Phase 1 of HS2 May 2013

Appendix A WCC consultation response for the Draft ES; Phase 1 of HS2 May 2013

Introduction Warwickshire County Council (WCC) has tried where possible to approach the commentary in this response logically and methodically. Where possible, comments have been referenced to the volume and section of the documentation they relate to. This approach has not been possible throughout the whole consultation response because in some areas e.g. Health, the draft ES makes no reference to the impact on health or the possible effects on communities. There is also no clear indication at this stage what methodology may be adopted in the full ES. In this instance WCC has provided both an overarching commentary on the value of a Health Impact Assessment and copy of a pro forma used within Warwickshire to aid HS2 Ltd in the production of a more robust report for the full ES.

A similar approach has been taken in the areas of Ecology, Heritage and Traffic Assessment because the current content of the information from HS2 Ltd in volumes, 1, 27 and the Community Forum Reports is considered to be of such poor quality and lacking in empirical data as to be impossible to comment meaningfully.

Furthermore, there are a number of material inaccuracies and omissions in the documents, where these occur the Council have picked them up in their comments and requested clarification or amendment as required. The terminology use in the report is in parts at best unclear and in places misleading. The repeated use of terms such as “low”, “medium,” “high” and “only local impact” (see page 27 of this report for specific examples on PROW) without any quantitative explanation in either the text or an accompanying appendix can lead the reader to either down play the impact being described or give the impression that HS2 Ltd. attaches no importance to the point. Neither option is considered by the Council to be acceptable; it is the Council’s expectation that this fundamental point is addressed prior to the publication of the Full ES.

Public Rights of Way (PROW) Broad Concerns.

It is important that there is consistency in the way that PROW are described within the ES documents and they should be referred to at their correct status as per the WCC Definitive Map and Statement. In the current version, E roads have been variously described as both footpaths and bridleways.

All PROW that are affected by HS2 should be mentioned within the relevant Community Forum Area Report. Where routes are not mentioned it gives the impression that they are unaffected by HS2 and that there is no mitigation required or alternatively that these routes have been ignored by HS2 Ltd.

When land is required on a temporary basis, it is imperative that the impact on PROW has been considered. For example, with temporary closures or alternative routes, it is vital to have clear and definite information on how long PROW are going to be shut for. It is of concern to WCC that the length of diversions and closure is being determined by an arbitrary figure of low usage (see Community Area Report section). HS2 Ltd need to ensure that where a route is re-opened after a long period of closure that the whole route is re-instated so that WCC does not incur any unnecessary maintenance costs.

Many PROW within WCC boundaries are regularly used by the public, but there are concerns that this is not reflected in the survey results as much of this usage fell at times outside of the survey period. The survey methodology for determining use of a PROW is not satisfactory, relying on usage during only two survey days between set times. The use of a PROW is by its nature transitory and on some routes unpredictable. Some routes identified by the HS2 survey as having ‘no use’ are known to be popular routes with heavy usage. This disparity has had an impact on the provision of crossings of HS2 for the route and has resulted in inappropriate diversions being proposed as alternatives.

HS2 maps accompanying the statement are known to be out of date. This makes it impossible to comment satisfactorily on any environmental or amenity impact of HS2 without knowing precisely what the actual impact is.

On the maps as presented the routes shown for diversions (temporary during the construction phase or permanent) are indicative only and subject to change. It is impossible therefore to offer any comments about the suitability or otherwise of such diversions.

There are inconsistencies within the plans with PROW diversions indicated on the construction phase drawing plans (plans prefixed CT-05-xxx) as being temporary, but in the Table of Footpath cycle and bridleway diversions found within the Community Forum Reports (possibly Table 6) are described as being permanent. The proposed scheme maps (prefixed CT-060xxx) show the permanent diversions of PROW. It is therefore not clear whether the prefixed CT-05-xxx plans show temporary or permanent PROW diversions. As a minimum, WCC expects that these mismatches are clarified and references corrected.

Where a temporary diversion is shown in the (prefixeCT-05-xxx) maps as passing through construction sites and material stockpiles, it is the duty of HS2 Ltd to ensure

that adequate provision will be made for the safe crossing of these sites by users of the PROW.

Within the ‘Glossary of terms and list of abbreviations’, the term ‘road used as a public path’ used as the definition for Public Rights Of Way no longer exists following the enactment of the Countryside and Rights of Way Act 2000 s47(2). The term Restricted Byway should be used. A byway is more correctly known as a Byway Open to All Traffic.

Volume 1: inc. Scope and methodology The commentary for this section deals with areas of concern where we are able to make useful and meaningful comments. As noted in the introductory paragraph of this documents, it is the Council’s view that much of the draft ES is deficient in detail which make a more forensic and consistent commentary impossible at this stage.

The Council has previously responded to the Scope and Methodology consultation in the summer of 2012 http://wp.me/p1vWUo-ms It is apparent from the Draft ES that much of the commentary and recommendations we made has not been incorporated into this version. Please note that Appendix C& D on Heritage and Ecology reiterate the main issues in these fields in respect to the scope and methodology

We believe that if HS2 Ltd. use the information previously supplied by ourselves and other statuary organisation the need to comment further on this section of the draft ES would be negated.

The table below outlines the main observations and changes to the methodology Warwickshire County Council consider reasonable to expect:

Document reference WCC comment/observation PROW Appendix A: Sustainable design aims Page 116 Design Aim 7: Protecting communities – One of the objectives of HS2 is to create The project would seek to maintain the sustainable communities with a health and amenity of residential sustainable design aim being to protect communities potentially affected by the communities. Proposed Scheme. This would include, where practicable, maintenance of It is unclear how separating communities access to services (such as health by severing PROW links between them facilities, schools and places of worship) and providing, in mitigation, a route and shops, and maintenance of alongside a busy road will enhance or environmental conditions such that protect a sustainable community. Even significant adverse effects on health and when there is suitable separation from amenity are mitigated. vehicular traffic the adverse effects of walking alongside a road are

Document reference WCC comment/observation considerable and would deter use of such diverted routes.

Some of the proposed diversions sever direct access from a settlement out onto a wide network of PROW and will thus affect the amenity value of the countryside within those affected settlements. The proposed diverted route in many such instances is alongside a busy road and adds significant distance to those popular Rights of Way and is not regarded as being adequate mitigation. The usage of the wider network of PROW will be adversely affected by the building of HS2.

No mention has been made that measures will be put in place to ensure that diverted Public Rights of Way can actually be provided on the ground and that there will be no additional maintenance liabilities placed upon the Highway Authority as a result.

3.5.54 page 39 It is imperative that appropriate PROW “would be constructed to the standards are used as those standards appropriate standard for each location”. applied to roads do not necessarily apply per se to Public Rights of Way and may not be appropriate. WCC expects reference to be made to BS5709:2006 – The British Standard for Gap, Gates and Stiles.

It is necessary that WCC is consulted on the surfacing of a route and that there is clarity on whether there will be an individual standard for each location. Bridleway bridges need to be suitable for horses and HS2 needs to take into consideration that some bridges can spook horses by the noise underfoot etc.

Main Activities – Site Clearance and Clarification is required as to when it is A4

Document reference WCC comment/observation Demolition page 40 expected that the alternative routes will be provided when physical work/site preparation affects public rights of way such that temporary diversions of PROW are implemented.

It is the minimum expectation that, as the Highway Authority, we receive notice at timescales agreed between HS2 and WCC of any temporary diversion/stopping up/alternative route required for any physical work/site preparation. It is imperative that this notice period takes into account the time required for notices to be put in place and advertised and consultation with any affected people. Clarification is also required as to how will these notices be provided for and who will pay for them.

There is no evidence to date that consideration has been given with regards storing of topsoil and other equipment to ensure PROW are kept open and unobstructed unless the appropriate temporary/permanent diversions are in place.

Viaducts page 43 It is implied that in the Water Orton/Coleshill area that the construction of the viaducts will take 6 years. It is however unclear as to whether it is expected that PROW will be diverted for long periods of time. If that is the case, when the correct legal line re-opens, it is necessary for HS2 to ensure that the entire route is re-instated (i.e. cleared of overgrowth/up growth, furniture repaired as appropriate) and that the PROW becomes usable again. It is important that it is not just the section that is within the HS2 area of operation is considered. PROW can become unusable quickly and it is important that they are put back A5

Document reference WCC comment/observation into a useable condition.

3.6.32 page 44 It is unclear from the document as to whether this includes PROW. It is Highway works, including temporary essential PROWs are included. diversions, would be carried out in consultation and agreement with the relevant highway authority. 3.6.33 page 44 Although PROW are mentioned in the first sentence, the rest of the paragraph Methods to reduce disruptions. only details roads. It is vital that PROW are not treated in the same way as roads as consideration needs to be given to the differing needs of users of PROW and those of road users. 3.6.41 page 47 It is clear that some PROW have been missed by HS2 Ltd where they did not Construction land requirements cross the route of HS2 i.e. they were some distance away from the proposed line but did fall within land take for construction works. Where additional PROW are affected by construction land, it is important that WCC, as the Highway Authority, is consulted before any works or diversions are undertaken.

4.2.15 page 56 As a minimum, WCC expects these assessments to be undertaken by a “Where it is not possible to quantify professional with experience in that field impacts ……… assessments will be (i.e. that impacts on PROW will be done carried out, based on professional by someone who has real knowledge of judgement” the way that PROW are used). The requirements of PROW users are different to those of road users and the use of a PROW differs significantly from the use of a road or footway, in timing of use, volume of use and type of user.

4.2.16 page 56 It is necessary that recognised standards and accepted criteria that have been Effects deemed to be significant have used for each topic area are clarified. been evaluated with reference to recognised standards and accepted There are concerns as to how the value criteria for each environmental topic of a resource can be determined by A6

Document reference WCC comment/observation area, where these are available. standards and criteria. The value of a PROW may not be apparent to a person from outside the environment in which the PROW exists. Some PROW are more important than usage figures for only one day would suggest.

5.5.5 page 63 and 5.13 page 71 It would appear that PROW surveys have been conducted using the same methodologies for road and footway usage. These do not give an accurate picture of usage and extrapolation of raw figures over a limited period. The condition of the surface and surrounding area, obstructions etc. would be a useful addition to any pure people count. Usage of PROW very often takes place at unsociable hours (e.g. early in the morning or late at night) and would not be picked up by a survey operating between 8am and 6pm. It would be more appropriate to have a PROW specific survey which may have prevented some of the issues now being raised by the proposed mitigation routes.

The temporary closure of PROW gets little mention although it is considered that some of the closures could be of a long timescale. It is important that consideration is given to the provision of temporary alternative routes to alleviate the length of time that PROW are closed. It is not just the closure of the promoted routes that would have an impact on walkers and other users but the closure of any PROW.

Long distance and promoted routes may be important to the economy of Warwickshire, for instance for tourism, but these are not the only important PROW within the county and as much consideration needs to be given to the A7

Document reference WCC comment/observation others as to those few promoted routes. The other PROW are important in their own localities and are heavily used by the residents within them. The impact of HS2 is severe and the mitigation inadequate.

Non-technical Summary The Council is dissatisfied with none technical summary, it is in our view deficient in respect to the Public Rights of Way. The table below set out our main concerns; not least the omission of key base facts including a number of rights of way:

Document reference WCC comment/observation PROW Appendix A: Sustainable design aims Page 116 Page 76 (Ladbroke and Southam) No mention is made of the impact of the building of HS2 on the PROW other than that they would be permanently diverted.

Page 79 (Offchurch and Cubbington) – Mention is only made of the impact of the temporary closure of two promoted routes. No mention is made of the significant impact of the loss of a crossing over HS2 of the one PROW north out of Offchurch leading into a wide network of PROW and severing a link between two settlements. The mitigated route is not satisfactory.

No mention made of the importance of the Offchurch Greenway and the effect of HS2 on that and its concurrent Sustrans route and parallel footpath.

Page 85 (Coleshill Junction) Within the community section it is stated that the consideration of mitigation measures are continuing and will be reported in the formal ES. Without sight of the proposed mitigation for the PROW in the area it is not possible to comment on the effect of the loss of them or any proposed diversions (the routes of which

are not currently available to WCC). No mention is made of affected PROW at all either those to be closed, temporarily or permanently diverted. The PROW in this area are severely affected by HS2.

Page 86 (Curdworth to Middleton) There is no mention made of PROW and the effect on the community.

Report 27 Route Wide effects

This section of commentary covers report 27 which summarises the likely effects of the project on a ‘route-wide’ basis – that is, those effects which require consideration at a larger scale than within a CFA context.

As previously note it has not been possible to comment on every aspect of the report and where the Council has not provided direct comment, this is not an indication of consent or acceptance of the documented information.

Section 1: Introduction

The council has no comment to make at this time

Section 2: The Chilterns AONB

The council has no comment to make on this section

Section 3: Agriculture, forestry and soils

The council has no comment to make at this time

Section 4: Air quality

The council has no comment to make at this time

Section 5: Climate

The council has no comment to make at this time

Section 6: Community

6.1.1: The statement that “Impacts arising from both the construction and operation of the Proposed Scheme are considered to be of no more than local significance.” Fundamentally undervalues the impact this project will have on the day to day lives of communities. The statement is both unhelpful to the reader and dismissive of their concerns. It is the Council’s view that more weight should be given to this issue in the Full ES.

Furthermore the omission of a health impact assessment reinforces the concern that communities can be seen as collateral damage in the development process.

Public Health Warwickshire’s view is that the HS2 Environmental Statement does not reasonably consider the impact the environmental disruption will have on people’s mental and physical health.

Health is not currently included in the documentation; it is the County’s expectation that this significant omission will be rectified in the full ES, with observations from Public Health Warwickshire fully taken into account. Due to the lack of any detailed consideration of health, WCC is unable to comment on specific proposals or mitigation however it is imperative that HS2 Ltd rectifies this in the full ES and therefore a brief commentary on WCC’s expectations in general and specifically in relation to the Health Impact Assessment (HIA) are outlined below and in Appendix E.

We understand HS2 Ltd plan to carry out a separate HIA and we have been informed this will be made available in time for the deposit of the hybrid bill. However, we recommend that this HIA is comprehensive in nature and addresses not only route wide issues but local area specifics. A description of how to undertake a HIA is contained in Appendix E.

Public Health Warwickshire considers people’s health and the physical environment in which they live as being intrinsically linked.

Current evidence shows that the physical, social and economic environment in which people live and work has a huge influence on health. Many of the issues which large strategic projects influence is responsible for and can influence physical and mental health and help to contribute to the reduction of inequalities.

There are a number of key areas where the links between planning a strategic project like HS2 and health are significant, including:-

a) Transport and accessibility to amenities including healthy food b) Economy and job opportunities c) The built and natural environment to include open and green spaces and opportunities for physical activity such as cycle tracks, green gyms and measured miles d) Community interaction, engagement and partnership working e) Safety and security f) Air quality and noise g) Health care services

Public Health Warwickshire has identified a number of issues that HS2 Ltd needs to take note of and need to be considered during all stages of the HS2 planning and construction phases:

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• Public Health Warwickshire strongly recommends that HS2 systematically considers health and wellbeing as a matter of course – in particular where there are instances of the construction of HS2 or the line itself isolating communities and vulnerable groups and preventing them from easily accessing health services.

• Public Health Warwickshire and Public Health England should be consulted in the early stages of planning any major development that will have an impact on the health infrastructures ability to serve the local population.

• Public Health Warwickshire expects HS2 Ltd to conduct a comprehensive Health Impact Assessment, as previously agreed (see Appendix E).

• Public Health Warwickshire expect HS2 Ltd, through the planning and construction phase to create environments to enable maximum opportunity for healthy living and reduce opportunities for unhealthy behaviour. For example, increasing opportunities for walking, cycling, adequate lighting and green spaces, whilst also creating an environment which is non obesogenic by presenting fewer opportunities for unhealthy behaviour.

• Public Health Warwickshire strongly recommend to HS2, that any existing green spaces which present opportunities for people to be physically active are protected, not adversely impacted on and where reasonable possible these assets are enhanced as a result of this development. If any green spaces or access to them is isolated as a result of HS2, Public Health Warwickshire would expect details of any steps that are being planned to mitigate the impact to be discussed and agreed with Public Health Warwickshire and other statutory partners in Warwickshire.

• Public Health Warwickshire would urge HS2 Ltd that local employment opportunities are prioritised in relation to the development of the line through Warwickshire.

• Public Health Warwickshire recommends HS2 Ltd consider the Joint Strategic Needs Assessment (JSNA) in considering any mitigating steps to be taken to counteract any environmental or health impacts.

Section 7: Cultural Heritage

There is insufficient information presented in the draft ES and associated documents to enable an adequate evaluation of the area specific content and the conclusions presented in this report in respect of the historic environment.

Where comment is possible this has been set out in Appendix C.

The Council would expect HS2 to address these concerns prior to the production of the Full ES.

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Section 8: Ecology and Geology

Warwickshire County Council agrees and endorses all the issues and concerns raised in the Ecology Technical Group response (Annex a). WCC would wish to make a constructive critic of the Draft ES, as it has done for previous consultation papers for HS2. This particular report is particularly important on the associated impacts at specific Warwickshire locations.

However, to date no data has been submitted with the documentation so the Council cannot agree or disagree with the conclusions raised in the Draft ES. Without this evidence the Draft ES does not comply with EU or UK Environmental Impact Assessment guidelines and is therefore unsound and misleading to any decision maker.

Warwickshire County Council has, therefore, no option but to reserve comment and judgement on all the ecological and geological findings of the Draft ES, including the methodology to which these findings have been formed, until it has received the survey data plus the scientific studies and/or best practice used to determine these findings.

WCC has been able to make more constructive series of comments on the Code of Construction Practice in Appendix B

Section 9: Land Quality

The Council has no comment to make at this time

Section 10: Landscape and Visual Assessment

The key concern that WCC has with relation to this area is that HS2 Ltd have stated in the draft ES that ‘it is not considered that there are any significant route-wide effects on landscape and visual receptors arising from the construction or operation of the Proposed Scheme.’

In terms of the baseline, the LVIA states that the study area has been sub-divided into LCAs, however it is not clear whether these are taken from existing local Landscape Character Assessments, or whether assessments were carried out specifically for this ES. Reference needs to be made either to the existing Assessments that have been used, or if a specific assessment has been carried out this should be made available to officers at WCC.

Furthermore, the ‘value’ of the landscape isn’t adequately addressed. Sensitivity is described as high/medium/low but there is no explanation of the basis for this judgement. Green Infrastructure is part of the landscape but hasn’t been mentioned in this section therefore it is not possible to ascertain whether the effect on GI and the potential to enhance it has been addressed. With regards mitigation it is unclear as to whether a draft Environmental Management Plan has been drawn up, as A12 recommended in the GLVIA, to demonstrate that any mitigation measures or enhancements can be delivered in practice. It is imperative that this is done prior to the publication of the full ES.

It is not possible to comment on landscape effects in any detail as they have neither been addressed adequately nor has the rationale for assessing significance been explained.

In terms of visual effects, the ZTV (Zone of Theoretical Visibility) has still not been produced. Furthermore, the direction of view of the photo montages needs checking to ensure they are labelled correctly e.g. 253-2-001 view looking south-west towards the scheme doesn’t seem to be accurate- it appears to look away from the rail line, this error needs to be corrected

It would be helpful to have the direction and angle of view of photo montages marked on the map itself. Some of the photo montages appear to lessen the impact, especially those where the viewpoint is quite distant from the proposed line. It is necessary for HS2 Ltd to produce further montages at closer viewpoints, as well as additional ones in the most sensitive areas.

No mention is given as to whether there is a photographic record of existing views, if this has not been undertaken it is the Council’s view this is a necessary addition to the base data and need to be completed prior to the publication of the Full ES.

