M20 Junction

M20 Junction 10a TR010006 Comments on Relevant Representations Revision A Planning Act 2008 Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Volume 10.7 January 2017

M20 Junction 10a

TR010006

Comments on Relevant Representations

Planning Act 2008 Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

Volume 10.7

Date: January 2017

Comments on Relevant Representations M20 Junction 10a TR010006

Issue and revision record

Revision Date Originator Checker Approver Description

A January 2017 Mott MacDonald Mott MacDonald Highways England DCO submission (deadline 3) Sweco Sweco AECOM

This document is issued for the party which commissioned it We accept no responsibility for the consequences of this and for specific purposes connected with the above-captioned document being relied upon by any other party, or being used project only. It should not be relied upon by any other party or for any other purpose, or containing any error or omission used for any other purpose. which is due to an error or omission in data supplied to us by other parties

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.

HA514442-MMGJV-GEN-SMW-RE-Z-10701 Revision A Comments on Relevant Representations M20 Junction 10a TR010006

Content

Chapter Title Page

Content 1

1. Applicant’s Comments on Relevant Representations 3 1.1 RR-001 ______3 1.2 RR-002 ______7 1.3 RR-003 ______26 1.4 RR-004 ______27 1.5 RR-005 ______29 1.6 RR-006 ______32 1.7 RR-007 ______33 1.8 RR-008 ______38 1.9 RR-009 ______39 1.10 RR-010 ______42 1.11 RR-011 ______44 1.12 RR-012 ______48 1.13 RR-013 ______50 1.14 RR-014 ______50 1.15 RR-015 ______51 1.16 RR-016 ______52 1.17 RR-017 ______55 1.18 RR-018 ______56 1.19 RR-019 ______62 1.20 RR-020 ______62 1.21 RR-021 ______64 1.22 RR-022 ______66 1.23 RR-023 ______67 1.24 RR-024 ______67 1.25 RR-025 ______69 1.26 RR-026 ______70 1.27 RR-027 ______80 1.28 RR-028 ______81 1.29 RR-029 ______83 1.30 RR-030 ______84 1.31 RR-031 ______84 1.32 RR-032 ______85 1.33 RR-033 ______88 1.34 RR-034 ______94 1.35 RR-035 ______95 1.36 RR-036 ______97 HA514442-MMGJV-GEN-SMW-RE-Z-10701 1 Revision A

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1.37 RR-037 ______100 1.38 RR-038 ______102 1.39 RR-039 ______102 1.40 RR-040 ______105 1.41 RR-041 ______105 1.42 RR-042 ______106 1.43 RR-043 ______108 1.44 RR-044 ______108 1.45 RR-045 ______111 1.46 OD-003 ______112

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1. Applicant’s Comments on Relevant Representations

1.1 RR-001 PINS Ref. Relevant Representation from Ashford Borough Council - Response from Highways England (the Applicant) RR-001 Affected Person 001.01 M20 Junction 10a Noted. Planning Inspectorate Reference TR010006 Representations by Ashford Borough Council on behalf of Head of Cultural, as landowner of Plot 3/14/a and Plot3/14/b and the proposed replacement land. The Borough Council recognises the importance and relevance of the proposed new junction. However, as owner of the land identified above, it is important that the scheme works for the local community and the Borough Council. Ashford Borough Council owns plots 3/14/a and 3/14/b. These plots form part of the public open space land at Church Road which is used for the purposes of public recreation and enjoyment. This land is also designated as a local nature reserve and forms part of the Ashford Green Corridor. The land at Church Road combines complementary wildlife habitats, such as dense scrub, trees and semi-natural grass areas; children’s play space, including the opportunity for informal pay in a safe and attractive space; visual quality to the immediate residential area, introducing a green element to the residential street environment; forming part of the Public Right Of Way and well used pedestrian route from South Willesborough to Sevington; providing a quiet and relaxing HA514442-MMGJV-GEN-SMW-RE-Z-10701 3 Revision A

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green space where people enjoy informal sport and contact with nature and fresh air.

001.02 Land to be Permanently Acquired from Ashford Borough There are ongoing discussions with Ashford Borough Council (ABC) to Council discuss maintenance access to existing open space. Plot3/14/b. In part 3 of the Statement of Reasons the description of the land being acquired concentrates on the vegetation cover and little else, without acknowledging the role this land plays in the ecological, social and the visual quality of the whole space of which it forms. Clarification is required over the extent of the permanent land being acquired; it is not clear from the plans and drawings. The acquisition of this plot and proposed profiling will obstruct the Borough Council’s maintenance access to the Recreation Ground at Church Lane, Sevington. This will be due to the introduction of a steep cutting along the access route and because the access route will permanently be removed from the Ashford Borough Council’s ownership. An alternative entrance will need to be constructed to enable Ashford Borough Council to access from Church Road to carry out maintenance of the retained public open space. There is no proposed clear demarcation between land being retained by Ashford Borough Council and the land being acquired by Highways England. Highways England to discuss with ABC their proposal for plot 3/4/a. 001.03 Land to be Temporarily Acquired from Ashford Borough Council Plot 3/14/a This small area should be permanently acquired by Highways England as it will be completely surrounded by HE land in future and cut off from the remaining public open space with no access for the Borough Council over its own land and no clear boundary demarcation. The steepness of proposed re- profiling of this plot will render it of little use to the public and HA514442-MMGJV-GEN-SMW-RE-Z-10701 4 Revision A

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difficult to maintain and less likely to sustain stable tree planting. It is unclear who will be responsible for maintaining the banked land. A substantial area of the land in question currently receives minimal maintenance in keeping with its designation as Local Nature Reserve and Green Corridor to encourage wildlife. It is unclear if the proposed changes in the profiling of the land will necessitate a higher standard of maintenance or of it will still be in keeping with Local Nature Reserve and Green Corridor status. It has been identified through the Relevant Representations that 001.04 Proposed Replacement Land to be given to Ashford Borough enhancement of the natural environment within and around Church Road Council by Highways England would be of benefit in terms of biodiversity value. Whilst the existing Plots 3/1/b, 3/1/c and 3/1/d proposals for replacement land are considered to have been cognisant of Clarification is sought over the extent of the proposed this, further design development could be undertaken to prioritise nature replacement land. The replacement land forms part of the conservation and maximise biodiversity benefits to the Ashford Green highway verge and is not of equal size to the land being Corridor. acquired. The available maps differ as to whether the cycleway is Further enhancements could also be made within the boundary of the included in the replacement land or not. The borough council existing Church Road Open Space. Opportunities exist to improve the is not responsible for the maintenance of highways and does current play provision and offer greater facilities. Currently there is a small not adopt highways standard cycleways, highway verge or playground for young children and beyond that there is an open playing field associated infrastructure because they are subject to highway with two goals and a vandalised shelter with seating. There is little diversity rights and obligations which are normally maintained by the with regards to planting, with trees and shrubs on the perimeter of the site. County Council. Dog fouling was prevalent on the playing field and litter was also evident. There is a lack of proposed demarcation (which is likely to Opportunities for play provision for older children, as well as making cause maintenance and liability issues), the land is improvements to the playing field facilitates would increase the pull of the surrounded by HE land and it is not easily identifiable as public site as a recreational asset, as well as there being potential to ecologically open space by the public and not easily accessible by Ashford enrich the area. Borough Council for maintenance purposes. The transfer of this land to the Borough Council will reduce the Potential proposals could include: - Provision of species rich grassland in appropriate locations of the site; efficiency with which it can be maintained and increase costs - A greater variety of planting to provide visual and biodiversity interest; to the public without bringing any additional public value. - Replacement or expansion of existing play equipment to serve a greater It is not appropriate for this replacement land to be subject to age range; and, the same rights, trusts and incidents as the Public Open HA514442-MMGJV-GEN-SMW-RE-Z-10701 5 Revision A

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Space being permanently acquired. The replacement land is - Provision of seating and or benches to provide a greater sense of not a like for like replacement in terms of public amenity, destination. landscape value or suitability as public open space or for inclusion in the existing Local Nature Reserve, which currently This item is being discussed between both parties and forms part of The includes plots 3/14/a and 3/14/b. Statement of Common Ground. The replacement land will be less advantageous to persons entitled to use the land given that it is highway verge and it is visually and physically severed from the exiting open space. Access to the replacement land from the existing open space is via a ramp going up and then down some stairs, which are not DDA compliant and is likely to adversely affect local people with mobility issues.

The replacement land is not suitable alternative land in exchange for the POS. In addition the replacement land does not meet the criteria for the inclusion in the Green Corridor due to its location and topography.

It would be more appropriate for Highways England to retain this piece of land together with the rest of the highway land which surrounds it.

There is reference to a new mini lighting column within the proposed land swap. It is not clear if this is to be maintained by Highways England, Ashford Borough Council or Kent County Council Highways who normally maintain public street lighting.

The Council has requested that Highways England look at alternative options such as other replacement land or the procedures under s131 (4A) PA 2008. The Council wishes to reserve its right to make further representations on these issues, given that negotiations are ongoing.

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1.2 RR-002 PINS Ref. Relevant Representation from Ashford Borough Council – Response from Highways England (the Applicant) RR-002 Local Authority 002.01 Overview Noted. 002.01a Ashford Borough Council considers there is a compelling need in principle for a new Junction 10a and A2070 link road to provide further capacity to facilitate residential and employment development within the Ashford growth area identified in its existing development plan documents

002.01b Ashford Borough Council also expects the scheme to avoid Mitigation for landscape and visual impacts has been incorporated into the and mitigate, environmental and social impacts in line with the Environmental Masterplan proposals (DCO Document 6.2, Figure 2.6f). principles set out in the NPPF and government planning The landscaping proposals include native hedges with intermittent trees, guidance. Good design should be an integral consideration of native tree planting and specimen trees along the length of the proposed the proposals and it must be as aesthetically sensitive as A2070 Link Road, which would provide visual screening of the Main and possible. Alternative Schemes and associated traffic and a strong vegetative northern boundary to the proposed Stour Park development area.

002.01c The need for additional motorway junction capacity to the We are happy that ABC agreed that there is a need for the Scheme. south-east of Ashford has been recognised since at least the turn of the century. The South of Ashford Transport Study (1999) highlighted that the limited available capacity at the existing Junction10 would mean that some development proposals in the then emerging Borough Local Plan 2000 would be unable to be fully built out unless a new ‘Junction 10a’ could be provided. Noted. 002.01d Since then, the council has adopted the Core Strategy (2008) which remains the principal Development Plan Document for the borough and the subsequent Urban Sites & Infrastructure DPD (2012). Both Documents place significant weight on the need for Junction 10a to be delivered in order for allocated

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sites to be built out. The council has also granted planning permission for several developments which rely to some degree on Junction 10a coming forward. Noted. 002.01e On 9 June 2016 the Council approved a consultation version of the emerging Local Plan to 2030. The relies on the delivery of Junction 10a to an even greater degree as it will be fundamental to the council’s ability to demonstrate the deliverability of key proposed site allocations for housing and employment development. Without this ability, the new Local Plan would be expected to be found unsound, or otherwise far less suitable sites elsewhere in the borough would be required to be allocated instead. Noted. 002.01f Ashford Borough Council has constructively worked with Highways England and our partners at Kent County Council from the pre-application stage. This has included meetings with Highways England and setting up a Junction 10a community group where Ashford Borough Council, Kent County Council and Highways England meet with local residents, parish councils and local members to discuss issues. This is expected to continue during the examination stage. Noted. 002.01g Whilst Ashford Borough Council supports the principle of the proposals it has set out detailed issues where there are still objections or concerns and where further changes need to be considered. In additional further information and plans are required in certain areas to fully understand the impacts of the proposals. Some of these were raised at the pre-application consultation stage.

