or road safety plans as they currently are, go far enough for the stretch of motorway between junctions 10 and 11.

1.5 The small measures proposed by Highways England will only help a few hundred residents in Emmbrook, Winnersh, Sindlesham, Lower Earley and Shinfield.

1.6 This is very disappointing because there are over 10,000 houses in the Lower Earley area alone and possibly nearly 30,000 people living here. When you add the residents of Winnersh, Emmbrook, Shinfield, Sindlesham and Three Mile Cross this number will move towards 12,000 houses and 35,000 residents. These residents get little or nothing from the proposals by Highways England.

Highways England Comment

1.6.1 The points raised in this summary are addressed by Highways England in response to the detailed comments below, which also take account of the additional comments provided by Mr Jones in his email of 4th December 2015 (contained in Appendix B).

My detailed comments are set out below:

2. ACCOMPANIED SITE VISITS

2.0 I was pleased that Highways England added some sites to the visit that I suggested you looked at in my earlier representation.

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2.1 During the accompanied site visits on the 10th November we visited 10 different sites. As we drove between the sites I was able to point out to you where earth bunding and acoustic fencing could go.

Highways England Comment

2.1.1 One of the design principles for the Scheme is to minimise land-take, in order to reduce the adverse effects of the Scheme on landowners and adjoining land users. This results in a preference for mitigation measures which can be accommodated within existing highway land, such as noise barriers, as opposed to measures that require land, whether through compulsory purchase or third party agreements, such as earth contouring for noise bunds.

2.2 Highways England have asserted that there will also be some noise from local feeder roads such as Lower Earley Way and Rushey Way and that this contributes to the noise and air quality levels. However on the site visits that we undertook we could distinctly hear the sound of motorway noise.

Highways England Comment

2.2.1 Highways England considers that noise from roads other than the M4 will contribute to the prevailing noise climate at some locations to a greater or lesser extent, depending on distance from the motorway, the closeness of other busy roads and shielding effects. This does not mean that Highways England does not accept that the M4 motorway contributes as a noise source at many of these locations.

3. NOISE

EARTH BUNDING AND ACOUSTIC FENCING

LOWER EARLEY

3.0 2.1.1.1 For Earth bunding there is generally land south of Lower Earley Way where the bunds can go. There is also enough space for Lorries delivering the earth to turn around without clogging up Lower Earley Way. The bunds will be able to start at Eden Way in Winnersh and continue alongside the M4 until a few hundred metres before Beeston Way. At the end of the bund and Acoustic fence could be erected by the side of the M4 up to the roundabouts at Beeston Way.

3.1 2.1.1.2 From here acoustic fencing can continue alongside the north side of the M4 continuing to the Black Boy roundabout.

Highways England Comment

3.1.1 This proposal would result in 3.6km of new earth bunds to the eastbound (northern) side of the M4 between Beeston Way in Lower Earley and Eden Way in Winnersh. Highways England considers that such a feature is not viable for the reasons set out below.

3.1.2 The effectiveness of acoustic barriers such as noise fences and earth bunds is greatest immediately behind the barrier and decreases with distance from the barrier. Any bund between Lower Earley and Winnersh along the eastbound carriageway would lie at distances of several hundred metres from residential

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properties. Apart from the very eastern and western ends of the bund, where housing is nearby, such a bund would not noticeably benefit residential areas. In comparison, the enhanced noise mitigation proposed by Highways England in this location (new noise barrier to Lower Earley/new and replacement barriers to Winnersh, on the Scheme boundary) will provide significant noise reductions to properties close to the Scheme, with lower noise reductions to properties further away.

3.1.3 The topography is not suitable for constructing an earth bund as much of the M4, especially east of the River Loddon, is on embankment. It would be necessary to construct a “false cutting” to raise the land sufficiently to create a bund. This would require considerably more aggregate than a bund where the motorway is at grade or in cutting. This would clearly increase the construction costs and associated haulage movements. Therefore, the enhanced noise mitigation proposed by Highways England will provide new and replacement noise fences rather than bunds.