Section 11: Socio-economic

11.3.1: Bullet point2: The Council is concerned by the comment regarding the development opportunities around the stations. For the NEC, some of the possible development land is within Warwickshire and forms part of the Green Belt. It is wholly inappropriate to suggest this is a positive gain without an assessment of the negative impacts. Furthermore nowhere in the rest of the report is the issue of development dealt with or its consequential effects on housing, traffic generation or unintended development.

11.5.4 The figure of only 2,190 potential job losses along the whole route is disputed by the Council. Greater empirical evidence is requests to prove this assertion.

Section 12: Noise & Vibration

WCC is disappointed that the fundamental question of what will the noise impact be from HS2 has not been answered in the draft Environmental Statement. This is chiefly due to an inadequate level of information being given necessary in order for an ES to be sufficiently robust to enable comprehensive and informed responses to be made.

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It is important to ensure that HS2 Ltd. develop and publish an appropriate methodology for determining the noise and vibration impacts for all of the noise sources associated with the construction and operation of HS2. WCC need to be assured that all noise sensitive receptors including dwellings, businesses, leisure facilities and areas of recreation will be correctly assessed for noise impact.

The lack of available data has been recognised by HS2 Ltd.’s consultants and there are a number of references to further work being undertaken to confirm the likely significant effects which will be reported in the formal Environmental Statement.

The key expectation is that HS2 Ltd. through its project planning and execution minimise the noise and vibration impact on both communities and rural areas along the whole route.

The concern: The level of noise from the operation of HS2 is at present unknown and is unlikely to be fully appreciated and quantified until the rolling stock has been fully developed.

The draft Environmental Statement contains only a limited amount of specific information on noise; namely noise contour plans which provide an approximation on the absolute level of noise impact from the operational phase of HS2. There is no indication of the relative impact i.e. the change from the existing baseline level or little in the way of operational or construction noise impact.

WCC believe the provision of baseline data, operational noise and construction noise details are essential in being able to quantify the magnitude of the noise impact and allow for a meaningful consultation exercise.

WCC has some specific areas of concern. The use of a minimum contour level of 50 dB LAeq in the absence of baseline data has the potential for properties in very quiet rural areas to be ignored in the overall impact assessment analysis. It is vital that the impact in rural areas is included in the process and we believe that a minimum contour level of 40 dB LAeq day and 30 dB LAeq night should be used. We are also concerned that the cumulative effect of LMax levels from the passing trains will have an unreasonable adverse effect on communities and request that HS2 Ltd take this factor fully into account.

Information provided on noise mitigation is only indicative at this time. WCC believe that this makes it difficult for communities to not only visualise the type of mitigation proposed but also to submit suitable and feasible alternatives to those currently offered.

A key factor in the process to mitigate the operational noise is to focus at the source with the provision of specific localised mitigation where it is deemed to be necessary.

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We are concerned that some locations may not be able to be sufficiently mitigated to prevent adverse effect.

We believe that the introduction of mitigation such as high noise fences and earth bunds can have the potential to create other undesirable effects on the landscape such as visual impact and also may be detrimental to local ecology. We urge HS2 to consider other measures to eliminate the need for substantial forms of mitigation.

The County recognise that further detailed work is being carried out which will be contained within the formal ES but are disappointed that a fully appraised view of the potential impact and mitigation measures cannot be given at this stage. There are further concerns that the tight timescale which the project is following could limit the opportunity to fully appraise the formal ES.

The County Council believe that it is vital that the whole community are not only included in the impact assessment process but feel part of it. We are concerned that HS2 Ltd.’s approach to identifying the areas of significant effect on a community defined basis may be prejudice to the many dwellings in isolated locations by excluding their impact from the assessment process analysis.

The County Council have a number of specific local concerns. We are concerned that where the proposed line runs adjacent to the village of Water Orton, we believe That the train movements on this section will have a severe impact on the community and in particular Water Orton Primary School. The County Council urge HS2 to accurately analyse noise in this area, and where an increase in noise is identified, significant appropriate mitigation be provided.

We are concerned that where the proposed line runs through the Burton Green, train movements on this section will have a severe impact on the community and in particular on Burton Green Primary School. The County Council urge HS2 to accurately analyse noise in this area, and where an increase in noise is identified appropriate mitigation provided.

The route passes through the Stoneleigh Showground, a site of national importance. The route of HS2 severs this site and will introduce noise and vibration to this site which houses rare and valuable livestock. The County Council urge HS2 to accurately analyse noise and vibration in this area, and where an increase in noise is identified or vibrations present, appropriate mitigation be provided.

The route passes through the area of Priors Hardwick, known for its tranquillity, the introduction of noise from HS2 will have a damaging effect on the area and the County council seek assurances from HS2 that suitable and effective mitigation will be provided in keeping with the location.

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We also have a concern regarding the impact of Rayleigh waves associated with high speed rail and the type of ground conditions the line is constructed on. The area of research on this is limited and the concern is that the actual impact may not be known until the line is open.

Warwickshire County Council expects:

The County Council seek to ensure that HS2 fully consider the following when preparing the formal Environmental Statement:

• HS2 to develop the highest quality noise mitigation measures.

• Proposed noise mitigation measures are accurately and clearly identified to enable communities to understand and also to allow alternatives to be proposed.

• The noise impact on all properties, including isolated dwellings, to be fully included in the analysis of the impact assessment process.

• Noise contours to commence at a minimum level of 40 dB LAeq for daytime hours and 30 dB LAeq night time.

• The cumulative effect of high LAMax noise levels is fully assessed in particular to the potential impact on sleep disturbance and that HS2 in their assessments take on board the guidelines published by the WHO.

• HS2 to develop its assessment of noise to take into full account the alterations to the highway network that it proposes, incorporating the effects from data contained in the TA.

• Noise assessments to be carried out for the construction phase of the works to assess the impact on the community and provide effective mitigation. . Section 13: Traffic & Transport

The County is disappointed by the basic errors in the report that are a consistent theme in each Community Forum area report. This is particularly evident in the failure to distinguish concisely between vehicle daily and peak hour trip rates for construction compound sites.

Without trusted base data it effectively renders any further assessment of the transport implications arising from HS2 impracticable at this stage.

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The council expects a significant improvement to the data and assessment prior to the publication of the full ES

Section 14: Waste and Mineral Resources

As identified in the CFA section concerning Waste and Minerals, the lack of detail on excavated material arisings at the sub-national/CFA level means that it is impossible to determine how much excavated material could be used ‘on-site’ as part of the works (which could be located some distance from where the material arises), or how much would be transported to appropriate disposal facilities ‘off-site’.

As the ES does not provide potential volumes or destinations, the ES has not taken into account the potential environmental impacts (direct, indirect or cumulative) of managing or transporting such material. As a minimum WCC expects that further detail is provided on this to ensure that these impacts are fully considered to ensure that the final ES is fit for purpose.

WCC considers that the sterilisation of important mineral resources must be considered as a potential route wide issue. Most adopted mineral plans, if not all, contain policies that seek to prevent the sterilisation of mineral resources and secure the prior extraction of the mineral where necessary. In particular, sand and gravel and crushed rock are required for aggregate production and national guidance in the NPPF requires that Mineral Planning Authorities should make provision for the maintenance of landbanks of at least 7 years for sand and gravel and at least 10 years for crushed rock (para. 145, bullet point 6).

It is understood that many MPAs are currently well below the 7 year landbank figure for sand and gravel and there is a potential for HS2 to sterilise large areas of resource along the route, as evident in Warwickshire. Such resources are note restricted to aggregates, and could be opened up to other construction or energy minerals where appropriate. Therefore in assessing the environmental impacts of the project through the ES, HS2 should undertake a detailed mineral assessment for the entire route examining: • permitted minerals sites on/in proximity of the route • potential/allocated mineral sites on/in proximity of the route • areas of mineral resource on/in proximity1 of the route

Where mineral resource is identified, detailed borehole information should be produced to determine the depth and quality of the resource. Consultation should be undertaken with MPAs and the minerals industry to determine whether the volume and quality of the material is of potential value, and whether the prior extraction is “practicable and environmentally feasible” (para 143, bullet point 5 of the NPPF).

1 Proximity will depend on the mineral and the method of working the material – see the British Geological Survey’s ‘A guide to Minerals Safeguarding in England’ (2007) and ‘Minerals Safeguarding in England: Good Practice Advice’ (2011) A17

Such an approach would embody the principles of sustainable development set out in Government national planning policy guidance

Chapter 15: Water Resource and flood risk assessment

There does not appear to be anything in the documentation regarding field drains. It is imperative that, as part of the construction works, any existing drainage is maintained.

Previous large-scale infrastructure projects like this have often interrupted centuries- old drainage arrangements and caused subsequent surface water flooding issues. It is the Council’s view that these issues are not yet adequately addressed and further evidence will be required prior to the publication of the Full ES.

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Community forum area 16- 21 specific concerns:

The following section covers technical specific issues for each local community forum Area report. Each series of tables is headed with the disciple it covers. As previously noted this is the Council’s initial view.

Community Forum Area report 16 – WCC comment/observation Ladbroke and Southam Highway

Section 2.3.6 and 12.3.21 The two statements are contradictory, furthermore the full TA has not yet been published, and therefore it is not possible for us to comment on the effects on the highway network. WCC should be given full opportunity to comment on this matter before the TA and final ES is published.

Section 2.3.5 – 2.3.7 The working hours stated are misleading as Core working hours would be from there is a start-up and close down period of 1 08.00 to 18.00 weekdays (excluding hour each side of the times stated. The hours bank holidays) and from 08.00 to stated are also misleading as it is inconsistent 13.00 on Saturdays. ……. with the CoCP where the hours may be different depending on the construction activity and the time of year. WCC urge HS2 to set out the working hours in line with their construction programme. WCC note that the TBM will be operating 24hrs a day, 7 days a week. WCC see this as unacceptable given that there will be movement of plant and vehicles outside normal working hours, which will not be within the tunnel.

Section 2.3.5 WCC urge HS2 to provide details on the Core working hours would be times for deliveries as there is no information from 08.00 to 18.00 weekdays on this and we would expect this not to outside the core working hours stated (excluding bank holidays) and from 08.00 to 13.00 on Saturdays. ……

Map book The construction traffic route using the lane CT-05-082-2 past Upper Radbourne Farm is thought to be a private road, and we cannot therefore

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Community Forum Area report 16 – WCC comment/observation Ladbroke and Southam Highway

comment on its suitability.

Map book The construction traffic route using windmill CT-05-083 Lane is unacceptable. It is a single track lane, with limited visibility and sharp bends

Map book The construction traffic route is unacceptable CT-05-113 as the salt Lane is a single track road

Map book HS2 severs the E6037 at the Longhole CT-05-119 Viaduct. From the drawings there is no indication of what HS2 intends to do to maintain access along this route

Map book WCC are disappointed at the level of detail CT-06-087 showing the alterations to the existing CT-06-086 highway network. WCC feel that it is not possible to provide any constructive CT-06-085 comments on the acceptability of the designs CT-06-084 given that there is no information to its CT-06-083 geometric layout. Of particular concern it is CT-06-082 not clear what standards the alterations have CT-06-082-2 been designed to. CT-06-081 CT-06-081-1 CT-06-080

CT-06-079 WCC request that HS2 re-examine the permanent diversion of the Banbury Road in order to reduce the length of diversion route required. The existing alignment can be retained to a degree by steepening the earthworks at the maintenance loop location and the introduction of a bridge of reduced span near to the current location where the HS2 route crosses Banbury road. WCC await a revised solution from HS2.

Section 12.5.5 Given that the full TA has not been published Given that the strategy is still WCC request that HS2 provide the Council developing, the assessment has yet opportunity to comment once the TA has to take into account any detailed been published, as we feel that there is phasing implications……. significant potential for adverse effects to our road network.

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Community Forum Area report 17 – WCC comment/ observation Offchurch and Cubbington Highway

Map book 20 WCC object in principle to the closure of Fig CT-05-089 Offchurch Lane, this is a loss to the Highway Authorities network. There is currently no provision for highway alterations at the crossroads with Welsh Road. WCC therefor require HS2 to re-examine its published proposals to keep this section of the highway network open.

Section 2.3.5 The working hours stated are misleading as Core working hours would be from there is a start-up and close down period of 1 08.00 to 18.00 weekdays (excluding hour each side of the times stated. The hours bank holidays) and from 08.00 to stated are also misleading as it is inconsistent 13.00 on Saturdays. ……. with the CoCP where the hours may be different depending on the construction activity and the time of year. WCC urge HS2 to set out the working hours in line with their construction programme

CT-06-115 This differs from all other figures for this section of the route. The realignment of the A4091 shown on CT-06-115 is more acceptable than the other realignment shown, as it links the side roads that previously required diverting.

Map book The construction traffic route along Welsh CT-05-088 road is unacceptable given the number and size of the compounds along its length. There will be a significant adverse effect on the junctions, for which there has been no TA provided.

Map book HS2 severs the E6037 at the Longhole CT-05-088 Viaduct. From the drawings there is no indication of what HS2 intends to do to

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Community Forum Area report 17 – WCC comment/ observation Offchurch and Cubbington Highway

maintain access along this route

Map book The construction traffic route is unacceptable CT-05-119 as the Marston Lane is a single track road and is not suitably constructed.

Map book WCC are disappointed at the level of detail CT-06-112 showing the alterations to the existing CT-06-119 highway network. WCC feel that it is not possible to provide any constructive CT-06-113 comments on the acceptability of the designs CT-06-113-2 given that there is no information to its CT-06-114 geometric layout. Of particular concern it is CT-06-115 not clear what standards the alterations have CT-06-116 been designed to.

Section 12.6.1 Given that the full TA has not been published The assessments undertaken at this yet WCC feel that the statement of ‘no stage have indicated that for this significant impact’ is misleading. WCC area there would be no significant request that HS2 provide the Council transport related impacts………. opportunity to comment once the TA has been published, as we feel that there is significant potential for adverse effects to our road network.

Community Forum Area report 18 – WCC/ Comment/ observation Stoneleigh, Kenilworth and Burton Highway Green

Map book The layout of the proposed realignment of the CT-06-094 B4113 does not satisfy the need for turning movements into the Royal Agricultural Ground at Stoneleigh. HS2 are urged to reconsider the highway layout at this location in order to provide adequate access to the main entrance and to facilitate the passage of through traffic.

Map book WCC object to the closure of Dalehouse lane CT-05-095 during the construction phase for HS2 in this CT-06-095 location. Section 2.3.9 The proposed scheme and land take will encroach on Kenilworth Club. WCC request

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Community Forum Area report 18 – WCC/ Comment/ observation Stoneleigh, Kenilworth and Burton Highway Green

that HS2 revisit their proposals for Dalehouse Lane to ensure that the road remains open during construction and that the proposed bridge and land take do not affect the viability of Kenilworth Golf Club

Section 2.3.5 WCC urge HS2 to provide details on the Core working hours would be times for deliveries as there is no information from 08.00 to 18.00 weekdays on this and we would expect this not to outside the working hours stated (excluding bank holidays) and from 08.00 to 13.00 on Saturdays. …….

Green Section 2.3.5 The working hours stated are misleading as Core working hours would be there is a start-up and close down period of 1 from 08.00 to 18.00 weekdays hour each side of the times stated. The hours (excluding bank holidays) and stated are also misleading as it is inconsistent from 08.00 to 13.00 on Saturdays. with the CoCP where the hours may be ……. different depending on the construction activity and the time of year. WCC urge HS2 to set out the working hours in line with their construction programme

Map book WCC object to the temporary closure of CT-05-100 Waste lane and urgeHS2 to reconsider their CT-06-100 current proposals for the construction of the online overbridge. This is an important Section 2.3.9 section of the road network in the area and is heavily trafficked at peak periods. It is also unsuitable as a construction traffic route due to the high traffic flows that currently use the road. The crossroads at the junction of waste lane and Hogetts lane is also unsuitable as a construction traffic route.

Section 12.3.5 The scope of this assessment has not been The scope of this assessment has agreed with the Highway Authority. The been discussed and agreed with the assessment is also sadly lacking any detail. relevant highway authority

Section 12.4.12 WCC request that HS2 enter into dialogue The following list shows the with the highway Authority to establish what junctions that would operate over improvements need to be made to the junctions as part of HS2’s proposals. HS2 capacity………. state that the delays at junctions mentioned

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Community Forum Area report 18 – WCC/ Comment/ observation Stoneleigh, Kenilworth and Burton Highway Green

Section 12.3.9 would not be significant, it is misleading, if the … Analyses of junction impacts results of analyses are not yet known. WCC during construction is not yet request that discussions take place before the final ES and full TA are published. known. Section 12.5.21 The effect of increased traffic on congestion and delay at junctions mentioned would not be significant…………

Map book WCC are disappointed at the level of detail CT-06-093 showing the alterations to the existing CT-06-094 highway network. WCC feel that it is not possible to provide any constructive CT-06-095 comments on the acceptability of the designs CT-06-096 given that there is no information to its CT-06-097 geometric layout. Of particular concern it is CT-06-098 not clear what standards the alterations have CT-06-099 been designed to. CT-06-099

Section 12.5.6 Given that the full TA has not been published Due to the temporary nature and yet WCC feel that the statement of ‘not to be very short nature of most of these significant’ is misleading. WCC request that diversions they are deemed not HS2 provide the Council opportunity to significant comment once the TA has been published, as we feel that there is significant potential for adverse effects to our road network. HS2 are urged to discuss the impacts on the road network with WCC before the publication of the final ES and the full TA

Community Forum Area report 19 – WCC/ Comment/ observation Coleshill Junction Highway

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Community Forum Area report 19 – WCC/ Comment/ observation Coleshill Junction Highway

different depending on the construction activity and the time of year. WCC urge HS2 to set out the working hours in line with their construction programme

Section 2.3.5 WCC urge HS2 to provide details on the Core working hours would be times for deliveries as there is no information from 08.00 to 18.00 weekdays on this and we would expect this not to outside the working hours stated (excluding bank holidays) and from 08.00 to 13.00 on Saturdays. …….

Map book The realignment of this Attlebrough Lane CT-06-115 realignment is unacceptable; the horizontal alignment is ill thought out and appears substandard. There are no details of the vertical alignment

Map book The construction traffic route is unacceptable CT-05-113-02 as the old Kingsbury Road is not connected to the main highway at its intersection with the A4097, it is a residential road, and Seeney lane is a single track lane.

Map book The construction traffic route is unacceptable CT-05-113 as the Cuttle Mill Lane is a single track road

Map book The construction traffic route is unacceptable CT-05-119 as the Marston Lane is a single track road and is not suitably constructed.

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Community Forum Area report 19 – WCC/ Comment/ observation Coleshill Junction Highway area there would be no significant request that HS2 provide the Council transport related impacts………. opportunity to comment once the TA has been published, as we feel that there is significant potential for adverse effects to our road network.

Community Forum Area report 20 – WCC comment/ observation Curdworth to Middleton Highway

Section 2.2.6 The layout of the roundabout as proposed is Map book 20 unacceptable and WCC request that the Fig CT-06-112 roundabout provided meets the required standards laid out in the DMRB

In addition, the A44 Lichfield road and roundabout would be realigned approximately 300m west of its current location (Map CT-06- 119,G9)………..

Section 2.3.7 The size of the Hams Hall construction Figure 1 compound and the number of satellite Map book 20 compounds within this location are far too large. The effects on the local transport Fig CT-06-112 infrastructure have not been demonstrated in the Draft ES as the TA has not been published. The effects on the A446 will have a very severe adverse impact on the ability for the road network in the area to function. HS2 are urged to re-examine the extent of the compounds required in this area

Section 2.3.5 WCC urge HS2 to provide details on the times for deliveries as there is no information

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Community Forum Area report 20 – WCC comment/ observation Curdworth to Middleton Highway

Core working hours would be on this and we would expect this not to from 08.00 to 18.00 weekdays outside the working hours stated (excluding bank holidays) and

from 08.00 to 13.00 on Saturdays.