002.02 Impact on public open space area in connection with works to Church Lane footbridge

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Ashford Borough Council objects to the proposals in their It is not believed that the play area will be affected directly by the Scheme. 002.02a current form as it impacts on existing public open space and The area affected by the works will be limited to areas immediately adjacent play area and at present acceptable mitigation measures have to the existing footbridge and access ramps. not been provided. The areas of the land designated as a LNR have been identified and will be returned to its original function following construction. The area of LNR The works at present are showing permanent and temporary habitat shall be equal to or greater than the original area. 002.02b acquisition of land forming part the Church Road Public Open Space area. This land also forms part of the Ashford Green Discussions are ongoing with ABC regarding the open space land. Corridor and is dedicated as a LNR. Highways England and Ashford Borough Council have been in An open space replacement strategy report was produced by Highways 002.02c discussion on this matter but this only came to light after the England and remains with ABC for consideration in order to inform formal pre-application consultation. At present there is no formal agreement regarding Statement of Common Grounds. A more detailed statement of common ground between the two parties. Ashford design drawing has been created to illustrate changes around the proposed Borough Council’s current position is outlined below. bridge and associated ramps and its relationship with existing adjacent landscape features. The plan includes two cross sections to aid information. This drawing also depicts access arrangements. 002.03 In response to the Statement of Reasons Vol.4 Ashford Borough Council agrees as shown on drawing number Noted. 002.03a HA514442-MMGJV-Gen-SMW-DE-Z-2204A with the measurements for plot 3/14b and 3/14a that 3/14b needs to be permanently acquired Ashford Borough Council considers that plot 3/14a should also Highways England to discuss with ABC their proposal for plot 3/14/a. 002.03b be permanently acquired as the necessary changes in level will permanently affect the accessibility of this land for members of It is not considered that there should be any adverse issues associated with the public and maintenance operations making it unsuitable for levels. Access to the proposed site will be sought either by steps, ramps or use as public open space. Further the necessity of building up alongside the ramp if accessing from the existing Church Road open space. levels to ensure a stable raised ramp will also entail the use of It is considered that Plot 3/14/a will be as accessible as the land which is fill which will hinder the establishment, survival and appearance lost. It is not considered that planting on fill material need be to the of amenity planting and will significantly and permanently detriment of successful plant establishment. Indeed, the existing made change the character of much of this land. ground forming the access ramps to the current Church Road footbridge is successfully planted. Ashford Borough Council objects to the proposed replacement Access to the proposed replacement land from the existing open space 002.03c land being given in exchange for the following reasons: area is via the side of the new ramp. If accessing from crossing Church Road Bridge from Sevington, access is either by steps or ramp directly from HA514442-MMGJV-GEN-SMW-RE-Z-10701 9 Revision A

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• It is visually and physically severed from the remaining the footway/cycleway located below the new Church Road Bridge. useable open space and has extremely low amenity potential 1. The severance between the open space is planned to be mitigated by being a linear strip beside the highway. the existing footpath being improved to create access between the areas without requiring steps. This will increase mobility into the existing open • Access to the replacement land from the existing open space space. via a ramp going up and then down some stairs, which are not 2. The proposed access between the existing open space and steps are not DDA compliant and is likely to adversely affect local people with required to be DDA compliant as there is a pathway which links the open mobility issues. spaces which will improve mobility and access to the existing open space. 3. The majority of the proposed trees selected are locally occurring and • The existing land is within the Ashford Green Corridors and is selected to provide ecological interest for native wildlife species. a LNR but the proposed replacement land is not of sufficient Furthermore, the area has not been designed at a detailed level and the wildlife potential to warrant it being part of the Ashford Green species can still be changed to whatever species mix the council desires. Corridor or LNR designation. These proposals are described in the Environmental Masterplan proposals (DCO Document 6.2, Figure 2.6f). Ashford Borough Council does not therefore accept that it is There is a substantial linear belt of shrubs and trees being provided which is 002.03d suitable for replacement land. Other possible replacement land in keeping with local native planting and that of other transient spaces within may be available which is more suitable for replacement land in the local green corridor network. Indeed, it will help to extend the green that it is suitable for inclusion in the LNR and of visual amenity corridor network for pedestrians and cyclists moving through the area. The value and accessibility at least equivalent to the land acquired. area of land lost as a LNR value is very small, and will be addressed with This land has been identified to Highways England by Ashford additional native vegetation. These proposals are described in the Borough Council but there is no agreement at present with Environmental Masterplan proposals (DCO Document 6.2, Figure 2.6f). Highways England. Issues of access have been addressed in previous responses, however it is not considered that access is hindered as a result of the current proposals. Part of the acquired land will be re-profiled in a way (Section A- There is currently no accessibility for maintenance through this area as the 002.03e A on drawing HA514442-MMGJV-GEN-00039-rev B) that council have suggested. From local knowledge 3/1/f and 3/14/a are effects and prohibits access by members of the public to the currently fenced off and inaccessible. The fenced off play area is not public opens space area from Church Road as well as by affected. The lighting column is shown outside of the play area. However, maintenance vehicles. It is also not clear if the fenced off play an access/maintenance chamber (FP3) is within the play area. A mini pillar area is directly affected. The main lighting scheme (figure 2.5d to serve the bridge lighting will be re-located outside the play area, inside drawing number HA514442-MMGJV-GEN-SMV-DE-Z-602106 the DCO boundary. The drawing HA514442-MMGJV-GEN-SMV-DE-Z- rev A) also indicates a mini pillar to serve the bridge lighting is 602106 will have to be amended to show this. within the play area. Confirmation of the overall impact on the POS/play area will be needed. A new access point is also likely Access to the park should not be hindered, if necessary a retaining solution can limit the extent of the proposed slope.

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to be needed and agreed and created at no cost to Ashford Borough Council. Stour Park scheme and relationship with alternative 002.04 scheme The council has resolved to grant outline planning permission Noted. 002.04a for the Stour Park development subject to a section 106 planning obligation agreement at the Planning Committee meeting 18 May 2016. The illustrative master plan showing the proposed building Noted. 002.04b footprint of the Stour Park development includes the principal access to the site from the access roundabout shown on the A2070 link as the alternative scheme proposals. The council has no objection to this access arrangement. The indicative master plan of the Stour park development Noted. 002.04c identifies that the northern boundary to the site would have a screen planting belt fronting towards the Junction 10a A2070 link road. The planting for the Stour Park development would be Noted. 002.04d supplemented by tree planting through the Junction 10a scheme. If the quantum of land needed by Highways England for the link road corridor is reduced by adjustments to its boundary with Stour Park northwards then the space available for tree landscaping entirely within Stour Park would be enhanced as a consequence. Overall in view of the substantial scale of the Stour Park The impact of the lighting on bats was assessed in, Chapter 8; Nature 002.04e development the council requests a strong boundary of Conservation, Volume 6.1 of the Environmental Statement. This woodland scale tree planting of maximum depth possible on the assessment concluded that the additional lighting and the operation of the southern side of the A2070 and that this supplements similar A2070 link road would have a Minor Adverse impact at Local level, but this planting provided with the Stour Park development. would be offset by the creation of additional habitat (3 balancing ponds; 14.19ha of grassland; and 4.89ha of tree, scrub and woodland habitats) and the provision of bat boxes, which would result in an overall Slight Beneficial residual effect is predicted in the long term once the habitats have become established. The Stour Park development identifies the importance of having The impact of the lighting on bats was assessed in DCO Document 6.1, 002.04f a sensitive lighting scheme in terms of impact on ecological Chapter 8; Nature Conservation. This assessment concluded that the receptors (bats) and visual & historic receptors (St. Mary’s additional lighting and the operation of the A2070 link road would have a HA514442-MMGJV-GEN-SMW-RE-Z-10701 11 Revision A

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Church and adjoining properties). The proposal is for limiting Minor Adverse impact at Local level, but this would be offset by the creation light spillage in certain areas marked purple as shown on the of additional habitat (3 balancing ponds; 14.19ha of grassland; and 4.89ha image attached as Annex 1. of tree, scrub and woodland habitats) and the provision of bat boxes, which would result in an overall Slight Beneficial residual effect is predicted in the long term once the habitats have become established. In terms of ecological receptors, the recommendations of the The impact of the lighting on bats was assessed in Chapter 8; Nature 002.04g bat conservation trust would be incorporated to ensure that the Conservation, Volume 6.1 of the Environmental Statement. This development mitigates impacts on wildlife. assessment concluded that the additional lighting and the operation of the A bat activity map was provided and this highlights in purple A2070 link road would have a Minor Adverse impact at Local level, but this ecologically desirable ‘dark’ areas of the site and in green would be offset by the creation of additional habitat (3 balancing ponds; conflict zones where street lighting has potential to cause 14.19ha of grassland; and 4.89ha of tree, scrub and woodland habitats) and fragmentation of habitat areas thus lessening the value to bats. the provision of bat boxes, which would result in an overall Slight Beneficial The Stour Park applicant acknowledges that this would dictate residual effect is predicted in the long term once the habitats have become as sensitive approach as possible in the conflict zones. The established. approach that would be taken in the areas marked purple would be to provide level (e.g. bollard) or directional lighting in order to limit excessive light spill into these areas with design to limit light spill being the subject of computer simulation with lux levels to be less than 1. The junction10a scheme involves new lighting being provided along the A2070 link road in close proximity to this area. The impact of this on ecological receptors in this area also needed to be considered as it has been for the Stour Park development. Impact on grade 1 listed St Mary’s Church and adjoining 002.05 listed Court lodge complex The setting of the grade 1 and adjoining grade 2 Court lodge A Cultural Heritage Assessment has been undertaken (DCO Document 6.1, 022.05a complex is important. The comments from Heritage England Chapter 6; Cultural Heritage) which includes an assessment of the effects need to be considered and whether improvements can be of the Main and Alternative Scheme on the viability and setting of St Marys provided such as less highway paraphernalia and more space Church. The assessment concludes that the Main and Alternative have the for landscaping to the noise barrier to the north. There are no potential for a residual effect on the setting of the asset as elements of the details of the new footbridge so this impact on the setting of proposed new Link Road and the junction with the A2070 (embankments, these buildings cannot be fully assessed. lampposts, signage etc.) would be visible from the church. The proposed Link Road would form a new visual barrier in the landscape to the north and north east of the asset. Design measures such as landscaping would reduce the potential impact on the setting and character of the church. To retain the viability of St Marys Church, pedestrian and road links to the HA514442-MMGJV-GEN-SMW-RE-Z-10701 12 Revision A

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church would be retained throughout construction and operation of the Main and Alternative Schemes. 002.06 Air quality The context of the Environmental Statement is noted. Further Noted. 002.06a clarification/information is required on the following matters outlined in Chapter 5 of the Environmental Statement. Further information as to whether there is the potential for An Air Quality assessment has been undertaken (DCO Document 6.1, 002.06b DMRB criteria for further assessment to be triggered for the Chapter 5; Air Quality). This noted that the temporary traffic lights that construction phase, specifically (i) Whether changes in speed would be installed on the A20 across the Swatfield Bridge for approximately (either peak-hour or average) at the approaches to 50mph 7 months may cause queuing, especially during peak periods, on the A20 speed limits on the M20 could trigger DMRB criteria; (ii) which has the potential to increase emissions. However, any increase in Whether temporary changes associated with traffic lights on the emissions from queuing would be temporary and for less than a year, are A20 or changes in speed on the M20 would be likely to be therefore not considered to have any long-term adverse effects. Any effects significant. would be reversible upon completion of the works and therefore not significant. Further information regarding modelled versus observed speeds The proposed traffic management is likely to result in vehicles travelling at a 002.06c that led to derivation of traffic speed data in Appendix 5.3. constant free flow speed of 50 miles per hour with fewer speed variations compared to normal operation. The free flow speed coupled with a reduction in speed limit from 70 miles per hour to 50 miles per hour is likely to cause a reduction in vehicle emissions which would benefit air quality. These are quality affects will be temporary and reversible and therefore are not significant. Clarification as to the apparent minor discrepancy between This comment is not absolutely clear, however it is assumed the comment 002.06d 5.8.12, Table 5.13 and Appendix 5.4 (specifically with respect to relates to the increase in concentration greater than 0.4µg/m3 at receptor receptor 1469). Confirmation that all receptors were fully 1469 presented in DCO Document 6.3, Appendix 5.4 but not included in the considered in the ‘Main Scheme – Operation’ and ‘Alternative assessment of significance in DCO Document 6.1, Chapter 5, Table 5.13. Scheme – Operation’ sections and whether any amendments to This receptor is located at the garden of the ‘French Connection Table’ pub the section are necessary. at the Orbital Retail park. The air quality objective applicable at this location is for 1 hour averaging periods as discussed in DCO Document 6.1, Chapter 5, Table 5.2. As the annual mean NO2 concentration is well below 60µg/m3 in all scenarios the 1 hour air quality objective is unlikely to be exceeded, as discussed in DCO Document 6.1, Chapter 5, Paragraph 5.3.35. All relevant receptors have been considered for the assessment of significance.