3.1.4 Further, the construction of an earth bund along the eastbound carriageway would require extensive removal of mature tree cover, which currently provides valuable screening.

3.1.5 The mitigation proposed for the Scheme, to provide low noise surfacing across all lanes, will mitigate noise at source, benefiting wide areas to the north and south of the M4. Two short sections of new noise barrier are also proposed on the eastbound and westbound carriageway at Mill Lane Underbridge, specifically to provide additional mitigation for properties close to the motorway at this location.

3.1.6 As reported in Chapter 12 of the ES (Application Document Reference 6-1, APP- 152), the magnitude of impact for the Scheme on ambient noise is minor beneficial in the short term and negligible in the long term, with the vast majority of the Scheme corridor experiencing negligible or minor reductions in noise levels with the Scheme in operation. This includes the Lower Earley area as shown on sheets 3 to 5 of drawings 12.4 and 12.5 (Application Document Reference 6.2 figures 12.4 and 12.5, APP-266 and APP-270).

3.1.7 However, it is noted in paragraph 12.4.112 of the ES (Application Document Reference 6-1, APP-152) that there is potential to improve further the noise climate within the Scheme corridor. A qualitative appraisal of an enhanced noise mitigation study to achieve this is provided in Appendix 12.5 of the ES (Application Document Reference 6-3, APP-351). This enhanced noise mitigation study comprises the possible provision of additional noise barriers and the possible replacement of some existing noise barriers with higher noise barriers.

3.1.8 The results of the enhanced noise mitigation study are provided with the Deadline V submission. The confirmed barrier provision in the Lower Earley area is detailed within Appendix E of the Enhanced Noise Mitigation Study Report (Ref 514451-MUH-00-ZZ-RP-EN-400158). Sheet 4 is relevant to the Lower Earley area. A new 2.5 metre high noise barrier is proposed to provide noise mitigation to Lower Earley.

3.2 2.1.1.3 Along the bunding we would like to see extensive planting of tree and bushes to help improve the air quality. This would greatly improve the visual impact from both sides of the bunds.

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Highways England Comment

3.2.1 Highways England recognises that extensive planting of trees and shrubs could potentially offer some benefit to air quality, as set out in Forestry Commission research http://www.forestry.gov.uk/fr/urgc-7edhqh. However, it should be noted that the effects of vegetation on nitrogen dioxide, the principal pollutant gas emitted by vehicles, are less well established. As nitrogen dioxide is generally the pollutant with higher concentrations along highways routes, vegetation may have less utility, compared to urban centres where particulate concentrations may be higher. For example the highest predicted annual average concentration of PM10 with the Scheme was 26.3 µg/m3 against an annual average air quality objective value of 40 µg/m3. Consequently, no such mitigation is required for the Scheme.

3.2.2 Additionally, the existing M4 along this section is mostly on an embankment going through an area with a limited number of residential properties which have a potential view to the Scheme. Where the motorway is close to residential properties, the existing embankments are vegetated and this vegetation would for the most part be retained as part of the Scheme. On this basis, Highways England considers that the scale of the earth bunds and associated additional loss of vegetation would outweigh any perceived visual impact benefit which may result.

3.3 2.1.1.4 The above bunding and acoustic fencing will be a major benefit to the 30,000 people who live in Lower Earley.

Highways England Comment

3.3.1 Drawing 12.4 Sheets 3 to 5 in the ES (Application Document Number 6-2, APP- 266) show that the mitigation proposals for the Scheme will reduce ambient noise levels in comparison with the Do Minimum for the opening year (2022).

3.3.2 No evidence has been supplied to support the contention that an earth bund and additional noise fencing will provide a major benefit to the 30,000 people living in Lower Earley. The way a noise fence (or bund) attenuates noise is complex, and it is not just dependent on the height of the barrier. The reduction in noise level at a receptor depends on:

 The height of the barrier;

 The distance from the motorway to the barrier;

 The distance from the barrier to the receptor; and

 The ground heights at the motorway, at the barrier and at the receptor.