Map book Figure CT-06-115 differs from all other figures CT-06-115 for this section of the route. It is unacceptable to have different road layouts in the same section. HS2 is expected to rectify this inaccuracy in advance of the full ES.

Map book The construction traffic route is unacceptable CT-05-113 as the Cuttle Mill Lane is a single track road

Map book The construction traffic route is unacceptable CT-05-119 as the Marston Lane is a single track road and is not suitably constructed.

Map book WCC are disappointed at the level of detail CT-06-112 showing the alterations to the existing CT-06-119 highway network. WCC feel that it is not possible to provide comment on the CT-06-113 acceptability of the designs given that there is CT-06-113-2 no information to its geometric layout both CT-06-114 horizontally or vertically. CT-06-115 CT-06-116

PROW: Draft Environmental Statement – Community Forum Area Reports

There are a number of PROW that are omitted in the reports (see earlier comments in this report) and they are listed within the appropriate section.

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It is not possible to comment on any proposed diversions of PROW shown in the plans associated with these reports because the routes have not been finalised and WCC is still in discussion with HS2 Ltd regarding these. However, it should be noted that some PROW and E roads are not depicted on the plans. It is expected that HS2 Ltd will remedy this when it provides updated plans.

Within Section 12 Traffic and Transport, there are a few sections (the actual section numbers varies between each Area Report) but often 12.4.6 and then 12.5.15 and 12.5.16 which refer to the number of users of PROW.

The decision to structure the reports without giving the PROW points a defined section of sub section within the Transport chapter has led to a number of omissions and inconsistencies that the Council find unacceptable. This peppering of information is inconsistent and makes the issues much more difficult to identify for the Rights of Way Officer and almost impossible for a member of the community to understand. This approach must be addressed prior to the publication of the full ES.

The various sections on PROW refer to the impact of diversions and are “considered to be not significant” or of “minor significance” because of the few people that would be affected (no more than x people per day per ROW)’.

The “x” number varies between each report and there is no consistency as to what is regarded as being “a few people” (in some instances less than 60 and in others less than 200). For most rural PROW 60 people a day would indicate (in the Council’s view) a route of high usage and the impact would therefore be significant. HS2 Ltd must be consistent with its use of numbers throughout all the Area Reports and not “tweak” the numbers to fit the published. It is the Council’s absolute expectation this anomaly is rectified prior to the Full ES publication.

Where a promoted route is affected by HS2, the WCC footpath numbers (as shown on the Definitive Map and Statement) must be included in any description otherwise the information becomes so opaque as to render the proposals worthless.

The Area reports suggest that all PROW have been surveyed taking into account the nature of the PROW and their utilisation levels, and that as appropriate this would cover weekday and weekend use. The surveys seen indicate that one survey of each PROW was conducted, with many PROWs being surveyed on the same day.

It is not clear from the documentation what type of survey undertaken. If it was based on the perceived nature of the PROW or if each survey was conducted in the same manner. If only a one day survey was used, it is statistically unsound to claim that the use identified is actually representative. This needs to be addressed prior to the publication of the Full ES.

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Sections 12.6 Operations. It is unclear what assessments have been undertaken to determine transport related impacts.

There is no quantitative definition as to what is meant by “no significant” or “minor adverse” effects. This needs to be addressed prior to the publication of the Full ES.

Community Forum Area report 16 – WCC comment/ observation Ladbroke and Southam PROW

2.2.3 SM116 and SM200 are not included – this is an omission E2424 is correctly known as Wills Pastures Road, not Salt Lane Bridleway.

2.2.4 SM90 is not mentioned.

2.2.8 SM101 appears on CT-06-080.

2.2.10 SM116 and SM200 are not mentioned.

2.2.15 SM89 is affected by the construction site.

5.5.8 onwards (Public Rights of There is no mention of the impact of Way and open space) construction on PROW other than a few promoted routes. Mention should be made of all other PROW even if just to say that there is no impact on them.

12.6.2 Why is SM101 regarded as a leisure drive? It is a footpath.

Community Forum Area report 17: WCC comment/ observation Offchurch and Cubbington PROW

2.2.6 Footpath E2994 is actually an unclassified county road, an E road. The term footpath is misleading and should be corrected.

2.2.8 No mention is made of the Sustrans cycle way. The bridge should be capable of taking

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Community Forum Area report 17: WCC comment/ observation Offchurch and Cubbington PROW

users of W192, the Sustrans route and the Offchurch Greenway.

2.2.11 W129y is a well-used route and should have a bridge over the line of HS2. HS2 presents a barrier between a settlement (Offchurch) and a well-used network of PROW. Suitable mitigation/alternative route should be provided rather than a footway alongside a busy road.

5.2.3 A key policy in the Development Plan relates to ‘support to protect the continuity of existing pedestrian and cycle routes and the improvement of walking and cycling networks throughout WDC (policies DP6 and SC4)’. The severing of a long footpath providing a connection to a wide network of PROW and the provision of a very lengthy diversion alongside a busy road does not appear to support these policies (with particular reference to W129y). Consideration should be given to an alternative solution to this – provision of a bridge over HS2.

5.5.9 E2994 is described as a byway. It is an E road (an unclassified county road).

5.5.14 Is there any provision of an alternative route during the 24 month closure? HS2 Ltd need to consider the re-instatement of the whole of the affected PROW not just the section that is closed.

12.6.2 What is meant by the term Link Road? How does this term relate to bridleways and footpaths? The impact on W129y is a minor effect.

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Community Forum Area report 18: WCC comment/ observation Stoneleigh, Kenilworth and Burton PROW Green

2.2.15 Map reference CT-01-49 is not correct for the area.

2.2.16 No comment can be made on these diversions as they are still under discussion with HS2 Ltd.

12.5.16 In this case the impact of the diversions would not be significance or of minor significance because of the few number of people affected (less than 200). Compare this with Area 16 and 17 where the number of people affected is less than 60. 200 for a PROW is significantly more than 60 but is still not regarded as being significant.

Community Forum Area report 19: WCC comment/ observation Coleshill Junction PROW

12.5.16 In this case the number of users is considered to be low at less than 70 per day.

Some of the PROW affected are not mentioned in the overview section. However, the whole of this area is subject to change by HS2 Ltd and it is not possible to make comment on something that is currently unknown. Any alterations to roads should take into account any PROW termination point and should ensure that PROW terminates on a highway.

All PROW affected either directly by the line of HS2 or by the construction land take should be recorded.

Community Forum Area report 20: WCC comment/ observation Curdworth to Middleton PROW

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Community Forum Area report 20: WCC comment/ observation Curdworth to Middleton PROW

2.2.5 to 2.2.17 There is inconsistent representation of the PROW in this section.

This is not acceptable and it is the Council’s expectation this is addressed prior to the publication of the Full ES.

2.2.10 Seeney Lane is a bridleway. Consideration should be given to the users of the route if it is to be used for construction or maintenance traffic. Permission will be needed for vehicular traffic.

2.3.14 Are there temporary or permanent diversions proposed for the area of the compound.

2.3.32 The status of the PROW in this area is still for discussion with HS2 and it is not possible to comment on the unknown. However, the Location plans in Table 5 are the construction plans rather than the scheme plans and as a consequence the references need correcting.

M450 is a byway open to all traffic.

5.5.18 There is no mention on the effect of the land take for the railhead on M16.

12.4.6 and Low usage is less than 50 users per day. 12.5.17 Consistency with the other sections should be maintained.

12.6.2 The number of users mentioned in this section is being regarded as low at less than 200 per day.

Chapter 5: Community 5

As previously noted Health is not currently included as a topic in the draft ES. However, Public Health Warwickshire have supplied a number of comments that the Council believe are pertinent to the draft ES:

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Document reference WCC comment/observation Health

Community Forum Area report 16 – Ladbroke and Southam

2.1.9 page 13 Further information is needed regarding the There are a number of circular walking health and social impact on the local communities routes around the town of Southam, on any changes to these key recreational walking the most notable of which is the Harry routes, pathways and open spaces, either during Green Way which extends for 34km construction or long term. This is particularly and connects eight villages around the important regarding the Harry Green Way which town, including Ladbroke, Ufton and connects eight villages supporting community Bascote Heath. cohesion and reducing social isolation.

2.1.16 page 14 It is recommended that a health impact There are a number of parks and open assessment is conducted including the impact on spaces within the centre of Southam. physical activity levels, weight, cardiovascular and Elsewhere in the study area there is respiratory conditions and mental health and relatively little public open space, wellbeing. Pre-exiting conditions such as mostly limited to small amenity green cardiovascular, arthritis, respiratory and back pain spaces in the villages or church yards. could be exacerbated leading to increased use of health services if negative changes are made to 2.1.17 page 14 the local walking routes. There is a public footpath that runs along the edge of the Ufton Wood (also forming part of the Harry Green Way) which features in a number of local walking guides for the area. The Ufton Fields Nature Reserve (map CT-01-44, I1 and J1) lies just south of Ufton village. The reserve, which extends to about 40ha in total, includes a number of waymarked footpaths providing access to varied habitats for observing birds, insects and wild flowers.

5.4.8 page 48 There are a number of circular walking routes around the town of Southam, the most notable of which is the Harry Green Way, which extends for 34km and connects eight villages around the town, including Ladbroke, Ufton and the Bascote Heath. The Proposed Scheme crosses the route of the Harry Green Way at Windmill Hill, Ladbroke and the footpath also passes through

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Document reference WCC comment/observation Health an area which is proposed for ecological mitigation at Bascote.

5.4.9 page 48 The Ufton Fields Nature Reserve (map CT-03-44, I1 and J1) lies just south of Ufton village. The reserve, which extends to about 40ha in total, includes a number of waymarked footpaths, providing access to varied habitats for observing birds, insects and wild flowers.

5.4.10 page 48 In the study area, the Proposed Scheme crosses a number of public footpaths and bridleways, including the towpath for the Oxford Canal and the Harry Green Way public footpath, both of which are key promoted recreational routes in the area

2.3.15 page 21 While it is positive that light pollution has been The design of lighting for site recognised, sleep disturbance can have an compounds during hours of darkness adverse effect on health and so we would would seek to reduce light pollution to recommend that light pollution be kept to the surrounding area as far as recommended standards rather than sought to. reasonably practicable. Local policy PR8 does not permit development that would give rise to light pollution.

3.4.11 page 38 While it is positive to see that measures have The whole area is a Nitrate Vulnerable been introduced to reduce nitrogen losses from Zone where nitrate pollution is a agricultural sources to water, further detail is potential problem and measures have required as to what these measures are. As the been introduced to reduce nitrogen area is a Nitrate Vulnerable Zone and is losses from agricultural sources to dominated by arable food crops, we would water. recommend that measures taken prevent nitrogen losses as far as possible rather than only reduce it.

4.2.2 page 43 It is unclear how the HS2 project is going to Stratford-on-Avon District Local Plan support the local policy, particularly PR8 Review provides the policies that are regarding pollution. Further information is required applicable in the District. The principal to demonstrate how the construction of the Local Plan policy of relevance to air Proposed Scheme will not adversely impact

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Document reference WCC comment/observation Health quality is Policy PR.8: Pollution. This pollution or soil contamination in the area. policy does not permit development that would give rise to air, noise, light The health implications from pollution have not or water pollution, or soil contamination been addressed in this document and it is where the levels of discharges or recommended that a health impact assessment emissions are sufficiently significant to be completed with regards to pollution and health. cause harm to other land uses, health or the natural environment. General policies relating to nature conservation also refer to the need to avoid development that could harm their quality.

8.2.3 page 67 The adopted Local Plan includes a policy (PR8) on pollution control that does not permit development that could give rise to pollution, including soil contamination.

13.2.2 page 98 Policy PR.8 (Pollution Control) does not permit development that would give rise to pollution.

4.4.7 page 44 Air pollution, particularly dust from construction, Several locations have been identified could exacerbate existing respiratory or in the study area, which are considered cardiovascular conditions leading to an increase to be susceptible to changes in air in GP and acute hospital use. A health impact quality and are in close proximity to assessment of the workers on site and their living roads that would be subject to accommodation, as well as of the local realignments or used by construction community and affected properties is traffic. recommended. Continuous monitoring of pollution levels at the site during construction is also recommended, with the implementation of further measures to mitigate any pollution exceeding minimum permitted levels.

4.5.1 page 45 It is positive that the impact from dust from Impacts from the construction of the construction has been assessed; however it is Proposed Scheme could arise from unclear whether this assessment included an dust generating activities and impact on the health of the local community. If it emissions from construction traffic. As didn’t then a health impact assessment is such, the assessment of construction recommended as dust pollution can affect health. impacts has been undertaken for

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Document reference WCC comment/observation Health human receptors sensitive to dust and exposure to NO2 and PM10, as well as ecological receptors sensitive to dust and nitrogen deposition.

4.5.5 page 45 The construction dust assessment determined that of the seven locations identified in the study area, which are considered to be susceptible to changes and where residential properties are present…be slight adverse due to the presence of residential properties within 20 metres of the dust generating construction activities.

5.2.3 page 47 It is unclear how the HS2 project is going to Other key policy themes in the Local support the local policy, particularly Policy COM.9 Plan relate to: The section of an area of regarding walking and cycling routes and CS13 countryside on the western side of regarding accessible green networks. Green Southam along the River Stowe for its spaces and an accessible outdoor environment open space value (Policy SOU.A); and are important for health and wellbeing, particularly Support for the provision of safe and mental health and physical activity. Further well-connected walking and cycling information is needed detailing how the project routes (Policy COM.9). will support local health policy to provide walking and cycling routes, and where it doesn’t what 5.2.4 page 47 measures will be put into place to minimise any Green infrastructure principles that negative effect from the Proposed Scheme on the seek the protection, enhancement, population’s health. restoration and creation of a district- wide accessible green network which, amongst other things, would reinforce the distinctive landscape and character of the area (Policy CS13).

5.5.2 page 49 The health impact on these residents of the It is assumed that the occupiers of disruption due to construction and being rehoused these properties would need to be need to be explored. A health and social impact rehoused temporarily for the duration of assessment is recommended construction activities likely to cause noise and disturbance, but could then return to their homes upon completion of the works.

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Document reference WCC comment/observation Health

5.5.16 page 50 While it is positive that effects on community will The incidence of significant effects be assessed, it is important that within this including in-combination effects on assessment the impacts on health and social community amenity will be assessed in aspects are assessed. This includes impact on the formal ES. mental health and wellbeing, social isolation and community cohesion. 5.5.18 page 50 Multiple (in combination) community effects will be considered and where significant reported in the formal ES.

5.6.1 page 51 Within this study area, effects on the community resulting from the operation of the Proposed Scheme could potentially arise from significant changes to amenity.

5.6.2 page 45 While it is positive that impacts from transport, The assessment of effects on amenity traffic, air quality etc. have been recognised, it is will draw upon other technical important that the health effects of the Proposed disciplines (e.g. air quality, noise and Scheme are also considered. A health and social vibration, visual, transport and traffic) impact assessment is recommended. findings to inform the amenity assessment. The presence of in- combination impacts from these other disciplines could result in significant amenity effects on a number of community facilities and resources in the area. This will be reported in the formal ES.

10.5.1 page 85 The assessment states that there will be no effect No significant direct effects on non- on non-agricultural employment yet fails to state agricultural employment have been any effect on agricultural employment of which identified within this study area. It is Stratford-on-Avon has a higher than national and estimated that the Proposed Scheme regional average with 10% of businesses in the would result in the displacement or area being of this business type. Examination of possible loss of approximately 30 jobs any effect from the project on agricultural within this study area. business needs further exploration.

The assessment states displacement or possible loss of approximately 30 jobs within the study area, but does not take into account the rural nature of the area and difficulty in transport

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Document reference WCC comment/observation Health

around it. If premises are moved this could lead to further job loss if new sites are inaccessible to staff or customers, leading to a reduced customer base and possibly closure of the business and unemployment if the relocated premises are inappropriate.

The rural nature of the area means that any job loss is significant as other employment may not be accessible or available depending on the sector. It can lead to mental health issues, debt, increased alcohol consumption and associated ill health.

The cumulative effect over all Warwickshire affected areas from job losses are examined at the end of this response.

11.6.4 page 89 Some residential receptors have been identified Residential receptors within the as having a significant adverse effect from day daytime 65dB contour, and therefore and night HS2 noise. Although Noise Insulation the night-time 55dB contour, have been Regulations and WHO Night Noise Guidelines are identified as being likely to experience being used, we would recommend that target a significant adverse effect from HS2 noise levels be aimed below this threshold to noise alone. This is in line with the reduce the health and wellbeing effects on daytime threshold in the Noise residents in this rural area. Insulation Regulations and the Interim Target defined in the World Health Measures taken to reduce noise nuisance need to Organization’s Night Noise Guidelines be detailed with expected effectiveness data given in order to demonstrate they meet the permitted noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete.

11.6.11 page 90 Although it is stated that the envisaged mitigates The envisaged mitigation (especially will substantially reduce the potential airborne landscape earthworks and noise sounds, it is not stated or clear how reduced the barriers) described in this chapter noises will and whether the noise levels will substantially reduces the potential therefore fall below the permitted noise level. airborne sound impacts and noise effects that would otherwise arise from Noise disturbance has multiple negative effects the Proposed Scheme. Nonetheless, on the health and wellbeing of individuals, potential significant adverse airborne particularly concerning mental health and the noise effects have been identified effects of sleep disturbance. Additional detail is needed on the effectiveness of the envisaged

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Document reference WCC comment/observation Health

mitigates and what measures are going to be taken to in specific relation to the property identified as SV16-D01 on Maps SV-01 which will experience noise exceeding day and night time targets in order to minimise the health effects. It is recommended that monitoring of noise at this site continue during construction and after completion.

12.4.6 page 93 While a survey has been completed it is unclear All PRoW which would be intersected how the survey was completed.. The number of by the route have been surveyed, A 60 people per day using the facilities is not total of 23 PRoW have been identified necessarily a small number as implied, given the consisting of public footpaths, rural nature and small populations in the bridleways and cycle ways. The surrounding areas. It is recommended that a surveys indicate that none of the roads, community consultation and a health impact footpaths, bridleways and cycle ways assessment is completed in order to assess the that would cross the route are used by true impact on health, including mental health and more than 60 people per day walking, wellbeing and the impact on community due to cycling or riding. the loss of these routes in this rural area.

12.6.2 page 96 PRoW diversions as detailed are not deemed to be significant as the maximum number of people affected is no more than 60 per day per PRoW

Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health

2.1.7 page 13 It is unclear how the Proposed Scheme will A well-established network of public impact upon these vital networks of public footpaths, byways and bridleways footpaths that link the small communities within provide connections between the this area. Further information is needed regarding villages in the area. the impact that may occur with respect to social isolation, community cohesion and health and wellbeing if the routes were to be negatively affected by the Proposed Scheme.

2.1.10 page 13 While it is recognised that residents in the area The villages of Offchurch, Hunningham are dependent upon travelling to other areas for

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health and Weston-under-Wetherley share a services, further assessment is needed as to the limited range of facilities, comprising a effect the project may have on accessing these church, a public house, a village hall services. For example, if GP surgeries and and some areas of public open healthcare access is negatively affected A & E space...Many residents in the area are admissions may increase due to its use as an dependent upon travelling to the larger alternative (and possibly inappropriate) source of village of Cubbington, or to other main health care. Ill health in the community may centres outside the area for access to deteriorate if access to healthcare is day-to-day services. compromised so when care is sought the outcome is poorer for the individual. These could increase A & E waiting times and admission to the acute sector.