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002.07 Noise and vibration The context of the ES is noted. Further clarification/information (i) DCO Document 6.1, Chapter 11, Section 11.2.14 refers to local policy. 002.07a is required on the following matters outlined in Chapter 9 of the Local policies are further discussed in DCO Document 6.1, Chapter 11, Environmental Statement: Section 2.9.8. (i) Section 9.2 – there is no reference to any local planning (ii) DCO Document 6.1, Chapter 11; Noise and Vibration assesses the policy in respect of noise and vibration as the NPPF would noise impact of the Main and Alternative Schemes. Noise calculations have require. been based on traffic forecasts and assumptions within those forecasts. (ii) One of the aims of the proposed scheme is to relieve current Notwithstanding this, forecast speeds have been derived using Interim and ameliorate anticipated future traffic congestion. However, Advice Note 185/15 which provides guidance on assigning more realistic the ES is not clear how the assessment has addressed the way speeds on a link-by-link basis. In this way a more realistic comparison can in which congestion in future “Do–minimum” scenarios will be obtained between scenarios with differing traffic conditions. influence the speed of traffic on the roads evaluated. This is With respect to benefits of a thin surface course, in accordance with DMRB potentially important as congestion often results in a drop in these have been incorporated into the calculation process and are reflected traffic speed and can cause the associated noise level to fall, if in the findings. not over the whole of a 16 or 18 hour day to be reduced for substantial periods during that time. Consequently, it is not clear if the calculated difference between “Do– minimum” and “Do- Something” noise levels appropriately reflects the likely difference between the “Do–minimum” scenarios with congestion and the DS scenarios without, or at least with less, congestion. Clarification of if and how traffic congestion in the opening and design year “Do–minimum” scenarios and whether the assumed future “Do–minimum” noise predictions allow for reduced speed and therefore lower noise levels associated with congestion, is therefore recommended. It should be explored whether the use low surface noise Highways England will specify thin surface course surfacing which will 002.07b surfacing throughout the scheme add any material benefits in mitigate noise from the Main and Alternative Schemes (refer to DCO terms of noise and vibration. Document 6.1, Chapter 11, Paragraph 11.7.2). The exception will be A20 as will remain in KCC maintenance responsibility. 002.08 Effects on All Travellers The context of the ES is noted. Further clarification/information (i): The area-wide or strategic model used for the economic case is a 002.08a is required on the following matters outlined in Chapter 12 of the SATURN model linked to a DIADEM variable demand model. Junction Environmental Statement: modelling of the Scheme was carried out using VISSIM with some inputs HA514442-MMGJV-GEN-SMW-RE-Z-10701 14 Revision A

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(i) The chapter refers to traffic models, but is not specific as to derived from LINSIG. which have been used. It seems likely that appropriate models (ii): The SATURN/DIADEM model was used to model the main stages of have been employed (e.g. an area-wide model such as construction for the purposes of quantifying construction delays and costs SATURN, and/or specific junction models such as ARCADY or that fed into the economic analysis. This was done in preference to using PICADY. QUADRO. The 2018 and 2023 forecast models were used as noted in (ii) Clarification sought over whether the traffic data has been Section 5 of the EAR to represent construction between 2018 and 2020, predicted for the construction period with bespoke TUBA runs providing the construction disbenefits to the overall economic assessment. 002.09 Landscape and visual The areas likely to experience the greatest landscape effects The visual impact of the Main and Alternative Schemes is assessed in the 002.09a are those adopted Landscape Character Areas physically Environmental Statement (DCO Document 6.1, Chapter 7; Landscape). affected by the proposed scheme and those which lie This assessment has been carried out in accordance with the Design immediately adjacent to the proposals e.g. Mersham Farmland Manual for Roads and Bridges (DMRB) Volume 11, and also uses the and Brabourne Lees Mixed Farmland. It is considered that the Guidelines for Landscape and Visual Impact Assessment, identifying significance of landscape effects on these two landscapes in landscape and visual baseline including value and sensitivity to change, Year 1 and Year 15 have been underestimated. prior to considering appropriate mitigation, the magnitude of change and resulting significance of effect. It is believed this comment refers to Mersham Village rather than Mersham Farmland given Mersham Farmland will be directly affected by the Scheme. Both Mersham Village and Brabourne Lees Mixed Farmland and neighbouring Mersham Farmland, remain visually disconnected from the Scheme in the vast majority of cases, with only partial/limited connectivity to neighbouring landscapes, and therefore the overall character of these Landscape Character Assessments (LCA) will not be significantly affected by changes in landscape features within the neighbouring LCA. There may be localised reductions in audible tranquillity however this would be set in the context of the M20 and A20 immediately adjacent to the works site. In relation to visual receptors it is considered that the visual The visual impact of the Main and Alternative Schemes is assessed in the 002.09b effects of the scheme have in a number of cases been Environmental Statement (DCO Document 6.1, Chapter 7; Landscape). underestimated either because they were not assessed, This assessment has been carried out in accordance with the Design because the additional effects of the alternative proposal were Manual for Roads and Bridges (DMRB) Volume 11, and also uses the not properly articulated or because ancillary aspects of the Guidelines for Landscape and Visual Impact Assessment, identifying proposals were not sufficiently taken into account. landscape and visual baseline including value and sensitivity to change, prior to considering appropriate mitigation, the magnitude of change and resulting significance of effect. Visual receptors have been grouped in HA514442-MMGJV-GEN-SMW-RE-Z-10701 15 Revision A

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cases where similar views are afforded. The effects of the Main Scheme design are considered to have been addressed sufficiently in line with DMRB guidance. Variations to the Main Scheme effects,associated with the Alternative Scheme, have been identified and explained under the section 'Predicted Effects of Alternative Scheme'. It is also considered that some of the mitigation planting Mitigation for landscape and visual impacts has been incorporated into the 002.09c proposals are inadequate and / or are uncharacteristic and have Environmental Masterplan proposals (Figure 2.6f, Volume 6.2 of the missed opportunities in relation to improving landscape legibility Environmental Statement). The landscaping proposals include native and place making. In addition, opportunities to improve access hedges with intermittent trees, native tree planting and specimen trees and connectivity between the urban areas of Ashford and the along the length of the proposed A2070 Link Road, which would provide wider countryside do not appear to have been adequately visual screening of the Main and Alternative Schemes and associated traffic considered. There is considerable scope to improve the and a strong vegetative northern boundary to the proposed Stour Park landscape proposals within the Aylesford Stream valley in development area. Proposed plant species reflect those within the local particular area and seek the use of native species for both landscape integration and biodiversity benefit. Opportunities have been sought to provide footway/cycleways bordered by native tree and shrub planting heading west towards the village of Mersham. PROWs to the south of the The Main and Alternative Schemes running through open farmland would not be directly affected and lie outside of the Scheme boundary. The area around Aylesford Stream has been developed to provide both landscape integration and visual amenity, as well as providing key biodiversity habitat through a mix of species rich grassland and native trees and shrub plots, linking down to existing trees to be retained adjacent to the riparian edge of Aylesford Stream. This area will not be accessible to the public due to the closure of PROW requested by KCC. A significant amount of existing established landscaping will be (i) Mitigation for landscape and visual impacts has been incorporated into 002.09d removed. It is important that substantial replacement and new the Environmental Masterplan (DCO Document 6.2, Figure 2.6f). This area planting is provided in particular the following locations. is currently proposed as linear belt of native shrubs and trees to replicate (i) The approaches along M20 corridor which currently are the existing character of the site adjacent to the Junction 10A eastbound characterised by dense tree-lined landscaping. The planting offslip. On the westbound carriageway the proposed planting scheme has proposals should look to continue and retain this characteristic. introduced linear native woodland strips to an area where there was (ii) Along Kingsford Street which currently has a narrow rural previously no substantial vegetation. lane tree- lined character. The planting should look to continue (ii) The replacement planting will include a native hedge with intermittent this characteristic. mature trees with native woodland planting set behind it. Over time this will (iii) The A2070 link road should have substantial landscaping develop to retain the character of the street. provided along the southern end in particular and this integrates (iii) There is an inadequate amount of space to provide "substantial

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with landscaping provided for the substantial Stour Park woodland planting" along the southern end of the A2070. The Stour Park development. The landscaping providing should include development have adequate room within the their boundary to woodland scale planting. accommodate more substantial woodland planting but this is outside of our (iv) The northern end of the A20 where existing boundary site boundary. Every effort has been made to provide as much vegetation landscaping along the highway is lost through the realignment of as possible within the space available. the road. Replacement boundary planting along the A20 with (iv) Substantial woodland planting is being provided where the A20 meets suitable trees will need to be provided. the new proposed J10a, the area could be increased at the northern end (v) The area around the new Church Road footbridge. The and include more substantial trees. This will be explored further at the next replanting on the western side and screening lost located close design stage. to the nearest dwellings along Nightingale Close is likely to (v) More substantial planting can be provided near Court Lodge side of result in overlooking from the footbridge. On the eastern side Church Road footbridge. In addition, it has been assumed that the retained screening to St Mary’s Church and the Court Lodge complex, intervening trees along the edge of Church Road will still provide screening more initial substantive panting is likely to be needed in these value. Likewise, retained vegetation will offer screening value to some areas properties on Nightingale Close. Over time, proposed vegetation along the ramp embankments will establish to provide further screening to these properties. Opportunities will be explored during the next design phase to include examples of more mature species to break up views to and from the footbridge for the small number of properties that may be effected. Appendix 2.2 provides the indicative planting schedule. The This will be provided at the relevant detailed stage in the development. 002.10 final detail planting will need to be clear Further clarification/information is required on the following (i) An aerial photograph will be provided to the Examination with the 002.10a matters outlined in Chapter 7of the Environmental Statement: Scheme overlaid. (i) It would be helpful to have an aerial photograph with the (ii) Environmental barriers have been included on the Environmental proposed scheme overlaid so that the features associated with Masterplan (DCO Document 6.2, Figure 2.6f). Given the scale of the the scheme could be readily placed in the existing landscape masterplan it is considered that lighting and signage are best placed on patterns and topography standalone drawings, as these features may not be easily identifiable on the (ii) It would be useful if the environmental masterplan proposals masterplan drawings. included all aspects of the scheme which can have a visual (iii) ABC was originally consulted regarding potential key visual receptors cumulative effect including barriers, signage and lighting and asked if there were any particular areas they felt should be addressed (iii) It is unclear why only three of the key viewpoints have been within the assessment. The response referred back to the original scoping made into montages and not others. report which did not detail any key views within close proximity to the (iv) St Mary's Church is not shown on Figure 7.9b although it is Scheme. As such photomontages were undertaken for a small number of expected that the removal of vegetation along the M20 will open viewpoints where it was considered that views to the Scheme could be up views to the church in Year 1. informative in supporting the Landscape and Visual Impact Assessment and (v) The main LVIA document does not set out all volumes general understanding of the Scheme by means of graphical presentation relevant to the chapter at the start of the chapter which would within the Environmental Statement (DCO Document, Volume 6.2, Figures HA514442-MMGJV-GEN-SMW-RE-Z-10701 17 Revision A

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aid navigation and cross referencing. 7.9b to 7.9k). These were chosen to best represent the Scheme from a (vi) There is no reference to the Ashford Green and Blue Grid series of locations and angles. An additional photomontage was provided prepared by Shields Flynn (2008) representing views from St Mary's church as a direct outcome from (vii) No reference is made to landscape impacts and in consultation with Historic England. particular physical and perceptual impacts (iv) The Church will be visible in Year 1 and will be added to the (viii) Not all important visual receptors appear to have been photomontage which will be submitted to the Examination. picked up during the assessment. For example it is considered (v) Noted that key visual receptors also exist on the Public Right of Way (vi) Whilst specific reference to the Ashford Green and Blue Grid has not which heads north from adjacent to St Mary's Church. been made within the Environmental Statement, the principles for creating (xi) No information is provided on the physical loss of trees, continuity with established green corridors has been considered and vegetation, grassland and arable land as a result of the implemented within the environmental design for the Scheme. The proposed development, although it is noted that the plans in importance of continued connectivity both for landscape and biodiversity Appendix 7.1 Volume 3.2 show trees and hedgerows for benefits is well understood, as well as the important aesthetic qualities of removal green corridors, and has been reflected in the design. (xii) It is unclear why the alternative proposal is not also (vii) There is a section dedicated to landscape effects within the landscape assessed separately for Visual Receptors 1 and 2 both of which chapter of the Environmental Statement. would afford views cross the Aylesford Stream to the rising land (viii) The footpath adjacent to St Mary's Church was identified under beyond. receptor number 11 which captured the view from the intersection of PROW AE337A and AE639 looking towards the new Junction 10A. (ix) The composition of the Main and Alternative Schemes are almost identical, with of course the exception of the new roundabout. Given the relatively small nature of the change, many receptors remained unaffected by the new junction and therefore only receptors noting a change resulting solely from the addition of the roundabout were mentioned in the Alternative Scheme impacts description. (x) For maintenance of the fence a distance of 1.5m is required, the fence has been positioned for optimal reduction of noise. Following consultation with the noise specialists it may be possible for the fence to be moved out of the optimal position to allow for more planting, although this would require additional work at the next design phase. (xi) The loss of habitats and broad Phase 1 classified land is detailed in the Extended Phase 1 Report, (DCO Document 6.3, Appendix 8.1). (xii) Viewpoint 2 represents a PROW which would be closed as part of the Scheme. Therefore the receptor would be removed from future consideration. With regards to Viewpoint 1 it is not considered that the Alternative Scheme would lead to a notably different change in scene in the