3.3.3 The consequence of this is that, whilst receptors close to the motorway will benefit from significant noise reductions as a result of a barrier, receptors further away and at different ground heights will experience negligible benefit.

3.3.4 As stated in the response above, the results of the enhanced noise mitigation study have been provided as part of the Deadline V submission. The confirmed barrier provision in the Lower Earley area is detailed within Appendix E of the Enhanced Noise Mitigation Study Report (Ref 514451-MUH-00-ZZ-RP-EN- 400158). Sheet 4 is relevant to the Lower Earley area. A new 2.5 metre high noise barrier is proposed to provide noise mitigation to Lower Earley.

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3.4 2.1.1.5 According to the drawing below (Highways England, Environment Statement) the scheme currently shows only a small improvement in noise levels in Lower Earley in 2022.

3.5 2.1.1.6 Fig 12.4 – Key : http://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR010019/2.%20Post- Submission/Application%20Documents/Environmental%20Statement/6-2-ES-Figures_12-4- Noise_Cover-and-Keyplan.pdf

3.6 2.1.1.7 Fig 12.4 – Drawings : http://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR010019/2.%20Post- Submission/Application%20Documents/Environmental%20Statement/6-2-ES-Figures_12-4- Noise_Sht01-06.pdf

Highways England Comment

3.6.1 Drawing 12.4 of the ES (Application Document Number 6-2, APP-265 and APP- 266) shows minor noise reductions across Lower Earley on Scheme opening (2022). In the short term (i.e. on Scheme opening), a minor noise reduction is defined as 1 to 3 dB reduction.

3.6.2 To put this in context, noise is presented on a logarithmic scale. A change in 1 dB is considered to be perceptible to humans while a change of 3 dB is similar to a doubling (or halving) of the traffic flow (assuming speed and percentage of heavy goods vehicles remained the same).

3.7 2.1.1.8 The drawing below shows virtually no change by the time we get to 2037.

3.8 2.1.1.9 Fig 12.5 – Key : http://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR010019/2.%20Post- Submission/Application%20Documents/Environmental%20Statement/6-2-ES-Figures_12-6- Noise_Cover-and-Keyplan.pdf

3.9 2.1.1.10 Fig 12.5 – Drawings : http://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR010019/2.%20Post- Submission/Application%20Documents/Environmental%20Statement/6-2-ES-Figures_12-6- Noise_Sht01-06.pdf

Highways England Comment

3.9.1 Drawing 12.5 of the ES (Application Document Number 6-2, APP-269 and APP- 270) shows negligible noise reductions across Lower Earley in the long term. Over such a period of time, a negligible noise reduction is defined as 0 to 3 dB. However, the noise reductions shown in Drawing 12.5 are very similar to those shown in Drawing 12.4 of the ES (Application Document Number 6-2, APP-265 and APP-266), with noise reductions of 1 to 3 dB. Thus, in the long term, with the Scheme in operation, the noise reductions evident on Scheme opening will be largely maintained.

3.10 2.1.1.11 It is our contention that the noise and air quality levels should be returned to the levels of the 1980’s and 90’s when most of the houses in this area were built. By Highways England’s own admission traffic levels have increased by 2.7 times since 1985. (Traffic levels across the whole country that is) It might be fair to say that the increase has been greater in the Thames Valley area than the average.

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3.11 2.1.1.12 Producing a scheme that has zero effect on the current noise and air quality levels is not acceptable to the many thousands of people who live along this stretch of the M4.

Highways England Comment

3.11.1 A traffic flow increase of 2.7 times results in a noise level increase of approximately 4 dB (assuming speed and the percentage of heavy goods vehicles remains the same). The operation of the Scheme partially eliminates this 4 dB increase (Drawing 12.4 of the ES (Application Document Number 6-2, APP-265 and APP-266) and Drawing 12.5 of the ES (Application Document Number 6-2, APP-269 and APP-270)).

