A30 Chiverton to Carland Cross TR010026 8.1 COMMENTS ON RELEVANT REPRESENTATIONS Volume 8 February 2019 WORK\33585641\v.1 1 15536.25 Classification: Confidential A30 Chiverton to Carland Cross | HE551502 Highways England Table of Contents Contents 1 Introduction 1 1.1 Purpose of this document 1 1.2 Structure of the document 1 2 Response to Relevant Representations 2 Annex A: Highways England Response to Environment Agency Relevant Representation 44 Annex B: Highways England Response to Historic England Relevant Representation 53 Annex C: Position Statement with the Health and Safety Executive 69 Annex D: Position Statement with Scottish Power Renewables 71 Annex E: Highways England Response to Nancarrow Farm Relevant Representation 74 Annex F: Highways England Response to the National Farmers Union Relevant Representation 103 Annex G: Highways England Response to Truro Cycling Campaign Relevant Representation 118 A30 Chiverton to Carland Cross | HE551502 Highways England 1 Introduction 1.1 Purpose of this document This document has been prepared by Highways England (the Applicant) for submission to the Examining Authority (ExA) under Deadline 1 of the Examination of the A30 Chiverton to Carland Cross Development Consent Order (DCO) application. The document provides the Applicant’s response to Relevant Representations submitted to the ExA by Interested Parties. 1.2 Structure of the document In total, 117 Relevant Representations were submitted to the ExA by the deadline of 10 November 2018. An additional 3 Relevant Representations were accepted at the discretion of the ExA after this deadline had passed. In total, therefore, 120 Relevant Representations have been received and considered by the Applicant. Table 1 provides: the Planning Inspectorate reference number for each Relevant Representation received; the name of the individual, party or organisation which made the representation (the Interested Party); the representation itself; and Highways England’s response or comment on the content of the Relevant Representation. In some instances, Highways England has provided a response to a Relevant Representation directly to the Interested Party prior to submission of this document. This has occurred through ongoing engagement and correspondence with such parties. In such cases, a copy of this correspondence is provided in an Appendix to this document. Similarly, Highways England’s continued discussion and engagement with parties has in some cases resulted in a substantial change in the position between the Interested Party and Highways England since the submission of the Relevant Representation. This has been captured in a ‘Position Statement’ submitted directly to the ExA prior to Deadline 1. Where this has occurred, reference is made to the relevant submission on the Planning Inspectorate website. HA551502-ARP-GEN-SW-RP-ZH-000020 | P01.1, --- | --- PAGE 1 OF 126 A30 Chiverton to Carland Cross | HE551502 Highways England 2 Response to Relevant Representations Table 1 Highways England's response to Relevant Representations Reference Interested Relevant Representation Highways England Response Party Relevant Representations made by section 42(1)(a)(b) prescribed consultees RR-097 Cornwall This is a single representation from Cornwall Council which takes into account the All matters raised in this Relevant Representation are dealt with in the updated Council many responsibilities and functions of the Authority. The response builds on the Statement of Common Ground with Cornwall Council (Appendix A, Document discussions which have taken place to date between the Council and Highways Reference 7.4(A)) that has been submitted at Deadline 1. England. It is of course accepted that the Development Consent Order process is ongoing, and that many of the technical issues that have been raised to date are being addressed by Highways England and will be subject to a further assessment as part of the Local Impact Report stage. While this process is still ongoing it is inevitable that the Council’s position will evolve; however underpinning this the Council wishes to maintain its overall support to the project and recognises the economic, environmental and social benefits the road improvement project will bring. At the time of writing this Representation the Council’s main areas of current concern for the Council are as follows: From a highways perspective there are a number of areas Cornwall Council in its role as Local Highway Authority require further clarification in order to reach an agreed position. These comprise: • Traffic Modelling – clarification on methodology and outputs of the traffic modelling, and how this has informed the junction strategy and design • Impacts on County Highway network – concerns remain on the impact of re-routed traffic as a result of the scheme on to local network, particularly the predicted increase on the B3284 through Shortlanesend into north Truro • De Trunking – agreement yet to be reached on the measures and associated funding required for de trunking the existing A30, particularly the treatment of Boxheater junction and measures to reduce the standard of the road appropriate for cyclists and local access traffic. • Walking, cycle and horse rider (WCH) provision at key locations, specifically at Chiverton junction and Carland Cross. Clearly it is understood that a scheme of this nature will have potentially significant environmental effects and on this basis the Council wishes to raise the following further points: • Potential noise and vibration impacts. • Potential impacts on the water environment through road traffic accidents - Measures for dealing with acute pollution through road traffic accidents are currently considered to be insufficient; • Draft Outline Construction Environmental Management Plan - It was considered that the draft Outline CEMP is generic at this time and comments are reserved on its provisions until the submission version is available; • Finally, Cornwall Council places a high priority on promoting Cornish distinctiveness in this project. Areas where this will require consideration will be in the promotion of bilingual signs, and the identification and HA551502-ARP-GEN-SW-RP-ZH-000020 | P01.1, --- | --- PAGE 2 OF 126 A30 Chiverton to Carland Cross | HE551502 Highways England Reference Interested Relevant Representation Highways England Response Party mitigation of effects on the World Heritage Site and Area of Outstanding Natural Beauty. More detailed comments on all matters will be provided at the Local Impact Report stage and at the examination stage of the process. RR-098 Environment See Annex A of this document. Highways England’s response to all matters raised in this Relevant Representation is Agency detailed in correspondence with the Environment Agency, which is provided at Annex A of this document. The detailed response from Highways England has been discussed with the Environment Agency and this will be incorporated into a Statement of Common Ground between both parties. Highways England consider that all matters are now agreed. AS-001 Historic See Annex B of this document. Highways England’s response to all matters raised in this Relevant Representation is England detailed in correspondence with Historic England, which is provided at Annex B of this document. RR-082 Public Health Thank you for your consultation regarding the above development. Public Health Noted. No response from Highways England is required. England England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project and can confirm that:- We have no additional comments to make at this stage and can confirm that we have chosen NOT to register an interest with the Planning Inspectorate on this occasion. Please do not hesitate to contact us if you have any questions or concerns. RR-070 Health and The applicant has acknowledged HSE’s response under Section 42 of The Highways England considers that all matters raised in this Relevant Representation Safety Planning Act 2008 in the Consultation documentation for this Project and has have been resolved through engagement with the Health and Safety Executive (HSE). Executive made several comments in response. These include confirmation that Highways This is evidenced in a Position Statement submitted by the HSE via email to the (HSE) England has consulted Wales and West Utilities and is in ongoing discussions Examining Authority on 13 February 2019. This Position Statement is provided in regarding the apparatus affected by the scheme and acknowledgement of our Annex C of this document. comment relating to Hazardous Substances Consent. In their position statement, the HSE confirms that it does not propose to enter into a However, until we are provided with the exact details of the proposed changes to Statement of Common Ground with Highways England (as requested by the the HP Gas Pipeline, there remains the possibility that HSE may advise against Examining Authority in the Rule 6 and Rule 8 letters), as they are satisfied that their the proposed development. We therefore reiterate advice given under Section 42 concerns regarding the Major Accident Hazard Pipeline and Newlyn Downs explosives of The Planning Act 2008 below: site have been addressed. “Reference is made to the proposed road project passing over and in part running Their risk assessors have looked at three Draft route plan drawings for the HP gas parallel with a major high-pressure gas main [Major Accident Hazard Pipeline pipeline diversion, noting that