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context of the wider view from this location and as such, to avoid repetition was not addressed separately for the Alternative Scheme. 002.11 Arboricultural Survey Report Appendix 7.1 TPO trees at Pilgrims Hospice boundary with A20 Hythe Road. ABC's interactive website map did not show any trees within the boundaries 002.11a The arboricultural survey report appendix 7.1 indicates no TPO of the Main and Alternative Schemes when used at the time of compiling trees are affected which is incorrect. The belt woodland trees on the Environmental Statement (Volume 6.3, Appendix 7.1). However now the the southern boundary of the Pilgrims Hospice is protected by Tree Preservation Order trees at Pilgrims Hospice have been identified the Tree Preservation Order No.22, 1998. The TPO has not been design has been altered and no trees within Pilgrim house land will be picked up in the survey which states that no TPO trees will be affected. A site visit to ascertain the full arboricultural impact on woodland affected. The trees are included within the wider area of W1 of W1 on 15th November will also be used to review Root Protection Areas of the survey and are mentioned as being implicated in the trees bordering Pilgrim Hospice land to provide assurances of this. The Arboricultural implications assessment. Arboricultural Survey Report (DCO Document 6.3, Appendix 7.1) and Arboricultural Implications Assessment (DCO Document 6.3, Appendix 7.3) will be updated to reflect the results of the additional visit and resubmitted to the Examination. The belt of woodland trees is an important visual feature and As above and woodland W1 will not be removed completely, rather a strip 002.11b provides screening to the hospice from the busy A20 road. This of approximately 30m will require felling to facilitate the works on the A20 will be of increasing importance with the construction of the embankment. The full impact will be assessed in a site visit on November Junction 10a link road. The loss of these trees is unacceptable 15th and the Arboricultural Survey Report (DCO Document 6.3, Appendix on the grounds of visual amenity and needs to be addressed at 7.1) will be updated to reflect the results of the additional visit and this early stage resubmitted to the Examination. Page 8, paragraph 6 of the Executive Summary states that The Arboricultural Survey Report (DCO Document 6.3, Appendix 7.1) and 002.11c there are 36 tree groups in the survey, however the Schedule of the Arboriculture Implications Assessment (DCO Document 6.3, Appendix Trees as well as page 14 paragraph 2.1.9 specifies that there 7.3) state 36 groups of trees. are 35 groups which have been surveyed. An error in counting group G30 twice in the Schedule of Trees has resulted in inconsistency in the report. Page 10, paragraph 1.5.1 states that the survey was undertaken A copy of the Arboriculturalist's CV and qualifications can be supplied if 002.11d by a qualified Arboriculturalist, please can the level of required. qualification for example ‘level 3’ qualification be specified. While this may not be a statutory requirement clarification concerning the competency of the surveyor would be required in line with best practice. Page 13, paragraph 2.1.2 to 2.1.4 discusses ‘grouping’ of trees The groups were assessed under section 4.4.2.3 of BS 5837:2012 taking in 002.11e in the survey. In the absence of clarification it is assumed that to account the note following 4.4.2.3 within BS5837:2012 which reads: “The HA514442-MMGJV-GEN-SMW-RE-Z-10701 19 Revision A

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the groups were selected in accordance 4.2.4 (B) of BS term “group” is intended to identify trees that form cohesive arboricultural 5837:2012 features either aerodynamically (e.g. trees that provide companion shelter), visually (e.g. avenues or screens) or culturally, including for biodiversity (e.g. parkland or wood pasture), in respect of each of the three subcategories (see 4.5)". Page 13, paragraph 2.1.4 discusses hybrid black poplar trees. A physical inspection of the trees indicated that these were hybrid black 002.11f Was a check made to establish if these were hybrid or native poplar rather than native. The physical feature reviewed included a) the black poplar trees, as native black poplar are nationally leaves were flat based and not diamond b) the leaves were heavily rather important and may require special consideration or upgrading of than shallowly toothed, c) there were no spiral galls on the leaf stem (the their category status. presence of which would have indicated that these would be native as the gall is reportedly present on all the native population) d) the overall habit of the trees was upward ascending branches rather than downward curving. Page 24, Appendix B. Species list cross referencing common A full Latin species list will be added to the Arboricultural Survey Report 002.11g names with scientific/botanical names is missing from the (DCO Document 6.3, Appendix 7.1) which will be revised and submitted to report.(paragraph 1.5.6) the Examination. 002.12 Arboricultural Implications Report Appendix 7.3 Page 8, paragraph 2 of the Executive Summary states that the Noted, Arboriculture Implications Assessment (DCO Document 6.3, 002.12a Arboricultural Implications Report should be read in conjunction Appendix 7.3) references to be checked and updated where necessary in with M20 Junction 10a Arboricultural Survey Report (June 2016) the revised version. document reference 341755-09-300-RE-02-A, however the Survey Report we have reviewed is reference July (2016) reference HA514442-MMGJV-GEN-SMW-RE-Z-630701, and therefore does not correspond. Page 8, paragraph 2 of the Executive Summary states that 36 The Arboricultural Survey Report (DCO Document 6.3, Appendix 7.1) and 002.12b groups of trees were surveyed, however this does not the Arboriculture Implications Assessment (DCO Document 6.3, Appendix correspond with the Schedule of Trees in the Arboricultural 7.3) state 36 groups of trees. Survey Report which states 35 groups. Page 11 paragraph 1.4.1 states that due to minor changes in Arboriculture Implications Assessment (DCO Document 6.3, Appendix 7.3) 002.12c the scope of works, a revised Arboricultural Survey report was references to be checked and updated for the revised version, which will be issued. Clarification is required to whether the latest report submitted to the Examination. corresponds to report reference July (2016) reference HA514442-MMGJV-GEN-SMW-RE-Z-630701. In Section 3 there is no reference to root incursion analysis of Generally, Root Protection Areas incursions should not occur on site as 002.12d root protection areas of impacted trees or specific construction protective fencing should exclude construction activity from these. However, mitigation recommendations. While it is not a requirement of BS HA514442-MMGJV-GEN-SMW-RE-Z-10701 20 Revision A

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5837, it is established industry practice to undertake an if there is uncertainty remains for specific issues, Arboricultural Method assessment of root protection area incursions. Statements will be produced to highlight any necessary mitigation. Visual impact of 3m Noise barrier along Kingsford Street 002.13 and A2070 The 3 m acoustic barrier will be a visually prominent feature in The limited space available along Kingsford Street will necessitate the 002.13a places. Although it is recognised that mitigation for noise is removal of existing vegetation to allow the construction of the new shared crucial it is important that the barrier is visually screened and footway/cycleway and noise barrier. A new hedgerow with intermittent trees properly integrated into the existing landscaping scheme in the will form part of the planting design for the area north of Kingsford Street. best way possible. Proposed native tree and scrub planting will be provided to the rear of the noise barrier, providing screening for the new slip road and the existing M20 corridor. The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides full details of the Scheme’s proposals. There are certain locations the barrier may be particularly The limited space available along Kingsford Street will necessitate the 002.13b intrusive and changes to the siting/landscaping should be removal of existing vegetation to allow the construction of the new shared considered if these still provide the required noise mitigation. footway/cycleway and noise barrier. A new hedgerow with intermittent trees will form part of the planting design for the area north of Kingsford Street. Proposed native tree and scrub planting will be provided to the rear of the noise barrier, providing screening for the new slip road and the existing M20 corridor. The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides full details of the Scheme’s proposals. The start of the Kingsford Street footbridge on the Kingsford The limited space available along Kingsford Street will necessitate the 002.13c Street side, the barrier is located right up to the footpath from removal of existing vegetation to allow the construction of the new shared Kingsford Street with no planting/ screening in between. This footway/cycleway and noise barrier. A new hedgerow with intermittent trees may look oppressive when walking along the footway. will form part of the planting design for the area immediately adjacent to Consideration should be given to setting the barrier further back north of Kingsford Street. Proposed native tree and scrub planting will be into the native shrub and tree planting area. There are also two provided to the rear of the noise barrier, providing screening for the new slip listed buildings located close-by - Ransley Cottage and Redburr road and the existing M20 corridor. The Environmental Masterplan (DCO and their setting would potentially be enhanced with better Document 6.2, Figure 2.6f) provides full details of the Scheme’s proposals. screening. The barrier along the corner of Highfield Lane by the Junction The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides 002.13d 10a roundabout is exposed without any screening landscaping. full details of the Main and Alternative Scheme’s proposals. The Landscape assessment within the Environmental Statement (DCO Document 6.1, Chapter 7) showed that no sensitive visual receptors have a direct outlook towards this section of barrier and as such the fencing has been placed to be as close to the noise source as possible.

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The initial barrier along the southern side of the A2070 near the The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides 002.13e Junction 10a interchange is right up against the full details of the Main and Alternative Scheme’s proposals. The Landscape footway/cycleway without any screening landscaping. assessment within DCO Document 6.1, Chapter 7 indicated that no sensitive visual receptors have a direct outlook towards this section of barrier and as such the fencing has been placed to be as close to the noise source as possible. The barrier on the southern side of the A2070 roundabout has The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides 002.13f little or no landscaping screen and is partly sited on a noise full details of the Main and Alternative Scheme’s proposals. Landscape bund. A cross section needs to be provided through this. screening is present, albeit quite narrow due to restrictions on space in this area. There will however be planting in front of the barrier to break up the timber face. Both the area in front of the fencing and the bund itself will be planted. There needs to be confirmation that there is no problem with The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides 002.13g planting in particular larger specimen trees being planted close full details of the Main and Alternative Scheme’s proposals. Detailed design to barriers or highway hard surface areas in terms of impact on can ensure appropriate interventions are made to provide suitable growing roots. environments for standard trees through the use of plastic cells such as arboraft or silvercells underneath hard surfacing to extend tree pits if necessary. The appropriate specification of tree species and form should prevent conflict with barriers. 002.14 Flooding and drainage The report refers to Ashford Borough Council as the Lead Local The error within DCO Document 6.3, Appendix 14.1 the Flood Risk 002.14a Flood Authority when it is actually Kent County Council. Assessment (FRA) is noted. An updated FRA will be produced to include ongoing modelling work, in which this error will be amended. With regards to the technical details then there are no Noted. 002.14b objections to the runoff rate and methodologies being proposed. As discussed with Highways England throughout the process the design has focussed on ensuring Ashford Borough Councils local Sustainable Drainage SPD by seeking to limit runoff rates to those identified within the aforementioned document. Due to the betterments that achieving these rates can provide it is considered positive that HE are seeking to generally achieve these rates across the proposed scheme. Pond 3 of the development a runoff rate of 4l/s/ha has been Noted. 002.14c opted for rather than the 2l/s/ha (As stated in the Sustainable Drainage SPD) for the area north of the M20, however it is likely HA514442-MMGJV-GEN-SMW-RE-Z-10701 22 Revision A

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that ground conditions here will be similar to the rest of the development, with the underlying geology being of Hythe formation and therefore of low permeability. Furthermore, as identified within the available documentation, due to the area being drained to pond 3 being just over 1Ha the control rate would be limited to just above 2l/s, whilst small orifice controls can achieve the lower discharge rate, and with regular maintenance can continue to ensure the risk of blockages is very low, as this scheme involves national critical infrastructure the discharge rate of just over 5l/s from pond 3 is deemed acceptable Appropriate levels of treatment are considered to be in place Maintenance work for the Main and Alternative Scheme will be managed by 002.14d before the water finally discharges into the Aylesford stream. Highways England ‘Area 4’ team, which is operationally responsible for the The use of ponds, when used in conjunction with appropriate strategic road network. vegetation, can enhance treatment process and biodiversity. However, appropriate maintenance will be required and consideration given in the final design to ensure that sufficient capacity is provided within the ponds, even during periods when these may be heavily vegetated 002.15 Funding statement Paragraph 3.1.9 states the following: Noted - document to be amended. 002.15a “The contribution from local developer is reliant on a grant funding agreement between the Homes and Communities Agency (HCA) and Ashford Borough Council…”. This needs amending as the contribution from local developer reliant on a loan or grant funding agreement, between the Homes and Communities Agency HCA and Ashford Borough Council 002.16 Highfield Lane It should be explored if a closure of the vehicular link between Highways England considers this request to be outside of the Scheme’s 002.16a Kingsford Street and Highfield Lane needs to be provided as scope. There is no justification from traffic modelling to justify this part of these proposals for Junction10a to prevent unreasonable incorporation in the Scheme. Highways England have been informed by levels of rat-running through Mersham village. Stour Park developers that this work has been included in their section 106 agreement with ABC. Highways England will work closely with Stour Park Developers to ensure that this will be incorporated. HA514442-MMGJV-GEN-SMW-RE-Z-10701 23 Revision A

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Highways England have also been informed by Kent County Council that they will forward fund this work and will implement before the opening of the Scheme. They will work with Stour Park Developers to form an agreement. 002.17 Barrey Road The council had previously requested that there is a right hand Highways England understand concern regarding the Barrey Road exit onto 002.17a signalised turn-out from Barrey Road onto the A2070. It is the A2070, we notice that a number of residents have raised similar regretted that a right hand turn from the Barrey Road junction is concerns in the relevant representations. not included as part the proposals. The last traffic assessment of the Barrey Road Junction was done prior to 2013 when permission to occupy the empty units in the Ashford Retail Park was given, and at that time it was indicated that there would be a negligible impact on traffic overall. Therefore before the Scheme starts we have already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

Any subsequent amendment to this junction would require a Traffic Assessment of the Ashford Retail park and residential traffic impact to be initiated by the local network authority at the request of local stakeholders, which is not part of the Scheme as Highways England Major Projects deals with Nationally Significant Infrastructure (NSIP) Construction.

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this environment including the use of compounds nearby whose be subject to measures laid out by the local environmental health officer. position needs to be clarified. Highways England contractors would also be required to apply for the ‘Considerate Constructors Scheme’. Part of the Scheme’s focus is on respecting the community. Highways England is committed to meeting with the Hospice representative to talk through proposals.

Noise impacts on the Pilgrim's Hospice were assessed in Chapter 11; Noise and Vibration, Volume 6.1 of the Environmental Statement. This assessment concluded that levels of noise from the A20 once the Scheme is in place are expected to reduce. Highways England has also incorporated an acoustic bund 2m high to the rear of Summerhill Place, adjacent to the M20 junction 10a eastbound off-slip.