2.1.13 page 14 Further information is needed regarding the There is also a recreation ground at health and social impact on the local communities Offchurch, which is approximately on any changes to these key recreational walking 900m west of the Proposed Scheme. routes and pathways, either during construction or The Shakespeare’s Avon Way and the long term. Millennium Way public footpaths, which run through South Cubbington Wood, It is recommended that a health impact are popular local walking routes as well assessment is conducted including the impact on as forming part of a long distance trail. physical activity levels, weight, cardiovascular and respiratory conditions and mental health and 5.4.4 page 42 wellbeing. Pre-exiting conditions such as There are a number of open spaces cardiovascular, arthritis, respiratory and back pain and recreational routes in the area to could be exacerbated leading to increased use of the south and east of Offchurch. health services if negative changes are made to the local walking routes. 5.4.6 page 42 The Centenary Way and Grand Union A social impact assessment on social isolation Canal Walk run along the southern and community cohesion is also recommended. boundary of the area, following the towpath of the canal to Leamington Spa. The Centenary Way is a 157km long distance route, which runs from the Gloucestershire borders in the south to Kingsbury in the north, passing through Leamington Spa, Kenilworth and Stoneleigh to the north. The Grand Union Canal Walk is part of a 230km trail from London to Birmingham following the route of the canal. Both routes cross through the temporary and permanent land take areas for the Proposed Scheme

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health

5.4.11 page 43 There are also a number of open spaces, recreational facilities and routes to the north and east of Cubbington. To the north, are the Coventry Road allotments and Waverley Equestrian Training Centre…The Shakespeare’s Avon Way and the Millennium Way long distance footpaths share the same route through Cubbington and are crossed by the Proposed Scheme at South Cubbington Wood…The Millennium Way is a 160km marked trail which runs from Worcestershire to Northamptonshire, passing through Hunningham, Cubbington, Leamington Spa and Kenilworth. This footpath is also a popular local walking route as well as forming part of the two long distance trails.

2.3.14 page 20 While it is positive that light pollution has been Lighting of site compounds during recognised, sleep disturbance can have an hours of darkness would seek to adverse effect on health and wellbeing, and so we reduce light pollution to the surrounding would recommend that light pollution be kept to area. recommended standards rather than sought to.

3.2.2 page 31 It is unclear how the Proposed Scheme will Relevant saved policies of the adopted support the local policies which aim to protect WDC Local Plan protect best and most rural land from pollution and agricultural land versatile (BMV) agricultural land (Policy which is used for food production in the local DP3(g)) and support measures to area. It is also unclear what compensatory protect rural land from pollution (DP9) measures will be put into place from the predicted and flooding (DP11), which are adverse impacts from the Proposed Scheme. indirectly linked to the protection of agricultural land and soil quality. The health implications from pollution have not been addressed in this document and it is 8.2.3 page 60 recommended that a health impact assessment The adopted WDC Local Plan includes be completed with regards to pollution and health. a policy (DP9) on pollution control, including soil contamination, which requires developers to ensure that land is made fit and does not pose an

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health unacceptable risk of contamination. General Policy DP3 and the linked Policy DAP.3 include provisions to protect features of geological and geomorphological value, requiring developers to consider mitigation and compensatory measures if adverse impacts are predicted to arise from development.

9.2.2 page 65 Policy DP2: Amenity requires developers to consider and seek to avoid adverse impacts on amenity from noise, pollution, general disturbance and mature tree loss.

13.2.2 page 89 Policy DP9 (Pollution) restricts permission to new developments if unsuitable levels of pollution are produced, thus contributing to safeguarding surface water quality.

3.2.3 page 31 It is unclear how the Proposed scheme will Local Plan -Policies for the support the policies which stress the importance conservation of rural landscapes and of the outdoor environment and its benefits. It is woodland are contained in Section 15, recommended that when exploring the impact on Green Infrastructure, which stresses the environment that the impact on health from the importance of the natural and loss of the outdoor environment is explored. outdoor environment and the benefits it can bring for people and nature.

3.4.13 page 33 While it is positive to see that measures have The whole area is a Nitrate Vulnerable been introduced to reduce nitrogen losses from Zone, where nitrate pollution is a agricultural sources to water, further detail is potential problem and measures have required as to what these measures are. As the been introduced to reduce nitrogen area is a Nitrate Vulnerable Zone and is losses from agricultural sources to dominated by arable food crops, we would water. recommend that measures taken prevent nitrogen losses as far as possible rather than only reduce it.

3.5.8 page 35 Air pollution, particularly dust from construction, Irrigated crops are likely to be sensitive could exacerbate existing respiratory or

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health to dust. In addition, a number of cardiovascular conditions leading to an increase holdings have diversified enterprises, in GP and acute hospital use. A health impact including letting of surplus buildings assessment of the workers on site and their living and a marquee hire business, where accommodation, as well as of the local dust, noise and vibration could cause community and affected properties is problems. However, the emission of recommended. Continuous monitoring of pollution dust, noise and vibration during the levels at the site during construction is also construction phase would be controlled recommended, with the implementation of further by implementing best practice set out measures to mitigate any pollution exceeding in the CoCP and these issues are minimum permitted levels. considered not to be significant.

5.2.3 page 41 It is unclear how the HS2 project is going to Other key policy themes - Support to support the local policy, particularly Policies DP6 protecting the continuity of existing and SC4 regarding protecting the continuity of pedestrian and cycle routes and the existing and improvement of pedestrian and improvement of walking and cycling cycling networks. The good availability of walking networks throughout WDC (Policies and cycling networks are linked to good health DP6 and SC4). including physical activity, weight management and mental health and wellbeing. Further information is needed detailing how the project will support local health policy to provide walking and cycling routes, and where it doesn’t what measures will be put into place to minimise any negative effect from the Proposed Scheme on the population’s health.

5.4.8 page 42 While it has been recognised that the scheme Whilst the village is some distance cuts across routes that provide access from away from areas of temporary and Hunningham to health care, education and other permanent land take, the Proposed services in Cubbington and Leamington Spa, Scheme cuts across routes that consideration needs to be given to the importance provide access from Hunningham to of good access in the area in relation to the social facilities at Cubbington and Leamington impact including isolation, mental health and Spa to the west. wellbeing, public transport routes and availability and emergency vehicle access. Further assessment is needed to assess the health and wellbeing impact of reduced access to this rural area.

5.5.1 page 43 While it is positive to see that measures to Specific measures in relation to air minimise amenity impacts are to be put into place, quality and noise would also serve to it is also recommended that the impact to health minimise amenity impacts on the from air and noise pollution is explored. neighbouring communities.

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health

5.5.5 page 43 It is stated that construction disruption to journeys Residents at Hunningham and Weston- from Hunningham, Weston-under-Wetherley and under-Wetherley, who are dependent other areas to Cubbington and Leamington Spa is upon travelling to Cubbington and limited. Evidence is required as to how the impact Leamington Spa for access to services being of only limited disruption was obtained and such as schooling and health care, further research into the effect of delays over would experience some disruption to several months (and longer if works are not their journeys via Hunningham Road completed on time) on healthcare appointments, and the B4453 Rugby Road. schooling, employment, emergency vehicle access, public transport and mental health and wellbeing through stress and anxiety.

5.5.16 page 45 It is recommended that a health impact The significant residual effects of the assessment is conducted including the impact on scheme during construction would be physical activity levels, weight, cardiovascular and as follows: The possible temporary respiratory conditions and mental health and postponement of the Wolf Run cross- wellbeing. Pre-exiting conditions such as country running event on land at Welsh cardiovascular, arthritis, respiratory and back pain Road Farm, at Offchurch due to could be exacerbated leading to increased use of construction of the route through the health services if adverse changes are made to centre of the course resulting in an the local walking routes. adverse effect on participants and spectators; and the temporary closure of the Shakespeare’s Avon Way and Millennium Way at South Cubbington Wood, which would have an adverse effect on walkers, both locally and those following the promoted long distance routes.

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health

9.4.2 page 66 It is recommended that a health impact The historic Fosse Way and Grand assessment is conducted including the impact on Union Canal also cross the area. physical activity levels, weight, cardiovascular and PRoW include three long distance respiratory conditions and mental health and routes and the Offchurch Greenway wellbeing. Pre-exiting conditions such as (Sustrans NCR 41). Land from south of cardiovascular, arthritis, respiratory and back pain Offchurch northwards to Weston Wood could be exacerbated leading to increased use of is designated green belt. The eastern health services if adverse changes are made to section of the area is designated by the local walking routes. WDC as a Special Landscape Area.

11.5.1 page 80 While it is positive that the potential effects on The assessment has considered the occupants from construction noise has been potential effects on all community assessed, it is unclear whether this assessment receptors within the spatial scope, their also explored the health impact from noise occupants and their use (including including sleep disturbances, stress and mental annoyance and activity disturbance) health. A health impact assessment is arising from construction noise and/or recommended. vibration.

11.5.5 page 81 While it is positive to see that further work Further work is being undertaken to regarding the effect of noise is being undertaken, confirm significant construction noise it is unclear whether this includes any work to and vibration effects, including any examine the health effects from the construction temporary effects from construction noise and vibration for the local community. A traffic. health impact assessment is recommended.

11.6.4 page 81 Residential receptors have been identified as Residential receptors within the having a significant adverse effect from day and daytime 65dB contour, and therefore night HS2 noise. Although Noise Insulation the night-time 55dB contour, have been Regulations and WHO Night Noise Guidelines are identified as being likely to experience being used, we would recommend that target a significant adverse effect from the noise levels be aimed below this threshold to Proposed Scheme. reduce the health and wellbeing effects on residents in this rural area.

Measures taken to reduce noise nuisance need to be detailed with expected effectiveness data given in order to demonstrate they meet the permitted noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete.

12.4.6 page 85 While a survey has been completed it is unclear All PRoW which would be intersected how the survey was completed. The number of 60

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Community Forum Area report 17 – WCC comment/observation Offchurch and Cubbington Health by the proposed route have been people per day using the facilities is not surveyed... A total of 13 PRoW have necessarily a small number as implied, given the been identified consisting of public rural nature and small populations in the footpaths, bridleways and cycle ways. surrounding areas. It is recommended that a The surveys indicate that none of the community consultation and a health impact roads, footpaths, bridleways and cycle assessment is completed in order to assess the ways that would cross the proposed true impact on health, including mental health and route, are used by more than 60 people wellbeing and the impact on community due to per day walking, cycling or riding. the loss of these routes in this rural area.

Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green

2.1.4 page 11 It is recommended that a health impact Further south is Stoneleigh Abbey assessment is conducted including the impact on (map CT-01-47, E9), an historic physical activity levels, weight, cardiovascular and country house and important visitor respiratory conditions and mental health and attraction set in a registered historic wellbeing. Pre-exiting conditions such as parkland. Other estate parkland around cardiovascular, arthritis, respiratory and back pain Stoneleigh is accessible to the public could be exacerbated leading to increased use of and is well used for local walks. Abbey health services if adverse changes are made to Park (map CT-01-47, E9), which is a the local walking routes. modern business campus in a parkland setting, is located just to the south of A social impact assessment on social isolation Stareton and alongside the Stoneleigh and community cohesion is also recommended. Deer Park Golf Course (map CT-01-47, C9). In the northern part of the area An economic impact assessment is also agriculture is the main land use, with recommended regarding adverse effects from the exception of the National Grid construction and long term of the Proposed transformer compound just north of Scheme on local business and tourist attractions. Burton Green and the golf course for These include Stoneleigh Deer Park Golf Course, the Nailcote Hall Hotel (map CT-01-50, Stoneleigh Abbey, Abbey Park, Nailcote Hotel, E8). Kenilworth Golf Club and Crackley Wood. The economic impact assessment should also include 2.1.10 page 13 any adverse effects on the employment of local The Coventry Way long-distance residents and income spent in the area from footpath and Centenary Way long- tourism and local use of the facilities. distance footpath wind their way through the area.

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green

5.4.11 page 51 There are a number of other public open spaces in the countryside separating Kenilworth from Coventry, the most notable being Kenilworth Golf Course and Crackley Wood. The Kenilworth Golf Club (map CT-03-48, F4) is immediately west of the route of the Proposed Scheme and the proposed area of temporary and permanent land take encroaches into the northern edge of the course along its boundary with Dalehouse Lane. Crackley Wood, which is located about 370m south of the Proposed Scheme, is designated as a local nature reserve and has a number of trails or walks that are accessible to the public.

2.1.19 page 14 Because of the limited range of community Burton Green in the north of the area facilities it is important that any impact on the has a limited range of community community from construction or long term is facilities. explored. Particularly regarding the health and wellbeing effects and social effects from increased social isolation due to closure of roads and footways etc. Attendance at A & E may increase if residents are not able to easily access their local GP if access routes are altered or removed.

2.3.13 page 23 While it is positive that light pollution has been Lighting of site compounds during recognised, sleep disturbance can have an hours of darkness would seek to adverse effect on health and wellbeing, and so we reduce light pollution to the surrounding would recommend that light pollution be kept to area. recommended standards rather than sought to.

3.2.5 page 36 It is unclear how the HS2 project is going to The emerging SMBC Local Plan support the local policy, particularly Policy P18: policies are similar to those in the Health and Well Being. Further information is SUDP and key themes relating to needed detailing how the project will support local environmental protection are retained. health policy and where it doesn’t what measures Policy P17: Countryside and Green will be put into place to minimise any negative Belt continues to protect BMV effect from the project on the populations health. agricultural land from development.

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green

Policy P18: Health and Well Being introduces a series of measures, one of which is to provide opportunities for growing local produce and resisting the loss of areas currently available for such cultivation.

3.4.12 page 39 While it is positive to see that measures have The whole area is a Nitrate Vulnerable been introduced to reduce nitrogen losses from Zone in which nitrate pollution is a agricultural sources to water, further detail is potential problem and measures have required as to what these measures are. As the been introduced to reduce nitrogen area is a Nitrate Vulnerable Zone and is losses to water from agricultural dominated by arable food crops, we would sources. recommend that measures taken prevent nitrogen losses as far as possible rather than only reduce it.

3.5.10 page 41 Air pollution, particularly dust from construction, Irrigated crops, including salad could exacerbate existing respiratory or produce, are sensitive to dust. In cardiovascular conditions leading to an increase addition, a number of holdings have in GP and acute hospital use. A health impact diversified enterprises, including horse assessment of the workers on site and their living stables/liveries, letting of surplus accommodation, as well as of the local buildings and car parking for events at community and affected properties is Stoneleigh Park, where dust, noise and recommended. Continuous monitoring of pollution vibration could cause problems. The levels at the site during construction is also emission of dust, noise and vibration recommended, with the implementation of further during the construction phase would be measures to mitigate any pollution exceeding controlled by implementing measures minimum permitted levels. set out in the draft CoCP.

4.2.4 page 44 It is unclear how the HS2 project is going to Air quality policy (EM9)… all major support the local policy, particularly EM9 development proposals will have to regarding air quality. Air pollution causes ill health demonstrate that they do not adversely and further information is required to demonstrate impact on air quality. how the construction of the Proposed Scheme will not adversely impact on air quality in the area. The policy encourages development where it can easily be accessed by Further information is needed detailing how the public transport, walking and cycling. project will support local health policy particularly concerning sustainable transport with accessing walking and cycling routes, and where it doesn’t what measures will be put into place to minimise any negative effect from the project on the

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green

populations health.

5.2.3 page 49 It is unclear how the HS2 project is going to Other key policy themes in the WDLP support the local policy, particularly Policies DP6, relate to Rural Area Policies which SC4, T16 and T17 regarding protecting existing seek to restrict development only to and improving walking and cycle routes and that...Protecting existing pedestrian networks. The good availability of walking and and cycle routes and the improvement cycling networks are linked to good health of walking and cycling networks including physical activity, weight management throughout Warwick District (Policies and mental health and wellbeing. Further DP6 and SC4). information is needed detailing how the project will support local health policy to provide walking 5.2.6 page 49 and cycling routes, and where it doesn’t what Other potential impacts of the measures will be put into place to minimise any Proposed Scheme relate to negative effect from the Proposed Scheme on the development and land uses that cross population’s health. the boundary between Solihull and Warwick District, such as PRoW and areas of nature conservation value. Policies T16 and T17 promote the maintenance and improvement of the walking and cycling network, including the co-ordination of route planning across borough boundaries. Nature conservation assets are protected by Policies ENV11, ENV13 and ENV14.

5.4.3 page 51 Although these urban areas are away from the Whilst Kenilworth and Coventry are the Proposed Scheme, further investigation is needed focus for shopping, education, health into the impact during construction in the care, employment and recreational accessibility of the healthcare and other social activities in the area, most of the facilities as travel is required to reach them. facilities in these urban areas are some distance away from the Proposed Scheme.

5.4.11 page 43 It is recommended that a health impact There are a number of open spaces assessment is conducted including the impact on and recreational facilities in the physical activity levels, weight, cardiovascular and southern part of the study area around respiratory conditions and mental health and Stoneleigh. Much of the estate wellbeing. Pre-exiting conditions such as parkland, which wraps around the cardiovascular, arthritis, respiratory and back pain eastern edge of Stoneleigh Park, is could be exacerbated leading to increased use of publicly accessible. It comprises a mix health services if adverse changes are made to

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green of natural and semi-natural green the local walking routes. spaces, crossed by a number of public footpaths and other established walking routes. The parkland extends to both sides of the B4113 Stoneleigh Road, with a small section falling within the proposed area of permanent land take for the Proposed Scheme.

5.5.5 page 54 The health impact on these residents of the A total of 27 residential properties in disruption due to construction and being rehoused this area would be situated adjacent to need to be explored. A health and social impact substantial engineering or demolition assessment is recommended. works or would be surrounded by land required temporarily for the construction of the Proposed Scheme. It is assumed that the occupiers of these properties would need to be rehoused temporarily for the duration of any construction activities likely to cause significant noise and disturbance, but could then return to their homes upon completion of the works.

5.5.17 page 55 While it has been recognised that the permanent At Stoneleigh, the Proposed Scheme land take at the Stoneleigh Estate and alterations would result in the permanent loss of during the long construction process at Kenilworth publicly accessible parkland from the Greenway and Sustrans cycle route would have a Stoneleigh Estate. This land is required significant adverse effect on recreational users to facilitate realignment of the B4113 and walkers, it has not been detailed how the Stoneleigh Road and Stareton Road Proposed Scheme will mitigate the adverse junction and to accommodate effects, particularly as local policy is to protect earthworks for the Proposed Scheme. and improve local walk and cycle routes. Whilst the area affected represents only a small proportion of the total Local policy also states that projects will need to estate, this particular section is well demonstrate that they will not have an adverse used by walkers. It includes a pathway effect on air quality. The closure of the cycle connecting the open space back to the networks and the commute link between the Stoneleigh Road and appears to be University and Kenilworth will have a significant used as part of an informal circular impact on users. If the option to cycle or walk is walk around the estate, via the historic removed for up to two years users may be forced Stare Bridge area to the north. This into cars to get to work or education. This would loss of land would, therefore, result in a lead to a decrease in the local air quality and

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green significant adverse effect on increase congestion in an already heavily recreational users. congested area. It is recommended that an air quality impact assessment is completed.