3.11.2 The noise and vibration assessment, as presented in Chapter 12 of the ES (Application Document Reference 6-1, APP-152), has been carried out according to the requirements of Design Manual for Roads and Bridges (“DMRB”) and the Calculation of Road Traffic Noise, as required by paragraph 5.191 of the NN NPS. The DMRB approach is based on comparisons of noise levels with and without the Scheme in operation for the opening year and for the year 15 years after opening. DMRB does not require comparisons with historical noise levels. Nor is the Scheme required to decrease noise levels to those experienced 25-30 years ago.

3.11.3 As stated above, the results of the enhanced noise mitigation study have been submitted with the Deadline V submission. The confirmed barrier provision in the Lower Earley area is detailed within Appendix E of the Enhanced Noise Mitigation Study Report (Ref 514451-MUH-00-ZZ-RP-EN-400158). Sheet 4 is relevant to the Lower Earley area. A new 2.5 metre high noise barrier is proposed to provide noise mitigation to Lower Earley. With this enhanced mitigation, it is not the case that the Scheme will have zero effect on the current noise levels. Noticeable noise reductions will be provided to many residential properties in Lower Earley, both in the short term (on Scheme opening) and in the long term.

3.12 2.1.2 ROADS THAT SUFFER PARTICULARLY BADLY FROM NOISE NUISANCE IN LOWER EARLEY

3.13 2.1.2.1 You asked me to let you know which roads were badly affected by noise in Lower Earley. I have detailed below those that are the worst affected. Generally most of the 10,000 houses in Lower Earley will hear the traffic from the M4 and it has only got worse since the houses were built in the 1980’s and 90’s.

3.14 In Hillside ward, Uffcott Close, Chippenham Close, Dove Close, Catcliffe Way, Beighton Close, Beauchief Close, Goldthorpe Gardens,, Worrall Way, Tickhill Close, Notton Way, Maltby Way, Tinsley Close, Felthorpe Close, Heacham Close, Anston Close, Finbeck Way, Tilney Way, Lutton Close, Thurnscoe Close, Fakenham Close, Hillmanton, Wickford Way Tiptree Close and Steeple Walk.

3.15 2.1.2.3 Other roads in the area of Rosemary Avenue and roads off Chalfont Way will also suffer badly when the wind is in the wrong direction!

3.16 2.1.2.4 In Hawkedon ward, Bradmore Way, Rainworth Close, Farnsfield Close, Pavenham Close, Selsey Way, Cutbush Lane, Cutbush Close, Redhouse Close, Colmworth Close, Odell Close, Chatton Close, Bosham Close, Faygate Way, Warnsham Close, Sharpethorpe Close, Berstead Close, Watersfield Close, Rustington Close, Moorhen Drive, Privet Close, Jay Close, Conygree Close, Chatteris Way, Turnbridge Close, Pasture Close, Ebborn Square,

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Irvine Way, Stonea Close, Wimblington Drive, Manea Close, Bottisham Close, Wild Close, Harlton Close, Gregory Close Bassett Close, Merrifiled Close, Witcham Close, Littlington Close, Porter Close Soham Close, Waring Close, Ledran Close, Firmstone Close, Kensington Close, Lidstone Close Bourne Close, Doddington Close, Fordham Way, Chittering Close, Burwell Close, Adwell Drive, Finstock Close, Fringford Close, Woodbine Close, Paddick drive, Chesterment Way, Barncroft drive, Wyatt Crescent, Gabriels Square, Simmonds Crescent, Broadmead, Kitwood Drive, Yoreham Close, Hambledon Close, Weild Court, Wickham Road, Barholm Close, Edenham Close, Swanmore Close, Easington Drive, Forndon Close, Hollym Close, Skeffling Close, Settrington Close, Flamborough path and Close, Burniston Close, Mill Lane, welwick Close, Thistleton Way, Kelton Close, Ridlington Close.

3.17 2.1.2.5 Other roads in the area of Hawkedon Way, Measham Way, Cannock Way, Bridport Close, Chilcombe Way, Maiden Place, Swepstone Close will also suffer when the wind is in the wrong direction.