Council's interactive website map did not show any trees within the boundaries of the Scheme when used at the time of compiling. However now the Tree Preservation Orders (TPO) trees at Pilgrims house are identified the design has been altered and no trees within Pilgrim house land will be effected. A site visit to ascertain the full arboricultural impact on woodland W1 on 15th November can also be used to review RPAs of trees bordering Pilgrim house land to make assurances of this. 002.19 Highways Ashford Borough Council will rely on comments made by Kent Noted. 002.19a County Council on this matter. 002.20 Draft Development Consent Order Part 2 section 8 - Limits of deviation. The full implications of this Yes, limits of deviation are fully covered in Environmental Statement. 002.20a need to be considered and are these limits of deviation covered in the current environmental statement. It is not clear what is a materially new or material worse environmental effect from those reported in the Environmental statement. Given the short time period for considering the application Noted. 002.20b documents the Council has not fully assessed the wording of the draft development consent order. The Council may wish to submit written comments on the draft development consent order. HA514442-MMGJV-GEN-SMW-RE-Z-10701 25 Revision A

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002.21 Further details required The two footway and cycleway bridges Required documents have been sent to ABC by Highways England. 002.21a The retaining walls/structures and extent of them shown along 002.21b M20 corridors and A2070 which should be aesthetically finished The precise area and working of the compounds as they are 002.21c shown indicatively More user friendly sections through the development showing 002.21d existing and proposed changes. The engineering sections This is a DCO submission requirement to provide Engineering Sections. provided are not user friendly to a lay person and it is not clear what the proposed changes in levels are. 002.22 Conclusion The Council is supportive of the proposed new junction and the 002.22a positive contribution towards the growth agenda of the borough. ABC will continue to work with Highways England and Kent County Council on this application to deal with the issues identified and welcomes the opportunity to comment in more detail at a later stage.

1.3 RR-003 PINS Ref. Relevant Representation from Barry Kerr Response from Highways England (the Applicant) RR-003 003.01 Kingsford Street must be shut as part of the Sevington and j10a Highways England considers this request to be outside of the scope of the development to protect the residents and local users of Scheme. There is no justification from traffic modelling to justify this Kingsford Street and Mersham. incorporation in the Scheme. Highways England have been informed by Stour Park Developers that this work has been included in their section 106 agreement with ABC. Highways England will work closely with Stour Park Developers to ensure that this will be incorporated.

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1.4 RR-004 PINS Ref. Relevant Representation from BDB Design LLP on behalf of Response from Highways England (the Applicant) RR-004 Brett Aggregates Limited 004.01 Summary 004.01a We represent Brett Aggregates Ltd in connection with Noted. development and redevelopment proposals including up 600 homes at Conningbrook Lakes, Willesborough Road, Ashford. 004.01b This objection relates to the inadequacies of the primary Noted. highway network including M20 Junction 10 to serve not only this development, but also many other development proposals within the Ashford Area. 004.01c The lengthy delays associated with the provision of a new Noted. Junction M20/10A continue to frustrate investment and the provision of much-needed homes and employment within the Ashford area. 004.02 Objection 004.02a Our objection is primarily about the protracted time-scale Unfortunately, the Scheme was put on hold due to funding issues but is now involved in securing all necessary consents, commissioning, back on track and currently in the Examination Phase of the DCO. building and completing the proposed junction. We strongly urge The Scheme is currently with the Planning Inspectorate and Highways a speedy resolution to the Inquiry procedure and delivery of this England are working with them to deliver the Scheme. essential infrastructure without further delay. We are in a process which has a fixed timescale which is out of our control but we are trying to deliver the Scheme as soon as possible. 004.02b The delivery of large numbers of much needed new homes at Noted. Ashford is the long-held primary aim of the Borough Council. This has been made clear through successive policy reviews and now accentuated recently by an under-delivery of homes to meet Objectively Assessed Need. The planning strategy steered by thorough analysis of constraints and opportunities, as well as National Planning Policy Guidance dictates that the bulk of new development for jobs and homes should be located at Ashford. 004.02c For many decades and in support of Ashford’s growth-point Noted. status, landowners including the Brett Group and developers, have been encouraged to invest significant resources into securing planning permission for development or redevelopment of sites within and at Ashford’s periphery. To a greater or lesser

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extent, these sites rely on access to and from the M20 motorway. However, in order to manage under-capacity at junction 10, planning applications generating additional capacity are either being refused as premature, or made the subject of ‘Grampian’ conditions withholding commencement until Motorway access capacities can be increased. These proposals offer this in the form of a new Junction at known as 10A. 004.02d As a first phase, planning permission has been granted for 300 Noted. homes at Conningbrook Lakes, together with the formation of a Country Park including a range of associated leisure and sporting activities. However, development proposals for further phases of mixed-uses with up to 300 further homes, cannot progress until such time as the additional M20 Junction has been completed and open for use. 004.02e Interim solutions to enhance the capacity at junction 10 have Noted. been prepared and agreed, but any extra capacity will already be absorbed by approved development schemes to the south and east of Ashford. This leaves no prospect for the timely delivery of further phases at Conningbrook Lakes and many other sites allocated for development in adopted and emerging planning policy, which suffer from the same embargo. 004.03 Conclusion 004.03a The failure to provide essential transport infrastructure to help The Scheme is being promoted as a key transport requirement to help realise Ashford’s growth-point status and long-held policy facilitate national, regional and local travel and regeneration and growth in objectives, continues to stifle investment in jobs and housing. support of future development south of Ashford. The Scheme is essential to the future development of South Ashford as the existing J10 will suffer from further congestion and long delays in the future if additional capacity is not provided. The DfT expects that national traffic growth will be particularly strong on the Strategic Road Network (of which the M20 is part) with an increase of between 29% and 60% between 2010 and 2040. Due in particular to the link that the M20 provides between Folkestone and the Channel Tunnel and the M26, M25 and rest of the country, the Scheme is an essential improvement to satisfy forecast traffic growth and to accommodate the level of housing and employment growth that is forecast in the Ashford area. There is therefore a compelling need for the Scheme.

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004.03b The proposed Junction M20/10A has been a preferred solution Noted. for a very long time. We object to the protracted programme for completion. The scheme should be approved, commissioned, built and opened for use without delay and afforded the highest priority. 004.04 Recommendation 004.04a We Support the provision of a new M20/J10A as proposed in Unfortunately, the Scheme was put on hold due to funding issues but is now the planning application and associated documents. However, back on track and currently in the Examination Phase of the DCO. WE OBJECT in the strongest terms to the inordinate delays to The Scheme is currently with the Planning Inspectorate and Highways completing the approvals and the delivery process. England are working with them to deliver the Scheme.

We are in a process which has a fixed timescale which is out of our control but we are trying to deliver the Scheme as soon as possible.

1.5 RR-005 PINS Ref. Relevant Representation from Bellamy Roberts on behalf of Response from Highways England (the Applicant) RR-005 Church Commissioners for England 005.01 The Church Commissioners for England (The Commissioners) Noted. are long term landowners in Kent with significant land holdings in excess of 3,500 acres to the south of Ashford. Part of that land holding at Cheeseman’s Green has an extant planning permission for 1100 dwellings and 8,500m2 of employment floor space. Implementation of that permission has commenced and is continuing apace. The final 400 dwellings are subject to a Planning Condition which restricts their development prior to completion of M20 Junction 10A. 005.02 The Commissioners are fully supportive of the proposals for a Noted. new motorway junction in this location. This will not only unlock the final part of their existing planning permission but it will also facilitate development on parts of their remaining land holdings in South Ashford (south of Cheeseman’s Green). It is recognised by all parties that the Junction 10A scheme is a key transport requirement which is essential to the future development of South Ashford and will unlock development potential in that area.

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005.03 However, The Commissioners are concerned that the traffic See 005.06 and 005.07 below. modelling work described in the DCO Application does not properly reflect the Approved Development Plan and, therefore, does not fully take account of the development potential for land in South Ashford. 005.04 The March 2015 Scoping Opinion from the Planning Noted. Inspectorate explains that “Ashford has been identified as a major growth area in Kent with 31,000 additional homes and 28,000 new jobs anticipated in the area by 2031”. That is repeated at Paragraph 1.2.2 of Document 7.2, the Submitted Transport Assessment Report. Paragraph 2.5.1 of that Transport Assessment Report records the current Development Plan as comprising the LDF Core Strategy 2008, Borough Local Plan 2000 Saved Policies, and the Urban Sites and Infrastructure Development Plan Document 2012. 005.05 The Core Strategy 2008 established the appropriateness of the See 005.06 and 005.07 below. South Ashford location and the principle of development, identifying the potential of the Cheeseman’s Green and Waterbrook area to accommodate about 4,300 dwellings up to 2021 and a further 2,200 dwellings beyond that period. The DCO Application for Junction 10A should accord with the Development Plan and, therefore, should reflect that development potential in the Cheeseman’s Green and Waterbrook area. 005.06 It is difficult to be certain from the submitted documents with the This is due to the Transport Assessment Report (TAR) quoting figures from DCO Application but from the Transport Assessment Report the ‘standard’ economic assessment of the Scheme that exclude any (Table 3-9) it appears that the traffic modelling has been elements of development that are dependent on the Scheme such that constrained to local traffic growth forecasts based upon a total there is a like-for-like comparison of the With and Without scheme scenario. of some 10,589 dwellings and 5,617 jobs. Those figures are They also exclude any ‘reasonably foreseeable’ and ‘hypothetical’ clearly a long way short of the figures set out in the developments, all as per guidance for the Core Scenario. The Economic Development Plan Core Strategy 2008. The list of included Appraisal Report however also presents an ‘adjusted’ economic developments in the Transport Assessment Report makes no assessment, whereby some of the dependent development is allowed, and allowance for any development at Cheeseman’s Green and three sensitivity tests including an ‘Optimistic’, scenario that includes among Waterbrook over and above existing planning permissions. others Phase 1 of Waterbrook as reasonably foreseeable, and a ‘Realistic’ scenario that includes all of Cheeseman’s Green.

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005.07 The Commissioners are concerned that if the traffic modelling It is important to recognise that the new modelling, with base year 2015, has indeed been constrained in this manner, even the new takes implicit account of the proportion of the 31,000 dwellings that were Junction 10A design will present a highway capacity constraint originally envisaged between 2001 and 2031 (as noted in the July 2008 on future development of their land holdings and others in South Core Strategy) that have actually been built. The forecasts therefore allow Ashford, which are a significant resource for economic growth in only for post-2015 development, which will be fewer than 31,000 dwellings. Ashford. We have not done a detailed retrospective analysis to check that in total, the completions since 2001 plus the new forecasts equate to these numbers, but we have agreed the post-2015 forecasts with ABC who were content with them and assisted with their production, and who would be aware of the completions history.

It is now possible to make some assessment of this following publication of the new Draft Local Plan (June 2016), which includes the latest draft targets. After the Localism Act of 2011, forecasts were re-appraised and in the DLP (Table 1.3: Meeting the Housing Requirement) it is noted that there is a target of 14,680 new dwellings between 2011 and 2030, of which 2,481 have been delivered since 2011, leaving 12,200. The corresponding number from the Uncertainty Log analysis was not far short of this at approximately 11,200 (accepting that only some 10,600 were included in the Core Scenario). The DLP was not available when our model forecasts were done, which is one reason why the Uncertainty Log approach is required by DfT guidance, and suggests that the model forecasts are reasonably aligned with current draft proposals.

A final point is that all forecasts need to be controlled to DfT official forecasts at district level, to ensure that forecasts are consistent nationally, meaning that more generic account would be taken of any balance of trips between those of the official forecast and those derived from the explicitly- modelled developments from the Uncertainty Log. These district-level DfT controls should broadly reflect the overall development aspirations of the area, being based on AMRs.