5.5.19 page 56 It is recommended that a health impact The Proposed Scheme would also assessment is conducted including the impact on cross the Centenary Way, Coventry physical activity levels, weight, cardiovascular and Way and Millennium Way long distance respiratory conditions and mental health and footpaths and both the Kenilworth wellbeing. Pre-exiting conditions such as Greenway and the Connect2 cardiovascular, arthritis, respiratory and back pain Kenilworth footpath/cycleway. could be exacerbated leading to increased use of health services if adverse changes are made to 5.5.20 page 56 the local walking routes. Just north of Kenilworth, the construction of the Proposed Scheme A social impact assessment on social isolation would require a temporary closure of and community cohesion is also recommended the recently completed Connect2 given the adverse effect on the local community, Kenilworth public footpath, bridleway particularly at Burton Green. and cycleway, which also forms part of the Sustrans National Cycle Network (route No. 52). Given the extensive nature of works in this area associated with the realignment of Canley Brook, a 6-12 month closure could be necessary. This would result in a significant adverse effect on users, particularly having regard to its value as a commuter link between Kenilworth and the University area to the north. The Proposed Scheme makes provision for a permanent diversion of the route to bridge over the new rail line.

5.5.21 page 56 At Burton Green, the construction of the Proposed Scheme would necessitate a temporary closure of the Kenilworth Greenway for a period of up to two years, giving rise to a significant adverse effect on the local community and on recreational users of the Kenilworth Greenway (which also

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green forms part of the Coventry Way between Crackley and Berkswell). Access to the Kenilworth Greenway from Cromwell Lane would also be lost during the construction period with limited suitable alternative access points in the area. The Proposed Scheme makes provision to divert the Kenilworth Greenway permanently over the line of the cut-and-cover tunnel through Burton Green and then alongside the route of the new rail line to the north

5.5.22 page 56 To the north of Burton Green, the construction of the Proposed Scheme would require the temporary closure of the Millennium Way public footpath, to the north of the B4101 Waste Lane. This closure could last for about 6-12 months, giving rise to a significant adverse effect on recreational users. The Proposed Scheme makes provision for a permanent diversion of the route to cross the railway via the Waste Lane overbridge, but given that the existing Waste Lane Bridge would need to be demolished and rebuilt; this diversion would not be available during the construction period.

5.6.2 page 57 The assessment of effects on amenity While it is positive that impacts from transport, will draw upon other technical traffic, air quality etc. have been recognised, it is disciplines (e.g. air quality, noise and important that the health effects of the Proposed vibration, visual, transport and traffic) Scheme are also considered. A health and social findings to inform the amenity impact assessment is recommended. assessment. The presence of in- combination impacts from these other disciplines could result in significant amenity effects on a number of community facilities and resources in the area. This will be reported in the

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green formal ES.

9.2.1 page 80 It is unclear how the HS2 project is going to Policy DP2: Amenity requires support the local policy, particularly DP2 developers to consider and seek to regarding pollution. Further information is required avoid adverse impacts on amenity from to demonstrate how the construction of the noise, pollution, general disturbance Proposed Scheme will not adversely impact and mature tree loss. pollution or soil contamination in the area. The health implications from pollution have not been 13.2.3 page 107 addressed in this document and it is Policy DP9 (Pollution) restricts recommended that a health impact assessment permission for new developments if be completed with regards to pollution and health. unsuitable levels of pollution are produced, thus contributing to safeguarding of surface water quality.

9.2.2 page 80 It is unclear how the HS2 project is going to Policy P18: Health and Well Being support the local policy, particularly Policy P18: references the role of green Health and Well Being. Further information is infrastructure in supporting health; and needed detailing how the project will support local seeks to safeguard and increase health policy and where it doesn’t what measures opportunities for local food production will be put into place to minimise any negative across the borough effect from the project on the populations health.

10.5.2 page 94 The assessment states displacement or possible It is estimated the Proposed Scheme loss of approximately 30 jobs within the study would result in the displacement or area, but does not take into account the rural possible loss of around 30 jobs within nature of the area, disruption to an already this area. Taking into account the congested traffic area and difficulty in transport availability of alternative premises and around it. If premises are moved this could lead to the relatively healthy local economy, further job loss if new sites are inaccessible to the displacement or possible loss of staff or customers, leading to a reduced customer jobs is considered to be relatively base and possibly closure of the business and modest compared to the scale of unemployment if the relocated premises are economic activity and opportunity in the inappropriate. area. The cumulative effect over all Warwickshire affected areas from job losses are examined at the end of this response.

11.6.4 page 97 Residential receptors have been identified as Residential receptors within the having a significant adverse effect from day and daytime 65dB contour, and therefore night HS2 noise. Although Noise Insulation

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green the night-time 55dB contour, have been Regulations and WHO Night Noise Guidelines are identified as being likely to experience being used, we would recommend that target a significant adverse effect from HS2 noise levels be aimed below this threshold to noise alone. reduce the health and wellbeing effects on residents in this rural area.

11.6.11 page 97 Although it is stated that the envisaged mitigates The envisaged mitigation (especially will substantially reduce the potential airborne landscape earthworks and noise sounds, it is not stated or clear how reduced the barriers) described in this chapter noises will and whether the noise levels will substantially reduces the potential therefore fall below the permitted noise level. airborne sound impacts and noise effects that would otherwise arise from the Proposed Scheme.

Nonetheless, potential significant Noise disturbance has multiple negative effects adverse airborne noise effects have on the health and wellbeing of individuals, been identified for residential receptors particularly concerning mental health and the effects of sleep disturbance. Additional detail is needed on the effectiveness of the envisaged mitigates and what measures are going to be taken in specific relation to the multiple communities identified as SV18-C01 on maps SV- 01, SV18-C02 on maps SV-01, SV18-C03 on maps SV-01, SV18-C04 on maps SV-01, SV18-D01 and Sv18-D02 on maps SV-01, who will experience noise exceeding day and night time targets during construction and on a long term basis from railway operation, in order to minimise the health effects. It is recommended that monitoring of noise at this site continue during construction and after completion.

12.4.6 page 101 The number of 200 people per day using the All PRoW which would be intersected facilities is not a small number as implied, given

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Community Forum Area report 18 – WCC comment/observation Stoneleigh, Kenilworth and Burton Health Green by the route have been surveyed. A the rural nature of the areas. Local policies total of 26 PRoW have been identified advocate improving cycling and walking networks consisting of public footpaths, and well used ones such as this are in contrast to bridleways and cycle ways. The the local policy. It is recommended that a surveys indicate that none of the roads, community consultation and a health impact footpaths, bridleways and cycle ways assessment is completed in order to assess the that would cross the route are used by true impact on health, including mental health and more than 200 people per day walking, wellbeing and the impact on community due to cycling or riding. the loss of these routes in this rural area.

Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health

2.1.9 page 13 It is unclear how the Proposed Scheme will There is a network of public rights of impact upon these vital networks of public way (PRoW) within the area including footpaths that link the small communities within public footpaths and byways that this area. Further information is needed regarding provide connections between the edge the impact that may occur with respect to social of Birmingham (in Solihull) and both isolation, community cohesion and health and Coleshill and Water Orton, linking to wellbeing if the routes were to be negatively the hamlet of Gilson. Recreational affected by the Proposed Scheme. routes for walking and cycling also traverse the area at Coleshill Road/Gypsy Lane. In the north of the area, there are local PRoW that skirt around the edge of fields to provide circuitous connections to Smith’s Wood from Gilson and Coleshill (footpaths M54 and M56). Green Lane (footpaths M77, M72, and M75) provides the main east-west route between Coleshill and Chelmsley Wood. Hall Walk (footpath M76) links Coleshill with the Birmingham Road area over a distance of approximately 1.5km via an existing bridge over the M42 carriageways and a subway beneath the M6.

2.1.18-2.1.22 page 14 Adopted Local Plan and UDP policies strictly limit Coleshill open spaces and recreational development in the green belt to maintain the facilities and sports areas. openness of the landscape and prevent Gilson rugby sports pitches coalescence between the settlements and, in the

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health

Water Orton multiple recreation Solihull area, the parishes of Smith’s Wood and provisions Chelmsley Wood. Lanchester Park and Bosworth’s Wood together comprise a large publicly Local policy P10 and P14 requires developers to accessible open space and woodland maintain a healthy natural environment and aims area in Smith’s Wood supporting a to protect and enhance the amenity of existing range of activities including children’s and proposed users. It is unclear how the play, skateboarding, football and other Proposed Scheme will support these and mitigate ball sports, dog-walking and informal any losses to open spaces, playing fields and recreation through the woodland on woodlands. marked paths. There are also small areas of amenity green space within It is recommended that a health impact the various residential areas, as well as assessment is conducted including the impact on formal sports and playing fields linked physical activity levels, weight, cardiovascular and to educational facilities. respiratory conditions and mental health and wellbeing. Pre-exiting conditions such as cardiovascular, arthritis, respiratory and back pain could be exacerbated leading to increased use of health services if adverse changes are made to the local walking routes.

2.3.13 page 23 While it is positive that light pollution has been Lighting of site compounds during recognised, sleep disturbance can have an hours of darkness would seek to adverse effect on health and wellbeing, and so we minimise light pollution to the would recommend that light pollution be kept to surrounding area. recommended standards rather than sought to.

3.2.3 and 3.2.5 page 37 It is unclear how the HS2 project is going to The emerging SMBC Local Plan support the local policy, particularly Policy P18: policies are similar to those in the Health and Well Being and NW11 and NW12 SUDP and key themes relating to protection of the natural environment. The natural environmental protection are retained. environment and access to the outdoors, green Policy P17: Countryside and Green spaces and recreational facilities are important for Belt continues to protect BMV health. agricultural land from development. Policy P18: Health and Well Being Further information is needed detailing how the introduces a series of measures, one of project will support local health policy and where it which is to provide opportunities for doesn’t what measures will be put into place to growing local produce and resisting the minimise any negative effect from the project on loss of areas currently available for the populations health. such cultivation.

Woodland and forestry are covered within Policies NW11 and NW12 dealing with nature conservation and

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health the protection of the natural environment.

3.4.12 page 39 While it is positive to see that measures have The whole area is a Nitrate Vulnerable been introduced to reduce nitrogen losses from Zone where nitrate pollution is a agricultural sources to water, further detail is potential problem and measures have required as to what these measures are. As the been introduced to reduce nitrogen area is a Nitrate Vulnerable Zone and is losses from agricultural sources to dominated by arable food crops, we would water recommend that measures taken prevent nitrogen losses as far as possible rather than only reduce it.

3.5.8 page 41 Air pollution, particularly dust from construction, Certain diversified enterprises such as could exacerbate existing respiratory or such as office; storage and cardiovascular conditions leading to an increase manufacturing units; and horse liveries, in GP and acute hospital use. A health impact would be particularly sensitive to dust, assessment of the workers on site and their living noise and vibration during accommodation, as well as of the local construction…these issues are community and affected properties is considered to be not significant. recommended. Continuous monitoring of pollution levels at the site during construction is also recommended, with the implementation of further measures to mitigate any pollution exceeding minimum permitted levels.

4.2.3 page 43 It is unclear how the HS2 project is going to The adopted Solihull UDP sets policies support the local policies, particularly Policy P10 to ensure that any new development on a health environment and P14 regarding contributes positively towards the protecting the amenity of existing and proposed Council’s environmental users. A good healthy natural environment is vital objectives....the importance of to health and wellbeing. More detailed information improving air quality in the borough is is needed on how the project will support local addressed in Policies P10, requiring policies, particularly focussing on the health developers to maintain a healthy aspects and where it doesn’t what measures will natural environment; and P14 be put into place to minimise any negative effect regarding protecting and enhancing the from the project on the populations health. amenity of existing and proposed users.

4.4.12 page 46 Air pollution, particularly dust from construction, Several locations have been identified could exacerbate existing respiratory or in the study area, which are considered cardiovascular conditions leading to an increase to be susceptible to changes in air in GP and acute hospital use. A health impact quality and are in close proximity to assessment of the workers on site and their living

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health roads that would be subject to accommodation, as well as of the local realignments or used by construction community and affected properties is traffic. recommended. Continuous monitoring of pollution levels at the site during construction is also recommended, with the implementation of further measures to mitigate any pollution exceeding minimum permitted levels.

5.2.3 page 48 Further detail is required as to the support of There are also new policy themes, these policies by the Proposed Scheme and the which include the active promotion and measures that will be taken to avoid disrupting or development of a comprehensive removing access to the green spaces and walking network of high quality and and cycling networks which are important in this multifunctional green spaces and rural area for both health and reducing social corridors (Policy NW13). isolation.

5.2.5 page 48 Adopted Solihull UDP Policies T16 and T17 promote the maintenance and improvement of the walking and cycling network, including the co-ordination of route planning across borough boundaries.

9.2.3 page 74 Policy NW13 looks to developers to contribute to the maintenance, enhancement and/or creation of green infrastructure, defined as high quality, multifunctional green spaces, corridors and other environmental features.

5.2.6 page 48 Further information is required as to the impact of Smith’s Wood, Kingshurst and the Proposed Scheme both during construction Fordbridge are located in a designated and on a long term rail operation basis on this regeneration zone...which commenced regeneration zone. with the construction of Smith’s Wood Community Primary School and would be completed with a new high street, shops, community facilities (including a health centre) and offices. Allied to this, the emerging SMBC Local Plan envisages further regeneration of existing housing areas and redevelopment of the existing

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health community facilities

5.4.5 page 49 However, the adverse effect of the isolation on Gilson has no other services and the community and an individual level including residents are reliant upon neighbouring mental health and wellbeing, social support, settlements for the provision of employment, emergency vehicle access and essential services and facilities access to services needs further assessment. including schools, convenience A&E admissions could increase due to no GP or shopping and healthcare. health care access, causing additional strain on the acute health service. It is recommended that a health impact assessment be conducted, assessing all health and social aspects of the isolation due to the project.

Further information is required on how the construction phase will be handled to ensure minimal impact on the community, particularly concerning access to essential services and facilities that are located outside of the area.

5.5.1 page 49 While it is positive to see that measures to Specific measures in relation to air minimise amenity impacts are to be put into place, quality and noise would also serve to it is also recommended that the impact to health minimise amenity impacts on the from air and noise pollution is explored. neighbouring communities.

5.5.9 page 51 It is encouraging to see that the effect of At Gilson, 50 properties are accessed construction and the ensuing isolation of the via Gilson Road.. Road access to community of Gilson has been recognised. Gilson would experience sequential However, the adverse effect of the isolation on disruption during the construction the community and an individual level including works as the surrounding roads are mental health and wellbeing, social support, temporarily closed...The combination of employment, emergency vehicle access and construction activity on all sides of the access to services needs further assessment. community and the disrupted access A&E admissions could increase due to no GP or could result in impacts on the health care access, causing additional strain on community if not managed the acute health service. It is recommended that a appropriately to reduce severance from health impact assessment be conducted, the nearest schools, childcare, assessing all health and social aspects of the healthcare and shops. isolation due to the project.

Further detail is also required on the proposed methods of how the construction will be managed appropriately in order to minimise the impact on the community in terms of health, social and

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health

economic aspects.

5.6.2 page 52 While it is positive that impacts from transport, The assessment of effects on amenity traffic, air quality etc. have been recognised, it is will draw upon the findings of other important that the health effects of the Proposed technical disciplines (e.g. air quality, Scheme are also considered. A health and social sound, noise and vibration, landscape impact assessment is recommended. and visual, traffic and transport). The presence of in-combination impacts from these other disciplines could result in significant amenity effects on a number of community facilities and resources in the area. This will be reported in the formal ES.

6.4.10 page 54 It is recommended that a health impact The former medieval park at Coleshill assessment is conducted including the impact on and Hall Walk, a historic avenue, lie physical activity levels, weight, cardiovascular and within the area of temporary and respiratory conditions and mental health and permanent land take. wellbeing. Pre-exiting conditions such as cardiovascular, arthritis, respiratory and back pain could be exacerbated leading to increased use of health services if adverse changes are made to the local walking routes.

9.2.6 page 74 It is unclear how the HS2 project is going to Policy P18: Health and Well Being support the local policy, particularly Policy P18: introduces a package of policy Health and Well Being. Further information is considerations aimed at improving needed detailing how the project will support local community health. The policy includes health policy and where it doesn’t what measures reference to the role of green will be put into place to minimise any negative infrastructure in supporting health; and effect from the project on the populations health. seeks to safeguard and increase opportunities for local food production across the borough.

11.5.5 page 92 While it is positive to see that further work Further work is being undertaken to regarding the effect of noise is being undertaken, confirm significant construction noise it is unclear whether this includes any work to and vibration effects, including any examine the health effects from the construction temporary effects from construction noise and vibration for the local community. A traffic. health impact assessment is recommended.

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health

11.6.4 page 93 Residential receptors have been identified as Residential receptors within the having a significant adverse effect from day and daytime 65dB contour, and therefore night HS2 noise. Although Noise Insulation the night-time 55dB contour, have been Regulations and WHO Night Noise Guidelines are identified as being likely to experience being used, we would recommend that target a significant adverse effect from HS2 noise levels be aimed below this threshold to noise alone. reduce the health and wellbeing effects on residents in this rural area.

11.6.13 page 98 It is recommended that the health impacts from Improvements in the performance of airborne noise are also assessed so that they are mitigation that may further reduce or taken into account when considering the avoid the potential significant airborne mitigation. noise effects are being considered for the formal ES.

12.5.15 page 98 While a survey has been completed it is unclear A total of seven PRoW would either be how the survey was completed. The number of 70 diverted or temporarily closed during people per day using the facilities is not an the construction period (subject to insignificant number as implied, given the rural consultation with the Local Authority). nature and small populations in the surrounding The numbers of users have been areas. It is recommended that a community identified during surveys undertaken in consultation and a health impact assessment is August and September 2012 as noted completed in order to assess the true impact on above. Of these seven PRoW, five health, including mental health and wellbeing and have been identified with user numbers the impact on community cohesion, particularly below ten per day. The remaining two social isolation, due to the loss of these routes in which are used more frequently are this rural area. detailed below:M43 – Attleboro Farm with 19 pedestrian and nine cycle users; and M77 – Link from Ryeclose Croft under the M6 (Green Lane Track) with 19 pedestrian and one disabled user.

12.5.16 page 98 The length of the diversions will be kept to a minimum where reasonably

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Community Forum Area report 19 – WCC comment/observation Coleshill Junction Health practicable. The impact of all diversions is not considered significant because of the few people that would be affected (less than 70 people per day per PRoW).

12.4.6 page 96 All PRoW which would be intersected by the proposed route were surveyed. As appropriate, these covered weekday and weekend use. A total of 23 PRoW have been identified consisting of public footpaths, bridleways and cycle ways. The surveys indicate that none of the roads, footpaths, bridleways and cycle ways that would cross the proposed route are used by more than 70 people per day walking, cycling or riding.

Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health

2.3.19 page 22 While it is positive that light pollution has been Lighting of site compounds during recognised, sleep disturbance can have an hours of darkness would seek to adverse effect on health and wellbeing, and so we minimise light pollution to the would recommend that light pollution be kept to surrounding area. recommended standards rather than sought to.

3.2.2 page 34 It is unclear how the HS2 project is going to The adopted NWBC Local Plan Core support the local policy, particularly Policy 10 and Policy 10: Agriculture and the Rural ENV6 regarding supporting and protecting Economy supports agriculture and agricultural land and maintaining soil quality. promotes agricultural diversification Further information is required to demonstrate activities where they can help to how the construction of the Proposed Scheme will underpin the rural economy...Policy not adversely impact pollution or soil ENV6: Land Resources includes contamination in the area, particularly in terms of protection of the best and most food production. versatile (BMV) agricultural land, as well as setting out a series of pollution It is unclear what impact the Proposed Scheme prevention measures that would will have upon the open green spaces and contribute to maintaining soil quality. community facilities. It is important to recognise Forestry and woodland are included in the health impact of these spaces to physical

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Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health policies relating to conservation and activity, respiratory condition management, weight recreation in the countryside... management and mental health. Dealing with nature conservation and the protection of the natural environment.