3.18 2.1.2.6 In Maiden Erlegh ward, Bythorn Close, Tinwall Close, Sawtry Close, Huntington Close, Thorney Close, Stilton Close, Ramsey Close, Whitestone Close, Northam Close, Ilfracombe Way, Holsworthy Close, Plymton Close, Toseland Way, Formby Close, Rhodes Close.

3.19 2.1.2.7 Other roads in the area such as those off Skelmerdale Way, Markby Way and Sellafield Way will also suffer badly when the wind is in the wrong direction!

Highways England Comment

3.19.1 Highways England notes the roads identified in this representation. The assessment of the noise effects of the Scheme has included all residential properties in Lower Earley within 600 metres of the Scheme (as required by DMRB). Employment of this distance will capture all significant effects of the Scheme. Additionally, it is recognized that the noise prediction methodology becomes less accurate at distances greater than this.

READINGS FROM OUR OWN NOISE METRE.

3.20 We hired a noise metre to check some measurements ourselves. Attached is a table showing the measured noise levels (LAeq) at 40 specified locations over 3 days in Lower Earley. Not calculated values, but a snapshot of the reality experienced by residents in a particular location on a particular day at a particular time.

3.21 We have plotted dB values at each specified location onto a road map of the area, using average values where readings were taken on different days at the same location. We will forward to you under separate cover.

Highways England Comment

3.21.1 Highways England has been provided with the measurement data (both in this submission and an email of 4th December 2015, Detailed in Appendix A and B to this response). Highways England is considering the data provided.

SHINFIELD & THREE MILE CROSS

3.22 On the South side of the M4 there should be Acoustic fencing in the area of Minosa Way, Chrysanthemum Drive and Monarch Way. Protecting residents form Shinfield. Further westwards nearer to Junction 11 there should be acoustic fencing on the south side of the M4

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extending 200 metres past the junction towards junction 12. This will protect the residents of Three Mile Cross.

EMMBROOK & WINNERSH

3.23 In Winnersh there is space for earth bunding on the South side of the M4 from Reading Road eastwards to junction 10. There is also space for acoustic fencing to go on the north side of the M4 from Woodward close to junction 10 and from King Street to Reading Road.

Highways England Comment

3.23.1 Highways England confirms that Shinfield, Emmbrook and Winnersh are included in the enhanced noise mitigation study. Three Mile Cross is a significant distance from the M4 and is subject to noise from traffic on the A33. Both of these factors would reduce any benefits of providing noise barriers to the M4, and therefore Three Mile Cross has not been included in the enhanced mitigation study.

SINDLESHAM

3.24 In Sindlesham acoustic fencing can go on the south side of the M4 behind St Marys Road, Mayfield and St Catherines Close.

3.25 We have generally suggested that we would like acoustic fences which were 3m in height. However it was drawn to our attention by the representative from Slough Borough Council that there was evidence from Holland that fences that are 6m in height are significantly more effective in terms of reducing noise and improving air quality. If this evidence proves to be correct could we have 6m high acoustic fences in our area?

Highways England Comment

3.25.1 Highways England confirms that Sindlesham is included in the enhanced noise mitigation study.

3.25.2 Highways England does not support the provision of 6m high acoustic fences. Such fences would require special consideration in their design to accommodate wind loading and would potentially have a significant impact on landscape quality and views.

COSTS OF EARTH BUNDING & ACOUSTIC FENCING

3.26 These measures to build earth bunds and acoustic fences between junctions 10 and 11 could be considered expensive. In the hearing I suggested that the fencing could cost in the region of £3m and the bunding perhaps the same or more. This was not challenged by Highways England. The difference that it could make to the lives of 35,000 could be immense.