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background growth. These tests represented the situation both with and without assumptions to take into account measures to reduce car usage, as referenced in the Core Strategy. Without these measures, the results led to some local network stress by 2033, mainly on the development access roads; with the additional measures, these accesses were considerably improved. Summary The summary response to the concern that the planning assumptions used in the analyses could under-represent the future scenario and possibly compromise the full development of the sites listed above is based on the following points: • We have followed official guidance on the forecasting process • The TAR reports the Core Scenario, not the sensitivity tests, so by definition does not include dependent, reasonably foreseeable or hypothetical developments • Overall growth is constrained to fixed DfT development totals by district, irrespective of the explicitly-modelled developments • A check using the new DRAFT LDF indicates that the explicitly-modelled developments in Ashford are not significantly lower than the latest post- 2015 targets

1.6 RR-006 PINS Ref. Relevant Representation from Campaign for Better Transport Response from Highways England (the Applicant) RR-006 006.01 Campaign for Better Transport objects to the quality of the New footways/cycleways are to be provided throughout the Scheme extent. accompanying pedestrian and cycle infrastructure that forms We are proposing two additional footway/cycleway bridges and new part of this application. It appears to be of a standard that does footway/ cycleway along Kingsford Street. This proposal will create better not fit with Highways England's requirements and aspirations as connectivity between A2070 and A20 roads. contained within its own Cycling and Access Strategies. It is unclear how the proposed infrastructure provides as good, or better connectivity for pedestrians and cyclists to what they currently enjoy. If anything, there are substantial elements that appear to be a backward step and therefore likely to make it harder for the Government to implement its Cycling and Walking Investment Strategy (CWIS), which relies in part on Highways England delivering improved infrastructure for these modes. HA514442-MMGJV-GEN-SMW-RE-Z-10701 32 Revision A

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1.7 RR-007 PINS Ref. Relevant Representation from David Hannigan Response from Highways England (the Applicant) RR-007 “I am an interested party due to being a local resident of Smeeth We believe that this representation is referring to the M20 Lorry Area which is very close to the suggested site. scheme and not M20 Junction 10a. Responses have been obtained from I am against this due to the following reasons: the M20 Lorry Area project team and are detailed below. Highways England would like to thank you for your feedback and if you have any questions or if you would like more information about the Scheme please contact them. 007.01 Traffic congestion It is recognised that the disruption caused by Operation Stack affects many It will not fix Operation Stack, it will only bring MORE lorries into people in Kent but this issue is not just local. More than 80% of road freight our area, affecting the local residents and businesses. This has entering or leaving the UK is via the Port of Dover and the Channel Tunnel, a knock-on effect for the whole of Kent and further afield. with freight traffic volumes forecast to double over the next decade. Incidents such as industrial strikes across the channel, severe weather, and fire, can be expected to occur in the future and are beyond the control of Highways England and government. So there is every reason to expect that Operation Stack will continue to be needed in the absence of a lorry area.

The key primary objective of the Scheme is to relieve the impact of disruption to cross channel freight in Kent through the delivery lorry area close to the M20. An off-highway lorry area will provide a safe and efficient lorry holding facility for use during periods where either the Port of Dover or Channel Tunnel are experiencing capacity constraints. Following a public consultation held between December 2015 and January 2016, Highways England evaluated a wide range of alternative options put forward by stakeholders and residents. These included different sites for a lorry area, the use of multiple small sites, more use of the latest technology and the increased use of rail and freight.

A full assessment of all the different options presented at the consultation was carried out. These were sifted on the basis of social, economic and environmental impacts, deliverability, capacity, affordability and practicality. Overall a lorry area was considered the best performing option of the alternatives. 007.02 Environment We are aware that the lorry area will have an impact on the environmental aspects surrounding the area, such as trees, plants and water courses. To HA514442-MMGJV-GEN-SMW-RE-Z-10701 33 Revision A

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The proposed lorry park to take 3500 – 4000 HGVs will devour better understand the potential we are conducting studies to assess the 150 acres of countryside and farmland in the ancient village of impact based on different frequency of uses. We will publish an updated Stanford, adjoining Areas of Outstanding Natural Beauty, along Environmental Assessment Report before construction of the lorry area with all the existing flora and fauna we enjoy in the Garden Of starts. There will also be exhibitions to inform local people of the revised England. proposals and give information on how to contact us throughout the process. 007.03 Air quality The results from air pollution monitoring have been used to inform a site The increased emissions and particulates produced by so many specific air pollution dispersion model allowing us to understand how the lorries concentrated into one area could kill vulnerable people lorry area may change air quality in the area around the site. The overall air living nearby. quality effects of the lorry area are not expected to be significant and no Particulate 2.5 which are produced by diesel engines are so exceedances of the national and European annual average threshold are small that the human lung cannot filter them and thus they go predicted. straight into the blood stream. These particulates are directly linked to cancers, heart disease and lung disease, which all medical bodies accept cause premature death to thousands of people each year in the UK. There is no safe limit to these particulates entering the human body. 007.04 Sound pollution We recognise that noise from refrigerated vehicles is a particular issue and The rumbling of Highways England’s expected 540 HGVs per are investigating a number of ways in which this might be mitigated. The hour will be heard for miles around and refrigerated units run supply of electrical power to the lorry area for the use of refrigerated units is through the night too. currently being considered as part of the detailed design. We are also looking at the possibility of distributing refrigerated vehicles throughout the area to lower noise impacts for the local community. 007.05 Light pollution During Operation Stack lighting will be required, but will be turned off in The proposed full lorry park capacity will be lit up like a small areas not being use at the time. Lighting will also be dimmed within zones town at night. No more starry skies to admire. of the Lorry Area when there are no lorry movements in that zone. 12 metre tall lighting columns will be installed within the Lorry Area. They will be fitted with flat glass LED lanterns to minimise unnecessary light spillage. 007.06 Rubbish Basic facilities such as toilets, fresh water and waste disposal will be Even though most lorry drivers are careful, we already know provided. We are considering various options including portable what sort of disgusting litter is left by a few unscrupulous convenience cabins. The operator will be required to maintain all facilities to truckers, including bottles of urine and bags of worse. Our a high level to ensure that they are attractive to use. The lorry area will also environment could be littered even more with the increase in be litter picked following any use. lorry traffic and time spent parked. 007.07 Crime The safety and security of members of the local community, users of the We have been given no assurance about how the potential lorry area, and staff is a key priority. We plan to secure the site using a HA514442-MMGJV-GEN-SMW-RE-Z-10701 34 Revision A

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increase in crime will be handled, since we do not even have robust perimeter fence with gates for footpaths and bridleways. These enough police officers in Kent now. gates will be closed when the site is being used to alleviate Operation Stack and alternative routes for pedestrians, equestrians and cyclists will be signed.

Highways England will continue to work with our partners and relevant stakeholders, including Kent Police, to ensure the safety and security of both local residents and the site. We envisage security being a standing item in the regular reviews of the area when in operation. 007.08 Emergency services The indicative design uses spacing between parked lorries requested by No one has been able to explain to those concerned about an Kent Fire & Rescue. As the design progresses we will continue to engage emergency on the proposed lorry park, where there would be an with the emergency services to ensure that the lorry area meets all their increased risk of fire, for example. This would be an added requirements. burden to the emergency services, which are already overloaded. It appears no one has thought about emergency access if the slip road is blocked (presumably through the village?!) and no thought to what emergency response times would be. 007.09 Terrorism The safety and security of members of the local community, users of the Some worry that a single large site holding multi-nationals could lorry area, and staff is a key priority. We plan to secure the site using a be a target for terrorism. robust perimeter fence with gates for footpaths and bridleways. These gates will be closed when the site is being used to alleviate Operation Stack and alternative routes for pedestrians, equestrians and cyclists will be signed.

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Agency and Kent County Council to ensure that the design of the lorry area does not cause flooding downstream or in its immediate surroundings. Kent County Council Drainage and Planning Policy Statement (2015) sets out the requirements of Kent County Council, as Lead Local Flood Authority, in regard to the management of surface water run-off. Kent County Council is a statutory consultee and will review the proposed drainage strategy for the project. 007.11 Quality of life We appreciate that when the lorry area is in operation this will have an Residents are understandably worried about the quality of life effect on the lives of local residents. However, we held a public consultation which they have worked so hard for will be destroyed, without between 11 December 2015 and the 26 January 2016 to fully test the case so much as the courtesy of being consulted. for a permanent lorry area and to understand the views of the community and other stakeholders.

More than 1,000 drivers, residents and workers attended eight public events during the consultation on the lorry area. Almost 1,300 people, over a dozen organisations and six statutory bodies provided written responses to the consultation.

Of the written responses, the majority of people (55%) supported the idea of creating a new lorry area, with less than a quarter thinking Operation Stack should continue in its current form.

Twice as many people thought the lorry area should be located at Stanford West as those who thought it should be built at an alternative site to the north of junction 11, which would have been closer to an area of outstanding natural beauty. 007.12 Smarter Options: Operation Stack is implemented when either of the cross-channel services Operation Stack is largely the result of man-made causes such is severely disrupted, for reasons such as bad weather, and operational as French industrial action and migrant incursion. These causes problems at the terminals. Industrial action and demonstrations, and, in of the problem should be addressed before spending so much recent instances, migrant action at Calais have also resulted in the Port of money on trying to fix the symptoms. Dover and Channel Tunnel experiencing capacity constraints. An off- highway lorry park will provide a safe and efficient lorry holding facility for use during these periods. 007.13 Upgrade A2 / M2 infrastructure With regard to the A2/M2 corridor, without the lorry park issue, It makes no sense to have a single motorway to both the consideration is being given to improvements to it with a view to capacity, Channel Tunnel and the Port of Dover. The A2 needs urgently safety and access to Dover related issues. This is being considered under

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upgrading to be M2 all the way to Dover. This will mean that the the Government’s Road Investment Strategy 2 (RIS2) programme of bulk of Dover freight can then use the M2, thus distributing the Strategic Road Network investments from 2020 onwards. As you may flow of traffic. It will also offer a better alternative route to port, appreciate, any improvements put forward as part of RIS2 will be subject to should one motorway be closed for any reason, causing less the funding that is made available from Government and the relative disruption. prioritisation of all schemes. Evidence gathering and consultations continue The French have far more major routes to their ports, which is to inform the development of the RIS2 programme and we continue to liaise why they never suffer as we do when they have industrial with stakeholders including Kent County Council, Dover District Council, action. Projections for increased freight over the next few years Port of Dover and others. suggest that more investment should be made into improving infrastructure to relieve the overburdened M20. 007.14 Smaller lorry parks Due to the geographic spread of multiple sites that would need to be £250 million is a huge amount to spend on a facility to be used investigated and the uncertainties and complexities of consenting and infrequently. There are plenty of applications for smaller new or developing these, multiple sites would result in longer timescales for extended lorry parking facilities in Kent, also adjacent to delivery. motorways. Far more suitable for larger numbers of HGV’s on the M20, less than an hour from the tunnel and Dover, is a As part of the changing freight industry, operating practices have also recently available brownfield site at Aylesford. If regular changed substantially with the logistics management centres for each overnight parking is the issue, then smaller lorry parks spread company often instructing drivers to get into the queue for the ports, and across the motorway network in the South would be far more hence make the Operation Stack queue longer, rather than wait at service effective when both major routes are completed. Smaller stations across the country. This is also due to foreign trucks returning facilities will cause less detrimental impact to individual empty to mainland Europe and therefore wanting to queue as close to the communities. ports as possible to minimise non-productive time, it will also help to ensure that ferries sail without unfilled capacity. 007.15 Use of smart Technology We carried out an assessment of alternative options and sites raised during Haulage companies and cross Channel operators could adopt public consultation and one of the options considered was a technology smarter ways of working together by using the smart technology based solution. A permanent lorry area still came out as the most viable available today. This would mean that hauliers, cross-channel option. operators, highways and lorry parks can work effectively together to ensure smooth traffic flow to ports and lorry parks, The use of smart technology is unlikely to be workable without further more efficient booking and loading. development of a model for compliance. For these and other reasons the e.g. instead of lorries gathering on local roads whilst playing off solution is unlikely to be delivered on time or within budget. the ferry and tunnel operators for the last minute best deal, The future operation of the lorry area will include the implementation of tickets should be purchased by app or on line before clogging Smart Technology in the form of Controlled Motorway, which will local routes. automatically reduce the speed limit. Variable message signs will be switched on to indicate which lanes HGVs should follow when Operation Stack is called.

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007.16 Rail Regarding the movement of goods by rail and water the Government aims Freight by rail is a far more sustainable method of transporting to deliver national networks, both road and rail, that meet the country’s long- freight. The UK needs far more investment into this opportunity term need to support a prosperous and competitive economy and improve as a long term measure. overall quality of life as part of a wider transport system. This will include supporting the delivery of environmental goals. In this case the proposals to create a lorry area represent the best solution.

1.8 RR-008 PINS Ref. Relevant Representation from David Lowe on behalf of The Response from Highways England (the Applicant) RR-008 Executors of Marianne Clunies-Ross deceased plus 6 others 008.01 As Freeholders of land (Plots 2/2/a. 2/2/b and 3/2/b on the Land Highways England has provided an alternative access off the old A2070 to Plans) directly affected my clients wish to confirm that they fully the field. support the proposed scheme subject to the following: With regard to the roundabout on the A2070 link road, this roundabout is My clients are prepared to co-operate fully with all parties not part of the Main Scheme put to DCO for approval. This “Alternative providing they achieve their primary objective. This is to ensure Scheme” includes the provision of access in the form of a three –arm that the balance of their land to be returned to them on roundabout midway along the new A2070 link road which would provide completion of the scheme will enjoy the benefit of direct access entry to the proposed Stour Park Development, however it is dependent on to and from the Link Road. This access must be suitable to a financial contribution from the developer. Should funding not be provided serve any future commercial development of that land rather then this Alternative Scheme option will not be included. Should you wish to than the limited replacement agricultural access provided for. progress a development in the future, then access to this potential This same approach has been maintained from the outset of roundabout can be included in a planning application to ABC. However, we this scheme and has been registered with The Highways cannot change the current application that we have now made to the Agency, Highways England and the Developers of Stour Park at Planning Inspectorate for the Main Scheme, to include a potential provision various times throughout the long history of the project. for an unconfirmed alternative option. It is noted from Highways England's submission dated July 2016 that an alternative scheme is being considered. This Regarding the plot of land 3/16/c, Highways England are currently involves the inclusion of a roundabout within the Link Road to undertaking discussions with the landowner. provide access to the proposed Stour Park Development. My clients support this revision because it facilitates development of a valuable motorway related site for commercial development. However if adopted this revision will effectively determine the point at which any access to the Link road will be possible. My clients therefore wish to propose that if this roundabout HA514442-MMGJV-GEN-SMW-RE-Z-10701 38 Revision A

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junction is included provision should be incorporated for a fourth arm. This fourth arm should be on the North side of the roundabout to ensure that the potentially landlocked area between the Link Road and the M20 Motorway is accessible. Linked with this it is further suggested that Plot 3/16/c is acquired by Highways England and then transferred to my clients as part of the land purchase/exchange arrangement. In this regards my clients are prepared to deal with the Land Transfers by negotiation in advance of compulsory powers. I further maintain that the suggestions proposed in these representations provide a practical and logical basis for constructive and equitable forward planning.