3.4.11 page 37 While it is positive to see that measures have The whole area is a Nitrate Vulnerable been introduced to reduce nitrogen losses from Zone where nitrate pollution is a agricultural sources to water, further detail is potential problem and measures have required as to what these measures are. As the been introduced to reduce nitrogen area is a Nitrate Vulnerable Zone and is losses from agricultural sources to dominated by arable food crops, we would water. recommend that measures taken prevent nitrogen losses as far as possible rather than only reduce it.

3.5.10 page 38 Air pollution, particularly dust from construction, The three holdings that use irrigation could exacerbate existing respiratory or for crops, including potatoes, are cardiovascular conditions leading to an increase sensitive to dust. In addition, a number in GP and acute hospital use. A health impact of holdings have diversified assessment of the workers on site and their living enterprises, including varied accommodation, as well as of the local commercial uses of farm buildings and community and affected properties is yards, a farm shop, stabling and a carp recommended. Continuous monitoring of pollution fishing lake (Cuttle Mill) where dust, levels at the site during construction is also noise and vibration could cause recommended, with the implementation of further problems. measures to mitigate any pollution exceeding minimum permitted levels.

4.2.2 page 41 It is unclear how the HS2 project is going to The NWBC Local Plan provide the support the local policy, particularly ENV9 policies that are applicable in the regarding air quality. Air pollution causes ill health borough. The principal adopted Local and further information is required to demonstrate Plan policy of relevance to air quality is how the construction of the Proposed Scheme will Policy ENV9: Air Quality. This policy is not adversely impact on air quality in the area. committed to safeguarding and enhancing air quality in the Borough and it includes reference to not permitting polluting forms of development within or adjacent to Air Quality Management Areas (AQMAs).

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Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health

Policy ENV11: Neighbour Amenities does not permit development where it entails significant loss of amenity for nearby occupiers, citing dust or fumes within the list of factors to be considered.

4.4.6 page 42 Air pollution, particularly dust from construction, Several locations have been identified could exacerbate existing respiratory or in the study area that are considered cardiovascular conditions leading to an increase susceptible to changes in air quality in GP and acute hospital use. A health impact and are in close proximity to roads that assessment of the workers on site and their living would be subject to realignment or accommodation, as well as of the local used by construction traffic. community and affected properties is recommended. Continuous monitoring of pollution levels at the site during construction is also recommended, with the implementation of further measures to mitigate any pollution exceeding minimum permitted levels.

5.2.2 page 45 It is unclear what impact the Proposed Scheme The adopted NWBC Local Plan policies will have upon the open green spaces and generally seek to resist the loss of community facilities. It is important to recognise existing community facilities, open the health impact of these spaces to physical space and formal sports and recreation activity, respiratory condition management, weight provision except where they are shown management and mental health. to be surplus to requirements and/or would be replaced to at least equivalent quality and quantity as part of development proposals (Policies ENV5, COM2 and COM3).

5.2.4 page 45 There are also new policy themes, which include the active promotion and development of a comprehensive network of high quality and multifunctional green spaces and corridors (Policy NW13).

5.4.6 page 46 While it is recognised that residents in the area Lea Marston lies within the study area are dependent upon travelling to other areas for to the east of the Proposed Scheme services, further assessment is needed as to the and is primarily a residential village that effect the project may have on accessing these lacks any day-to-day facilities, meaning services. For example, if GP surgeries and

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Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health that residents are reliant upon healthcare access is negatively affected A & E neighbouring settlements for the admissions may increase due to its use as an provision of essential services and alternative (and possibly inappropriate) source of facilities, including schooling, health care. Health in the community may convenience shopping and healthcare. deteriorate if access to healthcare is compromised so when care is sought the outcome is poorer for the individual. These could increase A & E waiting times and admission to the acute sector.

5.4.10 - 5.4.14 page 47 Further information is required as to how the Outdoor space, public footpaths, impact on these facilities will be mitigated, recreation facilities and tourist particularly with regards to the health benefits of attractions. such facilities, and the alternatives that will be provided if there is an unavoidable loss of open spaces and community facilities. Some of the paths connect local villages and the loss of these could lead to increased social isolation, reduced community cohesion and increased mental health conditions. A health and social impact assessment is recommended.

5.5.2 page 48 While it is positive to see that measures will be Specific measures in relation to air taken in relation to air quality and noise, we would quality and noise would serve to recommend that it is ensured that measures reduce amenity impacts on the ensure levels of noise and air pollution are below neighbouring communities. the recommended level rather than solely reducing them. A health impact assessment is also recommended.

5.5.10 page 49 It is encouraging to see that the effect of At Middleton, more than 50 construction and the ensuing isolation of the properties...would experience community of Gilson has been recognised. sequential disruption during the However, the adverse effect of the isolation on construction works. The combination of the community and an individual level including construction activity to the east and mental health and wellbeing, social support, south of the village and the interrupted employment, emergency vehicle access and access would result in isolation of the access to services needs further assessment. community, particularly from the A&E admissions could increase due to no GP or nearest schools, healthcare and health care access, causing additional strain on supermarkets, which are in Kingsbury the acute health service. It is recommended that a to the south-east. This would be a health impact assessment be conducted, moderate adverse isolation effect and assessing all health and social aspects of the is therefore considered to be significant isolation due to the project. in the context of the community.

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Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health

Further detail is also required on the proposed methods of how the construction will be managed appropriately in order to minimise the impact on the community in terms of health, social and economic aspects.

5.5.14 page 50 It is unclear what measures will be taken by the Dunton Stables is a well-used resource Proposed Scheme to mitigate the significant that relies on the availability of outdoor adverse effects of the temporary and permanent exercise space and the ability to loss of land. The bridleways and towpath are access and use the continuous network important parts of outdoor space, which are created by the surrounding bridleways important for good health and wellbeing, and canal towpath to deliver teaching particularly for physical activity and mental health. and trekking activities. The land take The impact on the local economy, including to the would impair the functionality of the owners and local employment, is also important in operation and have a moderate this rural area. A health, social and economic adverse effect on users of the stables impact assessment is recommended as to the and this is considered significant in the effects of the land loss. local context.

5.5.17 page 50 It is recommended that a community consultation At Middleton, there are several and a health impact assessment is completed in community facilities… A proportion of order to assess the true impact on health, regular users originating from outside including mental health and wellbeing and the Middleton are likely to rely on access impact on community cohesion, particularly social from the A4091 via Church Lane or isolation, due to the loss of these routes in this Park Lane and Vicarage Hill/Crowberry rural area. Lane. Road access between the village and the A4091 would experience sequential disruption during the construction works as surrounding roads are temporarily closed for the erection of bridging structures…The combination of construction activity to the east and south of the village and the interrupted access would result in partial isolation of these three community resources from some of the relevant users that they typically serve on at least a weekly basis. This would be a moderate adverse isolation effect and is therefore considered to be significant in the context of the community.

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Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health

5.5.19 page 50 While it is positive that impacts on community The incidence of significant effects, amenity have been recognised, it is important that including in-combination effects, on the health effects of the Proposed Scheme are community amenity will be considered also considered. A health and social impact and, where significant, reported in the assessment is recommended. formal ES.

5.6.2 page 51 While it is positive that impacts from transport, The presence of in-combination traffic, air quality etc. have been recognised, it is impacts from these other disciplines important that the health effects of the Proposed could result in significant amenity Scheme are also considered. A health and social effects on a number of community impact assessment is recommended. facilities and resources in the area. This will be reported in the formal ES.

9.2.3 page 76 It is unclear how the HS2 project is going to Local plan Policy NW13 looks to support the local policy, particularly NW13 on the developers to contribute to the maintenance and creation of green spaces. maintenance, enhancement and/or Green spaces are important for health, creation of green infrastructure, defined particularly physical activity, weight management as high quality, multifunctional green and mental health and wellbeing. Further spaces, corridors and other information is needed detailing how the project environmental features, with the will support this policy and where it doesn’t what Birmingham and Fazeley Canal and measures will be put into place to minimise any Kingsbury Water Park within the list of negative effect from the project on the populations green infrastructure assets. health.

11.5.5 page 94 While it is positive to see that further work Further work is being undertaken to regarding the effect of noise is being undertaken, confirm significant construction noise it is unclear whether this includes any work to and vibration effects, including any examine the health effects from the construction temporary effects from construction noise and vibration for the local community. A traffic. health impact assessment is recommended.

11.6.4 page 94 Residential receptors have been identified as Residential receptors within the having a significant adverse effect from day and daytime 65dB contour, and therefore night HS2 noise. Although Noise Insulation the night-time 55dB contour, have been Regulations and WHO Night Noise Guidelines are identified as being likely to experience being used, we would recommend that target a significant adverse effect from HS2 noise levels be aimed below this threshold to noise alone. reduce the health and wellbeing effects on residents in this rural area.

Measures taken to reduce noise nuisance need to be detailed with expected effectiveness data

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Community Forum Area report 20 – WCC comment/observation Curdworth to Middleton Health

given in order to demonstrate they meet the permitted noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete.

11.6.10 page 95 Although it is stated that the envisaged mitigates The envisaged mitigation (especially will substantially reduce the potential airborne landscape earthworks and noise sounds, it is not stated or clear how reduced the barriers) described in this chapter noises will and whether the noise levels will substantially reduces the potential therefore fall below the permitted noise level. airborne sound impacts and noise effects that would otherwise arise from the Proposed Scheme.

Nonetheless, potential significant Noise disturbance has multiple negative effects adverse airborne noise effects have on the health and wellbeing of individuals, been identified for residential receptors particularly concerning mental health and the effects of sleep disturbance. Additional detail is 11.6.13 page 96 needed on the effectiveness of the envisaged It is estimated that two dwellings – mitigates and what measures are going to be marked SV20-D01 on maps SV-01 – taken in specific relation to communities identified would potentially experience noise as SV20-C01 on maps SV-01 who will experience levels higher than the insulation trigger noise exceeding day and night time targets during level. construction and on a long term basis from railway operation, in order to minimise the health effects.

It is recommended that monitoring of noise at this site continue during construction and after completion.

12.4.6 page 99 While a survey has been completed it is unclear All PRoW which would be intersected how the survey was completed. The number of 50 by the proposed route have been people per day using the facilities is not surveyed. A total of 17 PRoW have necessarily a small number as implied, given the been identified consisting of public rural nature and small populations in the footpaths, bridleways and cycle ways. surrounding areas. It is recommended that a The surveys indicate that none of the community consultation and a health impact roads, footpaths, bridleways and cycle assessment is completed in order to assess the ways that would cross the proposed true impact on health, including mental health and route are used by more than 50 people wellbeing and the impact on community cohesion, per day walking, cycling or horse riding. particularly social isolation, due to the loss of these routes in this rural area.

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Community Forum Area report 24 – WCC comment/observation Birmingham Interchange and Health Chelmsley Wood

2.1.16 and 2.1.17 page 14 It is unclear what impact the Proposed Scheme Green spaces and outdoor amenities in will have upon the open green spaces and the local community community facilities. It is important to recognise the health impact of these spaces to physical activity, respiratory condition management, weight management and mental health. They are also important as a community meeting place and encouraging social cohesion.

2.3.14 page 23 While it is positive that light pollution has been The design of lighting for site recognised, sleep disturbance can have an compounds during hours of darkness adverse effect on health and so we would would seek to reduce light pollution to recommend that light pollution be kept to the surrounding area as far as recommended standards rather than sought to. reasonably practicable.

3.2.3 page 41 It is unclear how the HS2 project is going to The NWLP has three applicable support the local policy, particularly Policy 10 and policies. Policy 10 supports agriculture ENV6 regarding supporting and protecting and promotes agricultural agricultural land and maintaining soil quality. diversification activities where they can Further information is required to demonstrate help to underpin the rural economy. how the construction of the Proposed Scheme will Policy ENV6 includes protection of not adversely impact pollution or soil BMV quality land, as well as setting out contamination in the area, particularly in terms of a series of pollution prevention food production. The economic impact in measures, which indirectly benefit agricultural changes also needs further agriculture through safeguarding soil exploration and assessment. quality.

3.4.10 page 43 While it is positive to see that measures have All the areas affected by construction been introduced to reduce nitrogen losses from are classified as a nitrate vulnerable agricultural sources to water, further detail is zone (NVZ). NVZ are areas in which required as to what these measures are. As the nitrate pollution is a potential problem area is a Nitrate Vulnerable Zone and is and measures have been introduced to dominated by arable food crops, we would reduce nitrogen losses from agricultural recommend that measures taken prevent nitrogen sources to water. losses as far as possible rather than only reduce it.

3.5.9 page 45 Air pollution, particularly dust from construction, Farm or diversified enterprises, such as could exacerbate existing respiratory or housed livestock units, horticulture, cardiovascular conditions leading to an increase farm shops or visitor accommodation, in GP and acute hospital use. A health impact could be particularly sensitive to dust, assessment of the workers on site and their living

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Community Forum Area report 24 – WCC comment/observation Birmingham Interchange and Health Chelmsley Wood noise or vibration during construction. accommodation, as well as of the local community and affected properties is 4.4.6 page 42 recommended. Continuous monitoring of pollution Several locations have been identified levels at the site during construction is also in the study area that are considered recommended, with the implementation of further susceptible to changes in air quality measures to mitigate any pollution exceeding and are in close proximity to roads that minimum permitted levels. would be subject to realignment or used by construction traffic.

4.2.5 page 47 While it is positive to see that local air quality An Air Quality Action Plan (AQAP) has action plans have been recognised, it is unclear been developed by NWBC with the aim how the Proposed Scheme will support the plans of improving local air quality in the and the AQMA. Further information is required as designated Coleshill AQMA. As the to how the scheme will mitigate any effects due to AQMA only affects one property the pollution caused by it AQAP focuses particularly on this area and explores possible initiatives to mitigate the effects of air pollution at the property. These include continuing to gather air quality monitoring data from within the AQMA and exploring the reuse of the property in ways which do not conflict with the air quality objective.

5.2.2 page 51 While it is positive that relevant local policies have Other relevant policies of the SUDP been recognised, it is unclear how Proposed include: Policy ENV19 seeks to protect Scheme will support the policy. Particularly the amenity of residential and shopping regarding providing opportunities for recreational areas; community facilities; and open and physical activity, including PRoW and cycling spaces from potentially harmful, or bad routes, allotments for food production and loss of neighbour development...Policy R2 and community and social infrastructure. Further Policy R7 seek to protect and enhance information is required as to how the Proposed public parks, open spaces, PRoW and Scheme will support the policy and the cycling routes…Policy P18 addresses alternatives that will be provided if there is an the need to support strong, vibrant and unavoidable loss of open spaces, PRoW, cycling healthy communities by providing routes and community and social infrastructure in opportunities for formal and informal order to minimise any negative effect from the recreational and physical activity. Loss Proposed Scheme on the population’s health. of community and social infrastructure will be resisted unless there are commercial or operational reasons for ceasing, or an alternative is provided.

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Community Forum Area report 24 – WCC comment/observation Birmingham Interchange and Health Chelmsley Wood

Policy P20 states that the loss of existing open space, sports and recreational facilities will be resisted unless it can be demonstrated that it is surplus to requirements, or the benefit of the development outweighs the loss. Allotment gardens are protected in line It is unclear how the HS2 project is going to with Policy R5; support the local policy P14 regarding air, noise and light pollution. These pollutions can cause ill Policy P14 seeks to protect the amenity health and a health impact assessment is of areas by permitting development recommended to assess how the construction that would not contribute to air, noise or and long term use of the Proposed Scheme will light pollution and protect the impact on pollution and health in the area. tranquillity and local distinctiveness of Solihull Borough.

5.2.6 page 52 While it is positive that relevant local policies have In regard to community facilities, Policy been recognised, it is unclear how the Proposed NW17 states that proposals that would Scheme will support NW17 regarding access to result in the loss of an existing services community facilities. Further information is or facilities which contribute to the required as to how they will be supported, functioning of a settlement will only be particularly with regards to the health benefits of supported where the facility is replaced such facilities, and the alternatives that will be elsewhere or proven that it will not provided if there is an unavoidable loss of open harm the vitality of the settlement. spaces and community facilities.

5.6.2 page 55 While it is positive that impacts from transport, The presence of in-combination traffic, air quality etc. have been recognised, it is impacts from these other disciplines important that the health effects of the Proposed could result in significant amenity Scheme are also considered. A health and social effects on a number of community impact assessment is recommended. facilities and resources in the area. This will be reported in the formal ES.

9.2.1 page 79 It is unclear how the HS2 project is going to The SUDP contains eight policies that support the local policies, particularly C9 are relevant to landscape and visual regarding light pollution. While it is positive that assessment in terms of determining the light pollution has been recognised, sleep value and sensitivity of LCA and disturbance can have an adverse effect on health assessing the effects on these and so we would recommend that any effects on character areas...Policy ENV14 covers health from light pollution be mitigated. trees and woodlands. Policy R6 seeks to promote waterways as a recreational It is also unclear how policies ENV14 and R6 will feature whilst safeguarding the natural be supported by the scheme. Open spaces and

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Community Forum Area report 24 – WCC comment/observation Birmingham Interchange and Health Chelmsley Wood and heritage environment. Policy C9 access to the environment is important for health, concerns light pollution and is of particularly in terms of physical activity levels and relevance when determining effects mental health and wellbeing. Further information arising from additional lighting at night- is required to demonstrate how the construction of time on visual receptors. the Proposed Scheme will not adversely impact upon health.

9.2.3 page 79 It is unclear how the HS2 project is going to Policy P18: Health and Well Being support the local policy, particularly Policy P18: introduces a package of policy Health and Well Being and Policy 20 regarding considerations aimed at improving open spaces and outdoor recreation facilities. community health. The policy includes Further information is needed detailing how the reference to the role of green project will support local health policy and where it infrastructure in supporting health; and doesn’t what measures will be put into place to seeks to safeguard and increase minimise any negative effect from the Proposed opportunities for local food production Scheme on the populations health. across the Borough. Policy P20 relates to the provision of open space and outdoor recreation and sport facilities.

10.5.2 page 90 The assessment states displacement or possible It is estimated that the Proposed loss of approximately 20 jobs within the study Scheme would result in the area, but does not take into account the disruption displacement or possible loss of a total to an already congested traffic area and difficulty of around 20 jobs within this study in transport around it. If premises are moved this area. could lead to further job loss if new sites are inaccessible to staff or customers, leading to a reduced customer base and possibly closure of the business and unemployment if the relocated premises are inappropriate.

The cumulative effect over all Warwickshire affected areas from job losses are examined at the end of this response.

11.5.5 page 93 While it is positive to see that further work Further work is being undertaken to regarding the effect of noise is being undertaken, confirm significant construction noise it is unclear whether this includes any work to and vibration effects, including any examine the health effects from the construction temporary effects from construction noise and vibration for the local community. A traffic. health impact assessment is recommended.

11.6.4 page 94 Residential receptors have been identified as Residential receptors within the having a significant adverse effect from day and

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Community Forum Area report 24 – WCC comment/observation Birmingham Interchange and Health Chelmsley Wood daytime 65dB contour, and therefore night HS2 noise. Although Noise Insulation the night-time 55dB contour, have been Regulations and WHO Night Noise Guidelines are identified as being likely to experience being used, we would recommend that target a significant adverse effect from the noise levels be aimed below this threshold to Proposed Scheme alone. reduce the health and wellbeing effects on residents in this area.

11.6.7 – 11.6.10 page 94 During the further assessment of the effects of Noise pollution noise for the formal ES, it is recommended that the health implications are also considered and a health impact assessment is recommended.

11.6.11 page 94 Although it is stated that the envisaged mitigates The envisaged mitigation (especially will substantially reduce the potential airborne landscape earthworks and noise sounds, it is not stated or clear how reduced the barriers) described in this chapter noises will and whether the noise levels will substantially reduces the potential therefore fall below the permitted noise level. airborne sound impacts and noise effects that would otherwise arise from the Proposed Scheme.

