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1 Highways England's Response SLOUGH BOROUGH COUNCIL LOCAL IMPACT REPORTS HIGHWAYS ENGLAND'S RESPONSE 1. INTRODUCTION 1.1 This Local Impact Report sets out the preliminary position of Slough Borough Council (SBC) in relation to the issues of concern in the Borough arising from the M4 Smart Motorway Scheme (referred to as ‘the Scheme’). The report also responds to the First Written Questions of the Examining Authority (ExA) where relevant to Slough. 1.2 Slough is a compact densely built-up Borough with a population of some 143,000. The M4 fringes the southern edge of the town and runs approximately parallel to the A4, the historic route between London and Bath. Three motorway junctions serve Slough: (a) Junction 7 linking with the A4 via the Huntercombe Spur; (b) Junction 6 linking with the A355 which connects southwards with Windsor and northwards with Slough Trading Estate, South Buckinghamshire and the M40; and (c) Junction 5, the Langley Interchange, linking with the A4 and giving access to Heathrow and Slough town centre. 1.3 Between Junctions 7 and 6 the M4 runs close to residential areas and public open space at Cippenham. East of Junction 6 the motorway fringes residential areas and school grounds at Chalvey and Herschel Park. East of Junction 5 it severs the built up area, with Langley to the north and Brands Hill to the south. Air quality, noise and visual amenity are major concerns and Slough Borough Council (SBC) is anxious to protect its residents and others from negative impacts arising from the Smart Motorway scheme. 1.4 Because of its proximity to London, Heathrow and the M25, and being home to the extensive Slough Trading Estate, the Borough experiences high levels of traffic. Traffic leaving or joining the M4 at Slough regularly causes queuing and congestion on the local road network during peak periods. Occasionally, heavy congestion or an incident on the M4 can bring traffic in Slough to a virtual standstill as drivers divert off the motorway. SBC notes from the Socio-Economic Report (2.1.1 APP- 090) that the M4 typically carries over 130,000 vehicles per day and that this is forecast to increase to an average 160,000 vehicles per day over the next 20 years. Unless properly managed, this additional traffic could significantly increase pressures on the local road network. Deadline III - Response to Local Impact Reports 1 Highways England Highways England's Comment 1.4.1 Highways England notes Slough Borough Council’s concerns in respect of air quality, noise and visual amenity and the effects of the Scheme on its residents. Detailed responses to these issues are given under the respective sections below and demonstrate that there are no material adverse effects arising from the Scheme. 1.4.2 Highways England confirms that the M4 typically carries 130,000 vehicles a day and that it is expected that this will rise to an average 160,000 vehicles a day. This is the increase in traffic forecast to arise without the Scheme and is a reflection of national economic growth in general and the Thames Valley in particular. Highways England considers that the Scheme will play a major role in managing future traffic conditions in conjunction with the local authorities through their respective Local Transport Plans. 2. POLICY National Policy Statement for National Networks (NNNPS) 2.1 SBC takes particular note of those sections of the NNNPS that require HE to provide evidence that they have considered ‘reasonable opportunities to deliver environmental and social benefits’ as part of the Scheme (NPS para 3.3); and ‘use reasonable endeavours to address the needs of cyclists and pedestrians in the design of new schemes’ (NPS para. 3.17). Highways England's Comment 2.1.1 The opportunities provided by the Scheme to deliver environmental and social benefits have been considered by Highways England. The Socio-Economic Report (Application Document Reference 7-2) refers to a range of beneficial effects to be derived from construction of the Scheme (Paragraph 7.1.4), whilst Paragraph 7.1.6 of the Report highlights a number of mitigation measures proposed to ameliorate negative effects of the Scheme. The Engineering and Design Report (Application Document Reference 7-3) refers, in Paragraph 7.12.1 to various enhancement measures set-out in the accompanying Environmental Masterplan (Annex F to the Report), as suggested mitigation measures for the Scheme. 2.1.2 Chapter 13 (Effects on all Travellers) of the Environmental Statement (Application Document Reference 6-1) assessed the potential effects of the Scheme on vehicle travellers and non-motorised users (NMUs). The latter group includes pedestrians, cyclists, and equestrians. Paragraph 13.1.3 of the Deadline III - Response to Local Impact Reports 2 Highways England ES notes that NMUs are not permitted to use motorways for safety reasons, although it recognises that they may be affected by the Scheme when travelling on the locally adopted highway network and other Public Rights of Way (“PRoW”) surrounding or interacting with the Scheme. 