1.9 RR-009 PINS Ref. Relevant Representation from DHA Planning on behalf of Response from Highways England (the Applicant) RR-009 GSE Group 009.01 Land at Waterbrook, including land owned by GSE, is identified The assessment within DCO Document 6.1, Chapter 13; The Consideration in Policy CS5 of the adopted Core Strategy for 15ha of of Combined and Cumulative Effects and DCO Document 6.2 Figure 15.1 employment land as part of a mixed use development. It is also was based on the Planning Inspectorate's guidance and incorporated proposed to be allocated in the emerging Ashford Local Plan proposed developments included within the Traffic Model Uncertainty Log, (Regulation 19 Draft) under Policy S16 for a mix of uses as well as additional developments within a 2km buffer. Proposed including a relocated 600 space lorry park, residential and developments were identified using ABC's Planning Application Interactive employment uses. The delivery of the full Waterbrook Map System, ABC's Adopted Core Strategy (Ashford Borough Council, development is reliant on the new motorway junction M20J10a 2008), ABC's 2012 Local Development Framework Urban Sites and and GSE wish to present their views to the Inspector at the Infrastructure Development Plan Document, and through consultation with Examination. ABC's Planning Team. GSE have reviewed the DCO Application including the AECOM Transport Assessment (TA) and the PINS Scoping Opinion. We The TA is consistent with the strategic modelling, which is in turn consistent are concerned that the normal approach to the preparation of with DfT’s current WebTAG guidance, and was also agreed with ABC. It transport assessments has not been followed and that all may differ from what was current guidance at the time of the AHTS commitments necessary to establish the baseline have not been modelling work. included and that future development has been understated. The TA is thus considered to be inconsistent with the Development Plan as detailed in the PINS Scoping Opinion. The TA states that the updated traffic model has its origins based upon the M20 J10a 2010 Transport demand Model, HA514442-MMGJV-GEN-SMW-RE-Z-10701 39 Revision A

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which was an updated version of one used for the Ashford 10a Highway Traffic Study (AHTS). The TA then explains that the model has been further updated sufficiently to enable testing for planned development. 009.02 The local growth forecasts in the TA refer to a ‘Core’ Scenario’ The development quanta in the Core Scenario (and all other scenarios) “founded on the most unbiased and realistic set of assumptions were updated independently of the old AHTS model, and to a newer base that form the central case for the Main and Alternative Scheme. year. Consequently, the development data in the two models is not directly This includes assumptions on local uncertainty in terms of comparable and should not be compared one against the other, not least as delivery, which is typically dependent on whether developments the newer model will include new builds between 2003/2009 (the two AHTS or other planned transport schemes go ahead in the vicinity of demand model updates – see ASR 4.1.2) and 2015, the base year of the the scheme“. GSE do not accept that the full Core Strategy current model. development has been taken into account in the TA, as it was under AHTS, nor that the correct assessment of commitments has been carried out. 009.03 PINS Scoping Opinion explains that Ashford has been identified In terms of the Transport Assessment the derivation of the Core Scenario as a major growth area in Kent with 31,000 additional homes that was used in the network modelling was pursued in accordance with and 28,000 new jobs anticipated in the area by 2031. PINS go DfT’s WebTAG guidance, a process outlined briefly within the TAR by on to state that “The assessment of cumulative and combined paragraphs 3.4.10 to 3.4.12. Overall the Uncertainty Log explicitly effects is particularly important for a number of environmental accounted for 11,189 dwellings being developed in Ashford over the period topic areas, as noted above, and the ES should address each 2015 to 2031 (and 14,270 jobs). This was compared with the Strategic topic area fully”. Ashford Borough Council, in response to the Housing Assessment that had identified a need for 14,345 dwellings in HA’s Scoping Report, advised that the Development Plan Ashford between 2011 and 2030. It was agreed with ABC that the comprises the saved policies in the adopted Ashford Borough difference in numbers of some 3,000 dwellings equated to completions Local Plan 2000, the adopted LDF Core Strategy 2008, the between 2011 and 2015 and developments in rural areas outside the study adopted Ashford Town Centre Area Action Plan 2010, the area. Tenterden and Rural Sites DPD 2010, the Urban Sites and Infrastructure DPD 2012, the Chilmington Green AAP 2013. The quanta of dwellings and job growth outlined in Table 3.9 of the TAR GSE do not accept that the AECOM TA provides the correct was therefore compiled to reflect the overall number of developments that assessment of cumulative and combined effects consistent with were expected to accumulate over the period 2015 to 2031; i.e. up to the PINS Scoping Opinion. The DCO documentation approximately 11,189 prior to categorisation under the various WebTAG understates the Development Plan position for this critical headings of ‘Near Certain’, ‘More Than Likely’, ‘Reasonably Foreseeable’, element of strategic highway infrastructure, which is necessary and ‘Hypothetical’. to deliver full adopted Core Strategy development to 2031. The entire list was compiled in response to discussions and agreement at the time with ABC, and moved forward from base to forecast year. The level of development between the former base year and that revised for the TAR

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therefore accounted for known development delivery over the intervening period.

The actual number of developments that found their way through to the Core Scenario, i.e. those where the ‘Near Certain’ or ‘More Than Likely’ WebTAG conditions applied, resulted in the output shown in Table 3.10. This was essentially a summary of dwelling numbers compiled from the earlier Table 3.8; which had previously identified the specific developments included in the Core Scenario in association with an assumed completion year. The status of Table 3.10 in this respect was confirmed by a commentary in paragraph 3.5.5. From data available at the time the balance of dwellings recorded as the accumulated total over the period 2015 to 2031 and included in the Core Strategy (10,589) set against the equivalent provided by the overall log (11,189) equated to a difference of only 600 dwellings.

One of the main concerns from the above representations is that the Development Plan position may have been understated in the DCO documentation. The purpose of the Uncertainty Log is to ensure that local developments in the appropriate certainty categories are represented explicitly in the modelling, to increase local accuracy. However overall growth in households and jobs at district level is constrained to official DfT forecasts. In the modelling this ‘background growth’ is applied by scaling traffic levels up across each district having first removed the effects of the developments to be treated explicitly. In this way, allowance for growth up to official forecasts is maintained.

This process is explained in greater detail in the Traffic Forecasting and Economic Assessment Reports.

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referenced in the Core Strategy. Without these measures, the results led to some local network stress by 2033, mainly on the development access roads; with the additional measures, these accesses were considerably improved.

In summary, the forecasts for the current work are all estimated from the base year of 2015, on the basis that traffic associated with all completed developments up to 2015 is implicitly accounted for in the observed base year traffic flows and conditions that the base model is set up to replicate as closely as practicable. The forecasts are then split into two parts: development from 2015 in the local area, which is modelled explicitly to increase model accuracy in the areas of greatest interest; and ‘background’ growth associated with more widespread developments that it is not practicable to attempt to model explicitly. The latter are instead dealt with by factoring up base year trips not associated with explicitly-modelled developments according to official DfT growth forecasts at district level. The overall growth must be controlled to these official forecasts at district level. Thus the more developments that are modelled explicitly, the greater the reduction in the background growth factors such that the total number of trips remains constant. This process is set out in DfT’s WebTAG guidance, and was agreed with ABC. There may be differences in approach and assumptions since the AHTS model, but in principle the quanta of development for each proposed scheme, the likelihood of these schemes being built, and the dependency of each scheme on the M20 J10a in the final Uncertainty Log were as per the best opinions of all relevant bodies, including ABC, at the time that the Uncertainty Log was finalised.

1.10 RR-010 PINS Ref. Relevant Representation from Elizabeth Kerr Response from Highways England (the Applicant) RR-010 010.01 My concerns are regarding the configuration of traffic on the The Scheme has been designed to all relevant guidelines. triangle of roads and roundabouts formed by the addition of 10a. 1. The proposed highway alignment has been designed in accordance with I fear 1 minor accident will bring the whole thing to a stop and the Design Manual for Roads and Bridges (DMRB) standards which take cause backlog on and off the motorway. into consideration all users of the highway including motorcyclists. 2. A Road Restraint Risk Assessment Process (RRRAP) analyse has been undertaken and the results applied using TD19/06. Where this process HA514442-MMGJV-GEN-SMW-RE-Z-10701 42 Revision A

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determines that a vehicle restraint system is required the appropriate barrier will be specified in accordance with current guidelines and best practice. 3. Road signs are designed in accordance with the Traffic Signs Manual DMRB and other relevant standards and guidance notes. The sign locations are reviewed as part of the safety audit process considering the risks to all users of the highway. 4. Due to the location of the proposed Junction 10A the existing east facing slips of Junction 10 are to be closed to ensure there is sufficient distance between successive merges or diverges in accordance with the DMRB.

010.02 I am concerned about the location, as it falls on a bend of the The existing M20 is designed in accordance with standards (DMRB). The London bound carriageway, which has already seen several existing radius in the location where Kingsford Bridge is proposed is approx. accidents at the point of the new off ramp. 2209m. TD9/93 allows a minimum radius with superelevation of 2.5% of 2040m. The existing radius also complies with the visibility requirements. Our proposed Scheme and off slip will enhance the forward visibility. The visibility on the approach to the slip road is within the standards required at this location. 010.03 I am concerned that the pollution from standing traffic will The impacts of the Main and Alternative Schemes on Air Quality are increase, in an area close to the local hospice and hospital described in DCO Document 6.1, Chapter 5. The Scheme traffic data showed that there were no changes in traffic characteristics that trigger the need for an air quality assessment within 200m of the William Harvey Hospital. Roads that trigger an air quality assessment are referred to as the affected road network (ARN) and are presented in DCO Document 6.2, Figure 5.2 Operation Phase Study Area for Main and Alternative Schemes. Beyond 200m, the effect of changes in traffic characteristics, and therefore emissions, can no longer be distinguished from ambient concentrations. Therefore the William Harvey Hospital was not included as a receptor in the air quality assessment. Concentrations predicted close to the Pilgrims Hospice are well below the relevant air quality objectives. Additionally, there are predicted improvements in air quality along the section of the A20 adjacent to the Pilgrims Hospice during the operation of the Main and Alternative Schemes.

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1.11 RR-011 PINS Ref. Relevant Representation from Environment Agency Response from Highways England (the Applicant) RR-011 011.01 Flood risk assessment DCO Document 6.3, Appendix 14.1 the Flood Risk Assessment (FRA), has We do not consider that the Flood Risk Assessment (FRA) is assessed the flood risk from the Main and Alternative Schemes. Following complete. Further information is required to show that flood risk receipt of comments from the Environment Agency, the FRA will be updated will not be increased by this development. The following during the detailed design stage to assess the effects of the proposed information should be provided at this stage, in advance of a structures within FZ3. This will include flood modelling, using the grant of a DCO: Environment Agency's 2012 Aylesford Stream model, to determine the - Information to demonstrate that there will be no loss of extent of the changes in the flood zone due to the proposed slip road floodplain storage as result of the development. This applies in embankments and mammal ledge within the Lacton Farm culvert, and any particular to the proposed slip roads which are shown within the mitigation measures required as a result. These mitigation measures will flood zone. The FRA must be updated to include an assessment ensure that there will be no increase in flood risk as a result of the Main and of the loss of flood storage, and provide compensation storage Alternative Schemes, in accordance with the NPPF. on a level for level, volume by volume basis. - A modelled assessment of the proposed mammal ledges The updated 2012 Aylesford Stream model has been provided by the EA within the Lacton Farm culvert to demonstrate that channel and we hope to complete the FRA updates by the topic specialist hearings capacity will not be affected upstream/ downstream of the M20. in February 2017. Modelling should use the Environment Agency’s most up to date fluvial flood model, which is currently the ‘Ashford Updates The proposed soffit level of the animal pipe bridge over the Aylesford Model, 2012’. We will need to see drawings of the mammal Stream will be included in the flood modelling that is ongoing for the FRA ledge proposed within the culvert. update and these details agreed with the EA. 011.02 Access to the Aylesford Stream Satisfactory access to the Aylesford Stream will be maintained via gated We also require additional information and drawings to show access roads. that our access to the Aylesford Stream will be maintained. We need access to the Aylesford Stream to allow us to carry out We have submitted drawings showing our proposals and further discussion maintenance as part of our flood risk management role. We will will be undertaken with the Environment Agency; these will be documented need to see drawings of the new access tracks and any in the Statement of Common Ground (DCO Document 8.3). temporary or permanent structures in or within 8 metres of the Aylesford Stream (for example bailey bridge, coffer dams, over pumping arrangements, compounds, fencing, outfalls). We will also need to see details of the proposed mammal pipe bridge and associated fencing. This will help us understand whether, and how much of our access to the channel will be blocked by this structure. It may be sufficient to secure this information by requirement HA514442-MMGJV-GEN-SMW-RE-Z-10701 44 Revision A

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once the DCO has been granted, or through the protective provisions. We would be happy to provide more details on what sort of information we will need to see. 011.03 Land contamination and groundwater protection Ground investigation has been carried out and a Contaminated Land Risk The proposed works present a risk of groundwater pollution by Assessment (CLRA) has been produced (DCO Document 7.4). mobilising contaminants that are in this area. It should be possible to mitigate these risks however through appropriate There is to be no piling in the vicinity of Mersham Quarry and a backfilled requirements on the DCO. There will need to be requirements to historical quarry (referred to as Hythe Road Quarry in the CLRA) located cover: beneath the existing carriageway in the vicinity of the proposed East Bridge - Site investigations St Key 33031 is therefore the only location where piles could penetrate - Remediation strategy through a former backfilled quarry. - Verification report to confirm the completion, and effectiveness of measures carried out under the remediation strategy However, given the wealth of existing recent ground investigation - Piling risk assessment information in the vicinity of the Scheme, it is proposed to undertake - Monitoring and maintenance plan foundation works risk assessments without undertaking additional ground - Surface water drainage plan, limiting infiltration drainage to investigation. only those areas of the site where it has been demonstrated that there is no resultant pollution risk to the groundwater. Groundwater level monitoring and groundwater samples for analysis will be carried out on a quarterly basis to provide a baseline to groundwater quality prior to construction, using standpipes installed in the 2015 ground investigation.