Nonetheless, potential significant Noise disturbance has multiple negative effects adverse airborne noise effects have on the health and wellbeing of individuals, been identified for residential receptors particularly concerning mental health and the effects of sleep disturbance. Additional detail is 11.6.13 page 95 needed on the effectiveness of the envisaged It is estimated that one dwelling – mitigates and what measures are going to be marked as SV24-01 on Map SV-01 – taken in specific relation to the community would potentially experience noise identified as SV24-01 on map SV-01-53, who will levels higher than the insulation trigger experience noise exceeding day and night time level. targets during construction and on a long term basis from railway operation, in order to minimise the health effects.

It is recommended that monitoring of noise at this site continue during construction and after completion.

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Waste and mineral resources:

Document Reference WCC comment/ observation Ladbroke and Southam Waste

Para. 2.3.7 The draft ES does not provide detail on how much excavated material is likely to “Bored tunnelling and directly associated arise at the sub-national/CFA level. It is activities (such as removal of excavated therefore impossible to derive numbers material)…would be carried out on a 24 of potential lorry movements, or end hour day, 7 day week basis.” destinations of material. WCC would strongly recommend that HS2 makes a binding commitment to stockpiling material and removing during normal working hours only, with approvals outside these hours given only in exceptional circumstances and where there is an overriding and demonstrated need. This would help to reduce or mitigate adverse environmental impacts as far as possible during the construction phase. Page 25, Para. 2.3.34: The lack of detail on excavated material arisings at the sub-national/CFA level “Wherever reasonably practicable means that it is impossible to determine excavated material would be moved how much excavated material could be directly from the area of excavation to used ‘on-site’ as part of the works (which areas of the works where fill material is could be located some distance from required.” where the material arises), or how much would be transported to appropriate disposal facilities ‘off-site’. As the ES does not provide potential volumes or destinations, the ES has not taken into account the potential environmental impacts (direct, indirect or cumulative) of transporting such material. WCC strongly recommends that further detail is provided on this to ensure that these impacts are fully considered to ensure that the final ES is fit for purpose.

“Some processing and temporary Similarly, the lack of detail on material to stockpiling of fill material may be be processed or stockpiled, or the necessary if direct placement into the potential locations for this, means that

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Document Reference WCC comment/ observation Ladbroke and Southam Waste permanent works is not possible. Some the draft ES has not adequately material may require crushing and/or assessed the potential environmental screening to render it acceptable for use impacts. Again, WCC strongly elsewhere.” recommends that further detail is provided on this to ensure that these impacts are fully considered to ensure that the final ES is fit for purpose. Page 26, para. 2.3.35

“If a shortfall of fill material arises in this WCC strongly recommends that any section of the Proposed Scheme, where potential surpluses or shortfalls of reasonably practicable, materials would material are quantified at the sub- be imported from surpluses generated on national/CFA level so that the other sections of the Proposed Scheme. environmental impacts of transporting Where this is not possible due to the and managing imported or exported material being unsuitable, or the benefits material can be adequately assessed of importing material are outweighed by through the ES. This will ensure that the the impacts of transportation, local ES is sufficiently robust and fit for sources of material would be identified.” purpose.

Page 33, para. 2.7 WCC would question how the environmental impacts of the scheme can have been appropriately assessed when there are alternative proposals still to be considered. WCC would strongly recommend that the environmental impacts of all potential options are thoroughly assessed and consulted on before the ES is finalised. Not doing so would undermine the validity and value of the consultation process, particularly when there is so much detail to be finalised.

Page 50, para. 5.5.16 Without an appraisal of in-combination effects relating to amenity, the ES is not “The incidence of significant effects fit for purpose. WCC strongly including in-combination effects on recommends that all potential impacts community amenity will be assessed in are assessed, with appropriate the formal ES.” consultation with all affected parties as necessary. Page 50, para. 5.5.18 A75

Document Reference WCC comment/ observation Ladbroke and Southam Waste

“Multiple (in combination) community effects will be considered and where significant reported in the formal ES.”

Page 67, para. 8.2.2 Adopted Policy M5 states that WCC will seek to ensure the winning of proven and “The Minerals Local Plan for potentially workable minerals prior to the Warwickshire aims to safeguard parcels implementation of development which of land where there are mineral would otherwise sterilise them. As WCC resources of economic or conservation has raised this issue previously and value (Policies M1 and M5). supplied Minerals Safeguard Area information to HS2, WCC expects to see an assessment that examines whether prior extraction of the mineral in advance of the development is “practicable and environmentally feasible” (para. 143, NPPF). Para. 2.3.35 above implies that surpluses of excavated material could be used for restoration purposes, so the practicability and environmental feasibility of prior extraction should be given full consideration. In this CFA area, it appears that cement raw materials including Rugby Limestone Member (mudstone/limestone interbedded - Lower Lias) and Langport Member (limestone - White Lias), which are currently used in the cement manufacture process at Rugby Cement Works, could be potentially sterilised.

The Minerals Development Framework For clarification, WCC consulted on its (MDF) Core Strategy is currently in Minerals Core Strategy Revised Spatial development; nothing has been Options in February 2009. Due weight published to date.” will need to be given to the policies and proposals of the emerging Minerals Development Framework, over and above the adopted Minerals Local Plan policies.

Page 71, para. 8.5.12 WCC considers the potential adverse A76

Document Reference WCC comment/ observation Ladbroke and Southam Waste

impact upon the Cement Raw Materials “There is a potential moderate adverse MSA to be of “high” significance rather impact on the cement raw materials than “moderate”. The geology in the area MSA. The effect is considered not to be is unique - the Southam Quarry provides significant but pre-extraction of these materials for Rugby Cement Works, resources would reduce the impact.” which is of national importance. WCC strongly recommends that an assessment is undertaken to look at the practicability and environmental feasibility of prior extraction. This would prevent the sterilisation of these potentially very important mineral resources for posterity.

Page 94, para. 12.5.5 The potential highway impacts arising from the final construction strategy may “Given that the construction strategy is give rise to significant environmental still developing, the assessment has yet impacts. WCC strongly recommends that to take any detailed phasing implications these impacts are adequately assessed or capacity assessments at individual and consulted on so that the most junctions into account.” appropriate strategy with the least environmental impacts can be implemented.

Document Reference WCC comment/ observation Ladbroke and Southam Waste

2.3.12 The adjacent areas would be used for WCC requests clarification as to whether the temporary storage of any topsoil these approvals would be given by the stripped as part of the works. A material County Council (as the Waste Planning reprocessing facility would also be Authority) under the proposed planning located within the construction site regime. compounds for recycling demolition materials and aggregates for reuse (crushing, screening and grading plants).

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Document Reference WCC comment/ observation Ladbroke and Southam Waste

2.3.33 During design development The lack of detail on material to be consideration has been given to the excavated and used on site, or moved for movement of materials. Wherever processing/stockpiling, or the potential possible excavated material would be locations for this, means that the draft ES moved directly from the area of has not adequately assessed the excavation to areas of the works where potential environmental impacts. Again, fill material is required. Some processing WCC strongly recommends that further and temporary stockpiling of fill material detail is provided on this to ensure that may be necessary if direct placement all impacts are fully considered to ensure into the permanent works is not possible. that the final ES is fit for purpose. Some material may require crushing and/or screening to render it acceptable for use elsewhere.

5.6.2 Again, without an appraisal of in- The assessment will draw upon other combination effects relating to amenity, technical disciplines (e. g. air quality, the ES is not fit for purpose. WCC noise and vibration, visual, transport and strongly recommends that detailed traffic findings to inform the amenity analysis is undertaken at the local level assessment. The presence of in‑ so that all potential impacts are combination impacts from these other adequately assessed, with appropriate disciplines could result in significant consultation with all affected parties as amenity effects on a number of necessary. community facilities and resources in the area. This will be reported in the formal ES.” Page 56, section 7.5 – Ecology during The draft ES does not consider the construction potential environmental benefits that may arise from using waste materials for uses such as quarry restoration. Warwickshire is host to a number of former quarries that have experienced a shortage of material to restore sites to the agreed restoration. Minerals sites are unique in that very few other land-uses can offer opportunities for large, species-rich wildlife sites (e.g. grasslands, wetlands, secondary woodlands etc.). WCC strongly recommends that mineral operators of such sites are contacted to discuss opportunities for using the A78

Document Reference WCC comment/ observation Ladbroke and Southam Waste

material to confer ecological benefit, particularly if the extant restoration schemes are now undeliverable. As the Mineral Planning Authority, WCC is happy to engage in these discussions.

Page 61 para. 8.48 Historic landfill information will need to be checked with the Environment Agency. “The Offchurch Greenway is set within a However, our records show that although disused railway cutting which was details for the ‘Disused Railway Cutting’ partially filled with waste. Efforts to find site (HLD_Ref: EAHLD31500) are records of the types of wastes deposited unknown (which crosses the route), the and the dates of infilling are on-going.” infilling of the ‘Offchurch Cutting’ immediately adjoining the site to the east (ref: EAHLD28783) was with ‘Licence application point 5: domestic refuse, non- toxic trade, builders waste, top soil and sub soil’. First inputs appear to be in Dec 1970, with the last licence issued in June 1977.

Page 64, para. 8.5.16 WCC strongly disagrees that the impact on the sand and gravel MSA would be “There would be a minor adverse impact “not significant”, particularly when the on the coal and sand and gravel MSAs. sand and gravel deposit appears to The effect is assessed as not significant stretch for 4km north of the Offchurch because there would only be a partial cutting. Taking 300m either side of the loss or severance of a large local route, this equates to approx. 920,000m2 reserve.” of sand and gravel resource that may potentially be sterilised. Warwickshire’s Para 8.5.17 sand and gravel landbank is currently only 3 years, well below the required 7 “A plan would be discussed in advance year (minimum) landbank. To prevent the of the construction works with the unnecessary sterilisation of the resource landowner and WCC to ensure effective for posterity, WCC expects to see an management of minerals in these assessment that examines whether prior locations. Extraction of all or part of the extraction of the mineral in advance of resources would reduce the impact.” the development is “practicable and environmentally feasible” (para. 143, NPPF). WCC would expect borehole evidence to be used as part of the assessment to provide an indication of

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Document Reference WCC comment/ observation Ladbroke and Southam Waste

quality and depth of the deposit, particularly when such areas may be considered as borrow pits.

Page 65, para. 9.2.4 Please note that the 2011 version of the Sub-regional GI Strategy by LUC “Reference is made in adopted and consultants has now been superseded emerging policy to the Warwickshire by a 2013 consultation version. The Landscape Guidelines (1993) and the documentation can be viewed using the Warwickshire, Coventry and Solihull Sub- link below. Please contact WCC Regional Green Infrastructure Study Ecological Services on 01926 41 8076 (July 2011).” for further information.

Sub-regional Green Infrastructure Strategy and Biodiversity Offsetting (Feb 2013-Apr 2013)

Visual and Landscape Impacts – pages The final ES needs to provide a more 65-77 detailed justification as to why the sensitivity/magnitude of impacts at the sites listed have been considered as “high”, or the level of impact to visual receptors is “major adverse”. This will ensure that that any method of mitigation is appropriate and adequately justified.

Page 74, para. 9.6.9 WCC considers that producing only 2 photomontages for this section of route is “Photomontages have been produced inadequate. Furthermore, there is illustrating the view of the Proposed insufficient justification as to why these Scheme during operation year 1 from locations have been chosen. Instead, viewpoints 249.2.003 at Bunkers Hill multiple photomontages should be Cottage (figure LV-12-49), 253.2.001 at produced for the principal/sensitive views Valley Fields (figure LV-12-50) and of the route so that the visual and 259.3.009 on PRoW W130b (figure LV- landscape impacts can be adequately 12-51).” assessed as part of the final ES. This will ensure that the most appropriate forms of mitigation are taken forward.

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Document Reference WCC comment/ observation Stoneleigh, Kenilworth and Burton Waste Green

Para. 2.1.24 The saved policies of the For clarification, the saved Warwickshire Warwickshire Structure Plan5; the saved Structure Plan policies were formally policies of the Warwick District Local revoked by Statutory Order SI 2013/933. Plan (WDLP) 20076; the saved policies This was laid in Parliament on 24th April of the Solihull Unitary Development Plan 2013 and came into effect on 20th May (SUDP) 20067; and the saved policies of 2013. the City of Coventry UDP 2001 form the current adopted development plan for the area. Para. 8.4.15 A MSA for deep coal Production at Daw Mill has ceased and extends from Burton Green to the north the future of deep mining within of the route section. An application has Warwickshire is currently unknown. been submitted to the Coal Authority by Notwithstanding, the section of route Daw Mills Colliery, located to the east of does fall within the County’s deep coal Coleshill, to extend the area covered by MSA and there is the potential for coal their extraction licence as far south as related activity at some stage in the Burton Green, encompassing the future. The BGS report ‘Minerals northern extent of the study area. Safeguarding Areas for Warwickshire’ (2009) identifies that important structures where absolutely no subsidence or tilting is allowed to occur (such as high speed railways) may sterilise the coal beneath it, as a pillar of coal must be left to prevent subsidence. The report states that for such high precision industries, this may sterilise an area of up to 500m from the edge of the resource (or in this case, 500m either side of the route). WCC requests that HS2 holds joint discussions with the Coal Authority, relevant coal operators (such as UK Coal) and WCC (as the Mineral Planning Authority) so that the potential sterilisation impacts can be assessed and any measures to reduce sterilisation are investigated.

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Document Reference WCC comment/ observation Birmingham Interchange Waste

Although the site is referenced, the draft ES does not consider the specific environmental impacts of the project on all waste activities at the Packington site operated by Sita UK. There are numerous waste operations at the site. The western boundary of the permitted landfill area lies approx. 210m east of the proposed route but the safeguarding area appears to adjoin the permitted area of the site. The landfill currently provides 525,000 tpa of non-hazardous waste management capacity, the highest of any waste management site in the County and there is additional capacity for wood shredding facility (processing up to 45,000tpa), composting site (60,000tpa), wood waste recovery (104,000tpa) and anaerobic digestion (50,00tpa). It is understood that the road leading to the access into the landfill is intended to be remodelled and a new access is likely to be required. The associated highway works to A446 may also encroach upon the surface water lagoon in the landfill. The potential environmental impacts of the route upon these waste management operations do not appear to have been assessed in any great detail and further analysis should be provided in the final ES.

It should also be noted that the whole Packington site was allocated as a Materials Recovery Facility in the Waste Local Plan (1999). This allocation remains until the Waste Core Strategy is formally adopted. The Packington site is therefore a waste management site of strategic importance for the County (and

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Document Reference WCC comment/ observation Birmingham Interchange Waste

arguably the region) and delivers a significant proportion of the County’s waste management/treatment capacity.

The Council requires that all operational or permitted waste sites are recognised as part of the environmental impact assessment process and that any impacts from HS2 are reduced to the fullest extent possible or are appropriately mitigated to ensure their continued operation. This would be in accordance with Policy CS8 (Safeguarding of Waste Management Sites) of the Warwickshire Waste Core Strategy. This policy is likely to be adopted as part of the statutory development plan on 9th July 2013.

A large section of the route in this CFA appears to be underlain by sand and gravel. To prevent the unnecessary sterilisation of the resource for posterity, WCC (as a Minerals Planning Authority) expects to see an assessment that examines whether prior extraction of the mineral in advance of the development is “practicable and environmentally feasible” (para. 143, NPPF). WCC would expect borehole evidence to be used as part of the assessment to provide an indication of quality and depth of the deposit, particularly when such areas may be considered as borrow pits.

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Document reference WCC comment/ observation Coleshill Junction Waste

8.2.5 A large section of the route in this CFA The emerging SMBC Local Plan Policy appears to be underlain by sand and P10: Natural Environment maintains gravel. WCC strongly disagrees that similar protection of geological assets as there would be a minor adverse impact the adopted UDP. Policy M13 identifies upon the sand and gravel resource. To and protects minerals safeguarding prevent the unnecessary sterilisation of areas, none of which are within the study the resource for posterity, WCC (as a area. There are no proposed policies that Minerals Planning Authority) expects to relate directly to contamination. see an assessment that examines whether prior extraction of the mineral in 8.3.3 advance of the development is Engagement is being undertaken with “practicable and environmentally NWBC and SMBC regarding land feasible” (para. 143, NPPF). WCC would contamination and with WCC regarding expect borehole evidence to be used as mineral resources. part of the assessment to provide an indication of quality and depth of the 8.5.19 deposit, particularly when such areas There is a potential minor adverse impact may be considered as borrow pits. This on the sand and gravel and building is particularly important given that most stone MSAs. The effect is assessed as MPAs along the route are unable to meet not significant because there would only the minimum 7 year sand and gravel be slight sterilisation or severance of the landbank, as required in the NPPF large local reserves. (Warwickshire’s is currently around 3 years). Every effort should therefore be made to extract the mineral in advance of the development in order to prevent the sterilisation of the resource for posterity. This approach would accord with the adopted development plan policies for both Warwickshire County Council and Solihull Metropolitan Borough Council.

8.4.11 Although the site is referenced, the draft Current potentially contaminative land ES does not consider the specific uses include: environmental impacts of the project on • Coleshill Sewage Works (map CT‑03- Coleshill Sewage Treatment Works 55, A6). operated by Severn Trent Water Ltd. The existing works currently provides approx. 12,000 tonnes per annum of biological treatment capacity for the County. Part of the site is also permitted for thermal treatment of sewage sludge and lies

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Document reference WCC comment/ observation Coleshill Junction Waste

approx. 20m east of the proposed route and therefore falls within the safeguard area, with the route also intersecting the intended access road. WCC requests that the environmental impacts of the proposal upon this waste management are fully considered through the Environmental Statement. Any impacts from HS2 upon the site must be reduced to the fullest extent possible and/or appropriately mitigated to ensure their continued operation. This would be in accordance with Policy CS8 (Safeguarding of Waste Management Sites) of the Warwickshire Waste Core Strategy, which is due to be adopted as part of the statutory development plan on 9th July 2013.

Section 12: Transport and Traffic Assessments

The following comments are pertinent to all 5 the community forum areas in Warwickshire:

CFA sections and paragraphs WCC comments/observation. Traffic 12.3 Assessment scope and key assessments

‘The scope of this assessment has been This statement and variations of it is discussed and agreed with the relevant strictly not correct at the time of printing highway authority’. the Draft ES as WCC has only agreed that a Transport Assessment is required and not the scope within.

Accident intervention levels of 9 in 3 Local intervention level for a cluster site years. is 6 in 3 years and for route consideration accs/km are applied. WCC request that the intervention level is lowered and analysis of route issues considered. The

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CFA sections and paragraphs WCC comments/observation. Traffic final analysis of accidents risk at a junction or route is based solely on the assumed rise in construction traffic of which no predicted accident modelling has been referred to make the statement robust. No account is made of type of junction, geometry, non-motorised user usage that will provide greater acceptance of this statement. Further it is unclear as to whether Haul routes and there interface with the major have been included in the assessment

The lack of supporting documentation Without an appropriate Transport Assessment detailing local traffic modelling forecasts, distribution, a true appreciation of the likely impacts of traffic associated with HS2 cannot be validated. Until we have seen the analysis of the impact of construction traffic on the local road network we reserve our position on whether capacity and/or safety improvements will be required to cope with construction traffic. WCC urges HS2 to share their analysis of the impact of construction traffic as soon as possible and before the full TA is published to allow time for comment and dialogue on this matter Compound sites Trip rates Likely vehicle trip rates is stated as two way peak hours trips whereas the table description flip flops in each report between referring daily and peak flow trips. In some cases trip rates do not tally. WCC therefore cannot agree the trip rates as stated, and require HS2 to clarify the matter.