Highways England Comment

3.26.1 As stated in the response above, the results of the enhanced noise mitigation study are provided with the Deadline V submission. The confirmed barrier provision in the Lower Earley area is detailed within Appendix E of the Enhanced Noise Mitigation Study Report (Ref 514451-MUH-00-ZZ-RP-EN-400158). Sheet 4 is relevant to the Lower Earley area. A new 2.5 metre high noise barrier is proposed to provide noise mitigation to Lower Earley. As previously addressed in

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this response, this assessment work is based on the provision of noise barriers rather than bunds.

3.26.2 Highways England does not agree with the cost estimate provided, which would need to be subject to detailed assessment of the required area, fill requirements and haul routes as detailed in paragraph 3.1.3 above), and notes that no basis for the costing has been provided, nor has any evidence been provided to show that earth bunds and/or additional fencing would provide any significant mitigation over and above that provided by the enhanced noise mitigation being proposed by Highways England for the Scheme.

LOW NOISE SURFACES

3.27 We are really pleased that Highways England has decided to put “low noise” tarmac on all four lanes of each carriageway. They have asserted that this will give an average noise reduction of about 3 decibels across the entire stretch of motorway over the first ten years of the scheme. It will be greater at the beginning, perhaps by as much as 4-6 decibels. If the surface was not replaced for 15 years would all the benefit of the “low noise” tarmac disappear?

Highways England Comment

3.27.1 Research has indicated that new low noise surfaces provide on average between 4 and 6 dB(A) benefit over tested hot road asphalt (“HRA”) surfaces. In spite of the better acoustic durability of the HRA surfaces, the research concluded that low noise surfaces still outperformed the HRA surfaces by 1 to 3 dB(A) after 10 years (TRL Report PPR485: The Performance of Quieter Surfaces Over Time).

3.27.2 The -3.5 dB correction for the low noise surface used in the noise assessment is a requirement of applying the Design Manual for Roads and Bridges (“DMRB”) process (DMRB, Volume 11, Section 3, Part 7, paragraph A4.29).

3.27.3 Paragraph 6.22 of HD 37/99 ((DMRB, Volume 2 Section 5 Part 2) states that “Satisfactory working lives between 7 to 15 years may be expected for thin wearing course systems – depending on their thickness, void content, the level of trafficking and the condition of the underlying pavement”.

3.27.4 Lane 1 and 2, which are located closest to properties, attract a greater level of traffic, as they are the lanes which take the majority of heavy vehicles. Heavy vehicles impose a disproportionate level of wear on the pavement. Therefore, it is expected that, with all other criteria being equal, Lane 1 and 2 will deteriorate at a faster rate than the other lanes and will require resurfacing at more frequent intervals, in order to preserve their low noise qualities.

3.27.5 The surfacing will be monitored regularly following installation using a variety of tests (e.g. skid resistance) and will be maintained to a high standard. Replacement will be scheduled once the performance of the surface is no longer satisfactory, in accordance with Highways England's standard procedures and as required under its Strategic Licence.

3.27.6 As the level of noise reduction drops throughout the life of low noise surfacing, there is little data available assessing the performance of the surface after 15 years, as this is outside its satisfactory life of the pavement and in nearly all circumstances the surface would be replaced before the 15 year point.

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3.28 These values might impress the Minister, but will be utterly meaningless to local residents who want to know what will happen in their own locations.

Highways England Comment

3.28.1 Local residents can view the drawings provided in the ES and referenced in this representation, which show the noise level changes throughout the Scheme corridor resulting from the operation of the Scheme. The drawings will allow local residents to identify their own property and to determine the noise changes. As a rule of thumb, given the logarithmic distribution of noise, a reduction in noise levels of 1 dB is perceptible and a reduction by 3 dB is equivalent to a halving of traffic flow (subject to the speed and the percentage of Heavy Goods Vehicles being unchanged).

4. FLOOD RISK

4.0 Along parts of the motorway there are drainage ditches. We would like clarification of whether new drainage ditches will be built between junctions 10-11. If they are we assume they will build to the correct depths to take all surface water away quickly. Could there be confirmation from Highways England that any ditches will be maintained correctly by them following the completion of the scheme.