2.1.3 The assessment undertaken within the Chapter focussed on the Scheme effects on pedestrians, cyclists, equestrians in relation to the impacts on PRoW. Paragraph 13.6.1 advises that proposed mitigation measures for NMUs during the Scheme’s construction phase will be managed and monitored pursuant to the CEMP (Appendix 4.2A of the ES) (Application Document Reference 6-3), which is secured by Requirement 8, Schedule 2 of the Draft DCO (Application Document Reference 3-1). Slough Local Plan 2.2 SBC confirms that Table 1 of APP-089 accurately identifies the Development Plan for Slough, i.e. (a) Slough Borough Council Local Plan (March 2004); (b) Saved Policies (September 2007); (c) Core Strategy; (d) Development Plan Document 2006-2026 (December 2008). 2.3 The Highways England (HE) Planning Statement refers to Core Policy 7 and SBC draws attention to the following wording: ‘Development proposals will, either individually or collectively, have to make appropriate provisions for.... improving air quality and reducing the impact of travel upon the environment, in particular climate change.’ 2.4 SBC also draws attention to Core Policy 8 which includes the wording: ‘Development shall not: a) Give rise to unacceptable levels of pollution including air pollution, dust, odour, artificial lighting or noise’. 2.5 Reference is correctly made in the HE Planning Statement (6-49) to the ‘Action Plan for Slough Air Quality Management Areas Nos. 3 and 4’, November 2012. However SBC wishes to make clear that the Action Plans for Air Quality Management Areas no. 1 (M4 corridor) and no. 2 (Brands Hill) were included in ‘Annex C of the Second Local Transport Plan, March 2006’ which superseded the provisional document of July 2005 referred to in 6-48. Furthermore, these action plans were revised and specific measures incorporated into the ‘Slough’s Third Local Transport Plan 2011- 2026’ (para 5.6.4.): see 2.8 below. Deadline III - Response to Local Impact Reports 3 Highways England Highways England's Comment 2.5.1 The provisional Air Quality Action Plans referred to within Appendix 6.5 of the ES (Application Document Reference 6-3) were replaced by ‘Annex C of the Second Local Transport Plan, March 2006’ and that this has subsequently been superseded by Slough’s Third Local Transport Plan 2011- 2026 (“LTP3”). 2.5.2 The LTP3, and in particular paragraph 5.6.4, has been reviewed. Paragraph 5.6.4 notes that to reduce levels of nitrogen dioxide (“NO2”) the following is necessary: “Reduce the number of vehicles on the road; Reduce the levels of emissions from vehicles per mile; and Reduce stop/start traffic conditions.” 2.5.3 The LTP3 notes, in paragraph 5.6.7, that sustainable land use planning policies will be key to achieving reductions in the numbers of vehicles on the road (i.e. bullet point 1 above). Paragraph 5.6.7 of LTP3 cross references key policies within the Local Development Framework ("LDF") concerning sustainable land use and air quality. The Scheme does not adversely impact upon any of the LDF policies identified in paragraph 5.6.7. 2.5.4 Other actions to reduce the number of vehicles on the road contained within LTP3 include managing “parking demand” (paragraph 5.6.14), “school and workplace travel plans” (paragraphs 5.6.15-5.6.16 and 5.6.20-5.6.21), and promoting walking and cycling (5.6.17-5.6.19). The Scheme does not adversely impact upon any of the LDF policies identified in the above paragraphs. 2.5.5 Reductions in levels of emissions from vehicles per mile is considered within LTP3 for “cleaner buses, taxis and commercial vehicles” (paragraphs 5.6.11-5.6.12) and “promoting less polluting travel” (paragraph 5.6.13). The Scheme does not adversely impact upon any of the LDF policies identified in paragraphs 5.6.11-5.6.13. 2.5.6 The LTP3 discusses better management of congestion and speed in paragraphs 5.6.8- 5.6.10. In paragraph 5.6.10, the A4 and junction 5 of the M4 is discussed and opportunities to work with the Highways Agency (now Highways England) concerning the junction and mainline M4 are identified. The implementation of the Scheme may assist in the management of traffic both at junction 5 and the mainline of the M4. Deadline III - Response to Local Impact Reports 4 Highways England 2.6 SBC’s comments on HE’s assessment of the project against these Core Strategy policies (APP- 089) are as follows: (a) Ref Planning Statement 5.4.25: summary description of proposals in Slough area is acknowledged but it excludes reference to construction compounds near Junctions 6 and
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