Exclusions of proposed Haul routes WCC request that a more detailed appraisal of the impact of the haul routes and their interface with the adjoining highway is conducted. A86

CFA sections and paragraphs WCC comments/observation. Traffic

WCC expect the measures required to mitigate the haul routes are fully investigated.

WCC consider that many of these routes will be adversely affected by construction traffic.

A matter of concern is WCC’s involvement in the decision making process. Whilst HS2 will act as the overseeing organisation on the proposed highway mitigation measures, ultimately WCC we will inherit these changes, and any issues that may arise. We would therefore request that WCC has the opportunity to comment/agree on any proposals that propose to affect the highway e.g. Safety Audit responses, Departures from standards.

It is noted that proposals for bus service diversion will be included in the formal ES. WCC urges HS2 to share their proposals as soon as possible and before the full TA is published to allow time for comment and dialogue on this matter.

Community Forum Area Report 16 – WCC comments/ observation. Ladbroke to Southam Traffic 12.3 Environment Base line It is noted that proposals for bus service diversion will be included in the formal ES. WCC urges HS2 to share their proposals as soon as possible and before the full TA is published to allow time for comment and dialogue on this

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Community Forum Area Report 16 – WCC comments/ observation. Ladbroke to Southam Traffic matter Para 12.3.6 Says that there is no analysis of the impact on junctions during construction yet and this will be provided in the full TA yet Para 12.5.21 says there will be no problem since the junctions have sufficient capacity to cope with the construction traffic. Clearly these are conflicting statements.

12.3.7: The following key limitation exist Prior to a full assessment of impact is in the reporting of significant effects: As made, any comment or observation would yet only limited assessment has been be speculative. made of the impacts on public transport, although, at this stage it is not expected that demand generated by the operation of the Proposed Scheme would be sufficient to have a significant impact on existing public transport services in the area. The following Volume 1 criteria for construction and operational scenarios have not yet been assessed at this stage. Public transport delays. 12.4.4 Bus services between Bus services currently operating along Rugby/Daventry/Banbury and Leamington the B4451 and A425 are in the vicinity of via Southam and Harbury may be subject the proposed scheme. to delay or diversion during the construction phase

12.4.10 Not clear how a number of these junctions directly affect the Southam to Ladbroke section e.g. A4091 Tamworth Rd / Coleshill Street is in north Warwickshire over 40 miles away. For the avoidance of doubt to the general reader, junctions not included in this mapped section should be removed. 12.5.6 Overnight closures will not affect bus Temporary closures would be services. The duration of 'half day required…..to tie in new highway closures' is not defined and could lead to diversions with existing highways. AS temporary diversions and disruption to LISTED (half day/overnight closures) service.

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Community Forum Area Report 16 – WCC comments/ observation. Ladbroke to Southam Traffic 12.5.17 Bus service 503 no longer travels along Bus services which would be subject to B4451 Kineton Road. No mention is temporary diversion include the following: made of disruption to Home to School Bus route 503 on the B4451 Kineton transport to Southam College, Trinity Road. Bus routes 63,64,65 and 66 on School in Leamington and Warwickshire the A425 Leamington Road. College

12.5.18 Full implications, including any additional Details of bus diversion distances and resource requirements can be assessed durations will be included in the formal at that stage ES Haul routes

Map CT-05-081, Wills Pastures Road This is a single track rural highway that (D24240) will be serving a main construction compound, it is wholly unsuitable for two way movements. There is a poor interface with Banbury Road and will create a crossroads, which statistically in accident terms already performs poorly. WCC require further evidence of assurances and undertakings to be given to allay the safety concerns in the full ES

Map CT-05-083 Windmill Lane Single track rural highway that will be serving a Satellite compound, this is wholly unsuitable for two way movements. Concern with interface with Ladbroke by- pass with vehicles stationary turning right and approach speed of vehicles exceeding 65mph (85th%).

Map CT-05-087 Welsh Road Does not show full extent of haul route. (Cont in Offchurch to Cubbington section. This is both unhelpful and miss leading to the community and the County Council. The County expect this shortfall to be rectified in the full ES

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In addition to the generic comments made at the start of this section. The county considers these local issues to be worthy of further investigation and attention

Community Forum Area Report 16 – WCC comments/ observation. Ladbroke to Southam Traffic Para 12.3.6 It states that there is no analysis of the impact on junctions during construction yet and this will be provided in the full TA yet Para 12.5.22 says there will be no problem since the junctions have sufficient capacity to cope with the construction traffic. Clearly these are conflicting statements. 12.3.7 Prior to a full assessment of impact is The following key limitation exist in the made, any comment or observation reporting of significant effects: As yet would be speculative. only limited assessment has been made of the impacts on public transport, although, at this stage it is not expected that demand generated by the operation of the Proposed Scheme would be sufficient to have a significant impact on existing public transport services in the area. The following Volume 1 criteria for construction and operational scenarios have not yet been assessed at this stage. Public transport delays. 12.4.4 The bus service between Weston under The bus service currently operating along Wetherley and Leamington may be the B4453 Rugby Road is in the vicinity subject to delay or diversion during the of the proposed scheme. construction phase

12.5 Construction Trip rates of 560/day, this does not correlate to the figure in table 6 where 12.5.13 560 are anticipated alone in the peak hours. The county expects this anomaly and deficient statement to be addressed.

Fosse Way / Welsh Road junction has 12.4.10 been omitted yet it carries all construction related traffic. The county expects this anomaly and deficient statement to be addressed

There is no mention of the permanent A90

Community Forum Area Report 16 – WCC comments/ observation. Ladbroke to Southam Traffic closure of C91 Long Itchington Road, despite plans issued by HS2 in April 2013 suggestion this as a possible option. The county expects this anomaly and deficient statement to be addressed 12.5.6 Overnight closures will not affect bus Temporary closures would be services. The duration of 'half day required…..to tie in new highway closures' is not defined and could lead to diversions with existing highways. AS temporary diversions and disruption to LISTED (half day/overnight closures) service.

12.5.18 This will need an additional resource to The bus service 69, running along the maintain the current service level in B4453 Rugby Road, would be subject to Leamington. No mention is made of a temporary diversion and potentially disruption to Home to School transport to temporary increased journey times on North Leamington School, Trinity School this bus service. and Warwickshire College

12.5.19 Full implications, including any additional Details of bus diversion distances and resource requirements can be assessed durations will be included in the formal at that stage ES Haul Routes

Map CT-05-089, Welsh Road Welsh Road is not ideal in terms of width to support the potential number of movements of HGV’s/ WCC would request that mitigation measures and undertakings are agreed as a matter of urgency.

Priority at the Greenway/Welsh Road junction will need to be altered. WCC would request that this is included within the report and the proposals as foreseen.

New access created onto the B4455 serving a main compound and materials storage. WCC would request that it is comprehensively documented with the type of access clarified

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Community Forum Area Report 17 – WCC comments/ observation. Stoneleigh, Kenilworth and Burton Traffic Green Para 12.3.9 It states that there is no analysis of the impact on junctions during construction yet and this will be provided in the full TA yet Para 12.5.21 says there will be no problem since the junctions have sufficient capacity to cope with the construction traffic. Clearly these are conflicting statements.

12.3.10 Prior to a full assessment of impact is The following key limitation exist in the made, any comment or observation reporting of significant effects: As yet would be speculative. only limited assessment has been made of the impacts on public transport, although, at this stage it is not expected that demand generated by the operation of the Proposed Scheme would be sufficient to have a significant impact on existing public transport services in the area. The following Volume 1 criteria for construction and operational scenarios have not yet been assessed at this stage. Public transport delays. Para 12.5.5 – Closure of Dalehouse Lane for 12 months is unacceptable. 12.3.5 ……………”discussions are on- WCC would query the suggestion that going” “discussions are on-going,” it is the County’s view that in the field of transport assessment we are at a very tentative stage and we consider this a slightly misleading indication of our engagement.

12.3.6 As far as the County is aware no committed development (Coventry Gateway) has been assessed nor has local traffic modelling been used. Significant improvements have now been agreed in connection with Coventry Gateway which HS2 must take into consideration if it is not to significantly damage the highway network and the free movement of sub regional traffic

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Community Forum Area Report 17 – WCC comments/ observation. Stoneleigh, Kenilworth and Burton Traffic Green during the construction period

12.4.4 Bus services between Coventry, Bus services currently operating along Kenilworth, Leamington, Warwick and the A46, A429 Kenilworth Road, B4101 Stratford, together with local rural bus Waste Lane, B4115, Cromwell Lane and services may be subject to delay or Dalehouse Lane are in the vicinity of the diversion during the construction phase proposed scheme.

12.4.11 WCC would request that the junctions of Dalehouse Lane / Stoneleigh Road and A452/B4115 are comprehensively assessed and included in the full ES report. HS2 are urged to speak to the Transport Planning Group regarding junction assessment which should form part of the TA. 12.4.12…………….. 2041 base line WCC request that further information is scenario provided in support of this statement. Past WCC assessments believe that a number of junctions will reach capacity prior to 2041. The figure used in the draft ES is regarded as optimistic at best and possibly damaging to Warwickshire if used without further empirical analysis. 12.5.5 Overnight closures will not affect bus Temporary closures would be services. The duration of 'half day required…..to tie in new highway closures' is not defined and could lead to diversions with existing highways. AS temporary diversions and disruption to LISTED (half day/overnight closures) service.

12.5.7 This will require a permanent diversion to In addition to the temporary closures and services 84, 87 and 223 diversions, it is proposed to close the B4101 Waste Lane

12.5.12 …. 550 (total two way) vehicles This figure does not correlate with table per day 17 which refers to 550 trips/peak hr. WCC would require clarification and the report amended accordingly. 12.5.17 Bus services U15, 538 and 498 no longer Bus services which would be subject to run. Bus services 84 and 223 are temporary diversion include the following: additionally affected (Waste lane). No Bus route 548 on the B4115 Coventry mention is made of disruption to Home to A93

Community Forum Area Report 17 – WCC comments/ observation. Stoneleigh, Kenilworth and Burton Traffic Green Road, Bus Routes U12, 12, U2, 16, U17 School Transport to Kenilworth School. and X17 on the A429 Kenilworth Road, Bus Routes 498 and 538 on the B4101 Waste Lane, Bus routes X18, X15 and U15 on the A46, Bus routes X17, U17 and 539 on Dalehouse Lane, Bus route 87 on Cromwell Lane.

12.5.18 Full implications, including any additional Details of bus diversion distances and resource requirements can be assessed durations will be included in the formal at that stage ES

Haul Routes

CT-05-095 WCC has concerns over safety at the junction of Birmingham/ B4115 which triggers local intervention levels for accidents (6 in 3 yrs. Clarity sought over proposed routing of construction vehicles to allay fears of increased traffic through this junction. CT-05-097 Cryfield Grange Road – Single track rural road for the most part and unsuitable for two way movement, which will require mitigation measures to support the expected increased traffic arising from the satellite compound situated at the junction of Crackely Lane.

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Community Forum Area Report 19 – WCC comments/ observation. Coleshill Traffic Para 12.3.6 says that there is no analysis of the impact on junctions during construction yet and this will be provided in the full TA yet Para 12.5.21 says there will be no problem since the junctions have sufficient capacity to cope with the construction traffic. Clearly these are conflicting statements.

12.3.7 Prior to a full assessment of impact is The following key limitation exist in the made, any comment or observation would reporting of significant effects: As yet be speculative. only limited assessment has been made of the impacts on public transport, although, at this stage it is not expected that demand generated by the operation of the Proposed Scheme would be sufficient to have a significant impact on existing public transport services in the area. The following Volume 1 criteria for construction and operational scenarios have not yet been assessed at this stage. Public transport delays. 12.4.4Bus services currently operating Bus services between Coleshill and along the B4117 and Coleshill Heath Birmingham Airport via Chelmsley Wood Road are in the vicinity of the proposed may be subject to delay or diversion scheme. during the construction phase

12.5.6 Overnight closures will not affect bus Temporary closures would be services. The duration of 'half day required…..to tie in new highway closures' is not defined and could lead to diversions with existing highways. AS temporary diversions and disruption to LISTED (lane closures/traffic service. management/half day/overnight closures)

12.5.12…. 20% higher flows in the first Have these higher figures been used in three years capacity assessments at the junction named in Sections 12.4.10. This statement needs to be clearly and concisely referenced in Table 16. 12.5.17Bus services which would be No mention is made of disruption to subject to temporary diversion include Home to School Transport to Coleshill the following: Bus route 223 on the School. B4117 Gilson Road, Bus routes 777 and 90 on the Coleshill Heath Road.

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Community Forum Area Report 19 – WCC comments/ observation. Coleshill Traffic 12.5.18 Full implications, including any additional Details of bus diversion distances and resource requirements can be assessed durations will be included in the formal at that stage ES 12.5.22 WCC would query this brief assumption which bases numbers over a distance . As highlighted earlier accs/km should be used which will enable assessment whether this figure demonstrates an above accident rate for the type or class of road. Notwithstanding this is a HA matter, the county consider this is a wholly inadequate assessment methodology which will require a more robust appreciation before we are satisfied with the initial conclusion. 12.6.1 WCC questions the statement in para 12.6.1. Given the potential for substantial trip generation associated with the interchange station it seems likely that mitigation on the local highway network will be required. Para 12.6.2 says an assessment of this will be carried out and WCC urges HS2 to share their analysis of this impact as soon as possible and before the full TA is published to allow time for comment and dialogue on this matter. Haul routes The proposals illustrate a right turn at the Gorsey Lane signal junction. WCC query CT-05-111 the acceptance of this in regards to the operational capacity of the junction, required land take for geometric alterations, and the associated safety arising from both. Further detail is required in the full ES and assurances of the safety of the HS2 proposal. CT-05-133 – Gilson Road Gilsons Drive is wholly unsuitable for two-way movements, it has a poor interface with Gilson Road. Damage to the highway despite some assurances by HS2 will occur as the current road construction is not designed for this

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Community Forum Area Report 19 – WCC comments/ observation. Coleshill Traffic weight and volume of traffic.

Community Forum Area Report 20 – WCC comments/ observation. Curdworth to Middleton Traffic

12.3.6. …..discussion are on-going Strictly, this statement is incorrect as proactive discussions are yet to commence. 12.3.7…. Use of Tempro WCC would request what version of the software was used. If the current version of 6.2 was not the base model, the County would expect further evaluation to be done 12.3.8…. Committed development The statement without identifying which committed development has been analysed is worthless and wholly inadequate for a project of this scale.

The County requires quality baseline figures and robust data to make an assessment. It does not consider qualitative words an acceptable alternative.

12.3.11 Prior to a full assessment of impact is The following key limitation exist in the made, any comment or observation reporting of significant effects: As yet would be speculative. only limited assessment has been made of the impacts on public transport, although, at this stage it is not expected that demand generated by the operation of the Proposed Scheme would be sufficient to have a significant impact on existing public transport services in the area. The following Volume 1 criteria for construction and operational scenarios have not yet been assessed at this stage. Public transport delays.

12.4.4 Bus services between Bus services currently operating along Birmingham/Coleshill and Tamworth via the A4097 Kingsbury Road are in the Kingsbury may be subject to delay or vicinity of the proposed scheme. diversion during the construction phase

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Community Forum Area Report 20 – WCC comments/ observation. Curdworth to Middleton Traffic

12.5.7 Overnight closures will not affect bus Temporary closures would be services. The duration of 'half day required…..to tie in new highway closures' is not defined and could lead to diversions with existing highways. temporary diversions and disruption to service. 12.5.18 No mention is made of disruption to The bus services 115 and 118 running Home to School Transport to Kingsbury along the A4097 Kingsbury Road would School. be subject to temporary diversion

12.5.19 Full implications, including any additional Details of bus diversion distances and resource requirements can be assessed durations will be included in the formal at that stage ES 12.5.22 .. It is not expected that the With 13 accidents in 3 years recorded at increase in traffic flows on major roads is the junction, the statement needs to be likely to increase accident risk. more evidence led than just considered against a rise in trip rates.

WCC does not and cannot support this basic conclusion. Please see previous comment. 12.6.1 WCC questions the statement in para 12.6.1. Given the potential for substantial trip generation associated with the nearby interchange station it seems likely that mitigation on the local highway network will be required. WCC urges HS2 to share their analysis of this impact as soon as possible and before the full TA is published to allow time for comment and dialogue on this matter. Haul Routes CT-05-112 The main compound identified here is in excess of 2km in length and covers a vast expanse. WCC would query the traffic figures of 564 given the area it covers and the lack of clarity in the draft ES as to the nature of the number.

WCC is highly sceptical over why this area far exceeds that of any other main compound. The implication is that having acquired the land it will be prime A98

Community Forum Area Report 20 – WCC comments/ observation. Curdworth to Middleton Traffic

for future development which maybe contrary to the planning policies of North Warwickshire Borough Council. Vehicle access to the land is currently unclear. Detailed clarification is sought in each regard before the Council is in a position to with draw its objection. CT-05-119 Marston lane There is poor interface with highway considering it will serve a main compound. Alterations will be required to the access to cater for the any growth. Without verified traffic data it is impossible to be satisfied that access to the highway can a be safely maintained CT-06-112 The intention here is to replicate and offset the existing roundabout providing access to Hams Hall. Given the accident rate which is partly explained by the poor geometry of the roundabout. We would question the rationale of re-providing a junction type where the evidence has proven to make no contribution to improving traffic safety.

In comparison the signal junction at Gorsey Lane performs significantly better in accident terms and which takes comparative flows. CT-05-113 Cuttle Mill Lane Single track road wholly unsuitable for increased two-way traffic flows. Greater detail is required in the Full ES

CT-05-113-02 Single track road is wholly unsuitable for increased two-way traffic flows, especially through the residential area. The Highway terminates part way along Seeney lane. It is not clear at this stage how HS2 will overcome the private land ownership and how the road will be tied into the highway. CT-05-114 Brick Kiln Lane This is not suitable for two way movements of the size of vehicles A99

Community Forum Area Report 20 – WCC comments/ observation. Curdworth to Middleton Traffic

proposed. CT-05-115 Church Lane Road is not ideal to support construction vehicles however of greater concern is the potential for vehicles turning right from the central reserve which has Accounted for a number of accidents in recent years. WCC requires that highway mitigation works are considered at this point.

Community forum Area Report 24- WCC comment/ observation Birmingham Interchange Traffic

12.3.8 Prior to a full assessment of impact is The following key limitation exist in the made, any comment or observation reporting of significant effects: As yet would be speculative. only limited assessment has been made of the impacts on public transport, although, at this stage it is not expected that demand generated by the operation of the Proposed Scheme would be sufficient to have a significant impact on existing public transport services in the area. The following Volume 1 criteria for construction and operational scenarios have not yet been assessed at this stage. Public transport delays. 12.4.7 These bus services do not directly serve There are two public bus services that communities in Warwickshire. pass through the Middle Bickenhill area. The bus services provide connections to Birmingham, Coventry, Meriden, Solihull, Coleshill and Birmingham Airport

12.4.8 These bus services do not directly serve The area covering the Birmingham communities in Warwickshire. International Railway Station, NEC and Birmingham Airport is served by eight public bus services. The bus services provide connections to Coventry, Solihull, Chelmsley Wood, Marston Green, Erdington, Birmingham Business Park and Blythe Valley Business Park.

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12.4.9 These bus services do not directly serve The southern area of Chelmsley Wood is communities in Warwickshire. served by six public bus services. These bus services provide connections to Coventry, Solihull, Chelmsley Wood, Marston Green, Erdington and Birmingham Airport.

Conclusion Throughout the Draft ES there is evidence of inconsistency, omission of basic detail and factual errors which render the report almost useless. One of the primary purposes of an ES, or a Draft ES is to assure the affected communities that due care and attention has been undertaken to protect their environment from the development. This document falls short of that purpose.

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