Highways England Comment

4.0.1 Highways England confirms that new drainage ditches are considered unlikely to be required between junctions 10 and 11, with the potential exception of local connections to the five new Emergency Refuge Areas which are proposed between junctions 10 and 11.

4.0.2 No works are to be undertaken within the floodplain (which is defined by the 1 in 100 year flood event plus an allowance for climate change), so no floodplain compensation storage or any associated new ditches to provide hydraulic links are required. Furthermore, the Scheme drainage strategy utilises the existing highway drainage infrastructure and outfalls. As set out in paragraph 1.3.17 of the Drainage Strategy Report (Application Document Reference 7-5, APP 123), any enhancement or remediation measures which are required to ensure that the existing drainage system functions correctly during storm events will be completed during the construction phase of the Scheme.

4.0.3 Should any new ditches be required, Highways England confirms that these features will be subject to detailed design and approvals sought from relevant authorities as appropriate. Highways England also confirms that all components of the drainage systems will be subject to appropriate maintenance during the operational phase of the Scheme, as detailed in paragraph 1.3.17 of the Drainage Strategy Report (Application Document Reference 7-5, APP 123). The provision of surface and foul water drainage for the Scheme is secured pursuant to requirement 14 at Schedule 2 to the DCO.

5. SPEED RESTRICTIONS

5.0 We have been told that if traffic travels at 55mph or thereabouts. The noise levels are lower and the air quality levels are better. With this in mind I would ask Highways England if there could be a speed reduction to 55 mph permanently between junctions 10 and 11 where there is dense housing.

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5.1 The answer again from Highways England may be that they don’t have to do this. However if you were to recommend this, it would be a huge benefit for the residents alongside the M4 between junctions 10-11. It could create a precedent to be followed in other densely populated areas near motorways.

Highways England Comment

5.1.1 It is not necessarily the case that reduction in speed limits leads to improvements in air quality. Reducing speed limits during periods of the day on the motorway could, in some circumstances, help to improve noise and air quality. This is as a result of reductions in flows along the motorway or more optimal driving conditions. The Scheme will use speed control to manage the traffic flows as part of its operation. However, where a blanket speed control is applied there is the potential for wider scale changes in traffic movements: as the motorway has a lower capacity, there are risks of increased levels of congestion, less journey time certainty and as a result it has the potential to lead to traffic reassigning to alternative routes.

5.1.2 The Scheme is not predicted to result in a significant air quality effect nor affect the UK's reported ability to comply with the Air Quality Directive and therefore the use of speed restrictions are not required for air quality. The impacts of the Scheme on ambient noise is minor beneficial in the short term and negligible in the long term. Accordingly, the imposition of a speed restriction is not required.

6. ROAD SAFETY

6.0 We note that Highways England does not want road safety to be any worse than it currently is and that they expect an 8% improvement from the scheme. We note also that at the moment 21% of all traffic is on motorways and only 5% of fatal injuries and 5% of injuries happen on the motorway network. Highways England stated they expect that 50% of breakdowns will be able to get to a recovery area. These are being placed every 1.85 miles. I would like to know what evidence they have for saying this.

Highways England Comment

6.0.1 Calculations from the hazard analysis work show that the total score given in relation to the period after construction of the Scheme represents a reduction of risk of approximately 18% in comparison to the safety baseline (with no Motorway Incident Detection and Automatic Signalling ("MIDAS") queue protection). Even when the additional safety benefit of 10% above the baseline with MIDAS is taken into account, the Scheme would still expect to see a reduction in risk of approximately 8% and hence it would meet the required safety objective (Ref: paragraph 5.2.78 of the Planning Statement, Application Document Reference 7.1, APP-089).

6.0.2 The following evidence regarding the motorway flow, casualty rates and breakdown percentage able to get to a refuge area was provided by Highways England as part of its submission at Deadline IV (APP 4-002):

 Motorway Flow and Casualty Rates - Appendix B - Reported Road Casualties Great Britain: 2014 Annual Report - Moving Britain Ahead (September 2015); and

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 Percentage of Breakdowns able to get to refuges areas - Appendix C (Evaluation of the Provision of Refuge Areas (Ref: MMFD-ERA-030-Final Issue-June 2012) and Appendix D - 2001 Report ‘Safe Haven Layby Frequency and Specification’.

6.1 I was pleased to hear that there would be 130 CCTV cameras on the motorway and that they were infra-red so would be used at night. However I was very concerned to find when I questioned Highways England that some of CCTV screens may not be looked at for possibly up to two minutes. During this time there could be a breakdown which may turn into a pile up which may not be noticed by the CCTV operator for some time.

6.2 I would like to see a system for monitoring which meant that each CCTV screen/camera was looked at every 30 seconds and if it wasn’t a series of flashing lights would alert the operator. I am sure there is technology available to do this. It would need 12 operators 24/7 to do this so probably 50 operators in total. If I remember correctly the response form Highways England was it would cost a great deal to have enough operators to be able to do this. I don’t agree with this assertion from Highways England. The cost would be £2m to £3m a year and would make the motorway significantly safer than it is planned at the moment.

Highways England Comment

6.2.1 There will be full CCTV coverage of all parts of the Scheme. Operators will work within the Regional Control Centre ("RCC"), which is always staffed. However, this does not mean that all parts of the network are continually monitored. The main purpose of the CCTV system is to locate an incident once it has occurred in order to assist the emergency response and to enable protection of the vehicle. As is usual (and is currently the case on the strategic road network), the RCC will be informed of an incident through MIDAS, by a 999 call, a call from an Emergency Roadside Telephone by a vehicle occupant or a Traffic Officer call.

6.2.2 MIDAS typically reacts within minutes to queues forming behind a stopped vehicle and because MIDAS provides the RCC Operator with information identifying the queue location, the Operator can verify quickly the exact location of the stopped vehicle through CCTV (again, typically within minutes).

6.2.3 Continuous monitoring of CCTV cameras is not considered to be proportionate, or necessary, to achieve the Scheme’s safety objective, and without it the Scheme is expected to result in an 8% reduction in risk.

6.2.4 The level of resource required to monitor the entire Scheme every 30 seconds would be significant. As the Scheme is already expected to deliver a reduction in risk of 8%, Highways England does not consider that additional and substantial increase in operational cost is either necessary or justified.

6.3 When traffic flow is light and fast would it be possible to close the left hand lane to traffic, restoring the hard shoulder for a period of a few hours until traffic flows increased. This could be particularly beneficial during the night when the motorway is dark.

Highways England Comment

6.3.1 The closure of Lane 1 to traffic each night would introduce a complex and resource intensive operating system to “open” and “close” the hard shoulder, which would increase monitoring requirements (due to the need to check the complete extent of a section of hardshoulder with cameras before opening and

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closing the hardshoulder each night), and could potentially prove to be confusing for road users.

6.3.2 Reverting to what would in effect be a Dynamic Hard Shoulder scheme would also reintroduce the risk of hard shoulder misuse, which can occur with the part time use of the hard shoulder. Road markings, junction layouts and technology requirements (e.g. need for additional CCTV cameras) would also need to be considered as the Scheme is not designed for closure of long lengths of Lane 1 on a nightly basis.

6.3.3 For these reasons, the regular closure of Lane 1 to provide a hard shoulder at night is not proposed.

6.4 We look forward to seeing the enhanced noise mitigation strategy from Highways England, hopefully in the next three or four weeks.

Highways England Comment

6.4.1 As detailed above, Highways England confirms that the findings of the enhanced noise mitigation study are provided with the submission at Deadline V.

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Appendix A – Supporting Noise data submitted by Clive Jones in the submission of 25th November and additional information submitted on 4th December

Table 1: Noise data provided by Clive Jones as part of his submission of 25th November noted by him as noise levels (LAeq) at 40 specified locations over 3 days

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Appendix B – Clive Jones Email dated 4th December 2015

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