A surface water drainage plan is provided as an appendix to the Flood Risk Assessment (DCO Document 6.3, Appendix 14.2).

The proposed approach to construction adjacent to the known contaminated site (former landfill at Mersham Quarry, to the north of the M20) and approach to any contamination discovered during the construction of the Scheme, as set out in the Environmental Statement, Outline Environmental Management Plan and draft DCO, is acceptable. 011.04 Contaminated land desk study and preliminary Ground investigation has been carried out and a Contaminated Land Risk interpretative report dated July 2016 Assessment (CLRA) has been produced (DCO Document 7.4). This report assessed groundwater to be at risk from historic sources. This is due to vertical migration of leachates, and There is to be no piling in the vicinity of Mersham Quarry and a backfilled vertical and horizontal migration of contaminants in the historical quarry (referred to as Hythe Road Quarry in the CLRA) located saturated zone. The introduction of mitigation measures during beneath the existing carriageway in the vicinity of the proposed East Bridge

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construction works will not reduce this risk, as it is already St Key 33031 is therefore the only location where piles could penetrate present prior to construction. The report also indicates that through a former backfilled quarry. groundwater is at risk from man-made contaminant transport pathways (e.g. piles). We agree with this assessment and the However, given the wealth of existing recent ground investigation mitigation methods proposed, including the production of information in the vicinity of the Scheme, it is proposed to undertake foundation works risk assessments, to be written in accordance foundation works risk assessments without undertaking additional ground within the relevant Environment Agency guidance. investigation.

Groundwater level monitoring and groundwater samples for analysis will be carried out on a quarterly basis to provide a baseline to groundwater quality prior to construction, using standpipes installed in the 2015 ground investigation. 011.05 Piling near landfills From investigations it appears that Mersham Quarry landfill is not an There is a historic landfill adjoining the site. We are very engineered landfill but a backfilled quarry. Capping being a thickness of concerned about piling operations in close proximity to, or made ground rather than an engineered cap and there is no liner. Having through historic landfill sites, as this may cause leachate and said that, no piling works are proposed in the vicinity of Mersham Quarry, landfill gas release. It is therefore essential that the filled areas therefore there is limited risk of disturbance of leachate and landfill gas have been characterised fully, including any capping layers or release. liners which could be compromised by the introduction of piles. It is likely that more ground investigation will be necessary in A backfilled historical quarry (referred to as Hythe Road Quarry in the these areas to gather this information. Contamination risk Contaminated Land Risk Assessment (CLRA) (DCO Document 7.4) is assessments should be updated accordingly. The borehole and located beneath the existing carriageway in the vicinity of the proposed East trial pit logs for exploratory hole positions did not appear to be Bridge St Key 33031. This is the only location where piles may possibly available within the document. penetrate through a former backfilled quarry, however the requirement for piling is a conservative estimation and the majority of these structures will potentially end up being constructed on spread footings once detailed design has been completed. On that basis, given there is to be no piling in the vicinity of Mersham Quarry and the wealth of existing recent ground investigation information in the vicinity of the Scheme we believe we can undertake foundation works risk assessments without undertaking additional ground investigation.

Groundwater monitoring will be carried out on a quarterly basis, using standpipes installed for the purposes of the Ground Investigation (GI) carried out in 2015.

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011.06 Groundwater monitoring Groundwater level monitoring and groundwater samples for analysis will be The Outline Construction Environmental Management Plan carried out on a quarterly basis to provide a baseline to groundwater quality suggests that selected water courses will be sampled during prior to construction, using standpipes installed in the 2015 ground construction operations. Given the potentially contaminative investigation. historic uses, proposed piling, and sensitive groundwater receptors, this should also include groundwater analysis. Baseline groundwater quality data would need to be provided, and should include more than the single round of groundwater analysis currently undertaken. 011.07 Ecology Noted. We are satisfied that the proposed ecological mitigation is appropriate. We can also confirm we believe that from an ecological perspective the scheme is compliant with Water Framework Directive requirements. This is because we do not believe that the proposed works to the Aylesford Stream will cause deterioration to the stream or wider waterbody. 011.08 Protective Provisions Noted. Highways England seeks to disapply various pieces of legislation (in the draft Development Consent Order submitted with the application). We are currently considering our position in relation to the legislation which is relevant to the Environment Agency. The draft protective provisions included by Highways England in the draft DCO are similar to those accepted by the Environment Agency in the past but we are currently reviewing our preferred form of protective provisions (in particular because flood defence consenting now falls under the Environmental Permitting Regulations 2010 as of April of this year rather than under the Water Resources Act 1991 as it did previously). We will be responding to the applicant on these issues in due course and will provide the Examining Authority with an update.

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1.12 RR-012 PINS Ref. Relevant Representation from Geoffrey Fletcher Response from Highways England (the Applicant) RR-012 012.01 I am deeply concerned that the application does not include the Highways England considers this request to be outside of the scope of the closure of Kingsford Street from Highfield Lane, and that this is Scheme. There is no justification from traffic modelling to justify this left to other parties at some future stage. This application incorporation in the Scheme. necessitates the closure of Highfield Lane to the A20, so there will be a rat run through the village. Highways England have been informed by Stour Park Developers that this work has been included in their section 106 agreement with ABC. Highways England will work closely with Stour Park Developers to ensure that this will be incorporated.

The last traffic assessment of the Barrey Road Junction was done prior to 2013 when permission to occupy the empty units in the Ashford Retail Park was given, and at that time it was indicated that there would be a negligible impact on traffic overall. Therefore before the Scheme starts we have already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

Furthermore after a meeting on 30 November 2016 with Local Authorities and local businesses further discussions between Highways England Area HA514442-MMGJV-GEN-SMW-RE-Z-10701 48 Revision A

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1.13 RR-013 PINS Ref. Relevant Representation from George Koowaree Response from Highways England (the Applicant) RR-013 013.01 I do welcome the Junction 10a on the M20. I would like to see Highways England understand concern regarding the Barrey Road exit onto Traffic Lights at the Junction of Barrey Road with the A2070. the A2070, we notice that a number of residents have raised similar even if will more than the planned junction before junction 10 concerns in the relevant representations. this will not solve the risk of a serious accident at that junction The last traffic assessment of the Barrey Road Junction was done prior to specially now the Commercial Centre service by Barry Road 2013 when permission to occupy the empty units in the Ashford Retail Park has had more retail shops with an increase in footfall. The new was given, and at that time it was indicated that there would be a negligible signage will not solve the problem of joining the A2070 or impact on traffic overall. Therefore before the Scheme starts we have entering the Centre. Please let have traffic lights. already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

1.14 RR-014 PINS Ref. Relevant Representation from Georgina Mayes Response from Highways England (the Applicant) RR-014 014.01 I really disagree in keeping Kingsford street open at the Highways England considers this request to be outside of the scope of the Highfield road and Kingsford street junction as it will be so Scheme. There is no justification from traffic modelling to justify this dangerous and cause disruption. Kingsford street is a country incorporation in the Scheme. lane and not design for a lot of traffic, which will happen being used as a rat run if there are delays on the A20. This road is a HA514442-MMGJV-GEN-SMW-RE-Z-10701 50 Revision A

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village lane with families with young children and animals i.e. Highways England have been informed by Stour Park Developers that this dogs and horses/ponies. Buses currently come down here and work has been included in their section 106 agreement with ABC. Highways should go on the main road out of Mersham to the A20 as there England will work closely with Stour Park Developers to ensure that this will are no bus stop on Kingsford street and there is no need for be incorporated. them to go down Kingsford street which make it hard in a car to pass the buses as the road is not designed for them. Not closing Highways England have also been informed by Kent County Council that Kingsford street is a disaster waiting to happen. they will forward fund this work and will implement before the opening of Scheme. They will work with Stour Park Developers to form an agreement.

1.15 RR-015 PINS Ref. Relevant Representation from Gillian Miller Response from Highways England (the Applicant) RR-015 015.01 The effect of disruption during building process. And then the The Effect of disruption is considered in+B10ters including DCO Document increase lighting, and noise ruining our quiet country life the 6.1, Chapter 7; Landscape, DCO Document 6.1, Chapter 11; Noise and additional dust and dirt from lorries and cars being so close to Vibration, DCO Document 6.1, Chapter 5; Air Quality, and DCO Document our property, 6.1, Chapter 13; Community and Private Assets. In addition, the combined The damage to the house foundations with drilling and building effect of these effects are further considered in DCO Document 6.1, the new slip road and later the noise of Lorries as they change Chapter 15; Consideration of Combined and Cumulative Effects. down coming up the slope to the new junction 10a Construction noise and vibration will be controlled during construction, and a permanent noise barrier will be installed as part of the Scheme mitigation. Survey of the property foundation can be carried out prior to construction works to ensure that the vibration from the proposed works will not affect the property. 015.02 Kingsford street is at present a country lane this will either Highways England considers this request to be outside of the scope of the change, either it will become a rat run for Ashford traffic Scheme. There is no justification from traffic modelling to justify this avoiding the roundabout, or it will be closed off and mean we incorporation in the Scheme. would have an extra 2 miles plus run each way in order to get into Ashford and we would not have acts to Highfield Lane. Highways England have been informed by Stour Park Developers that this work has been included in their section 106 agreement with ABC. Highways England will work closely with Stour Park Developers to ensure that this will be incorporated.

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1.16 RR-016 PINS Ref. Relevant Representation from Gowling WLG LLP on behalf of Response from Highways England (the Applicant) RR-016 Friends Life Limited/ Aviva Investors 016.01 Friends Life Limited and Aviva Investors (the "Interested Party") Noted. owns and controls the land known as Sevington, north of Highfield Lane. Sevington is allocated in local planning policy for major employment development. Friends Life submitted an outline planning application to Ashford Borough Council (the “Council”) for such a development on part of this land, known as “Stour Park” (the “Development”). The Development is referred to in section 2 of the Statement of Reasons. The Council resolved to grant planning permission for the Development, a section 106 agreement is near to being finalised and outline planning permission will be granted shortly. 016.02 The Interested Party supports the Scheme in principle. Noted. However, it objects to the proposed compulsory acquisition of its land on the grounds that it is both unnecessary and would significantly prejudice the Interested Party’s ability to deliver the Development. 016.03 The Interested Party objects to all of its land being included in Noted. the compulsory acquisition, in particular the following plots: 016.04 3/16/a It is not necessary for the Applicant to acquire the The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides entirety of this plot for the stated purpose - a section of the plot full details of the Main and Alternative Scheme’s proposals, including the would be sufficient. The Interested Party has included part of demolition of the existing Church Road Footbridge and the provision of a this plot abutting Church Road for a future development of the new footbridge accommodating pedestrians and cyclists. The proposal adjacent Batts Farm yard. includes new ramps on both side of the A2070. Part of the land needed for this is owned by Friends Life Limited, and Highways England need to permanently acquire approximately 4052.9m2 of land forming part of the existing Church Road- east side. This land is essential to maintaining the existing screening of Sevington from the A2070 and this land parcel is a key part of the dormouse mitigation strategy. If this land were removed from the dormouse licence (M20 Junction 10a Ghost licences (Main and Alternative) for Dormice submitted to Natural England in September 2016) it is likely that Natural England would refuse to grant the licence, as in order to grant the licence Natural England requires either proof of land ownership or a letter of long-term support for the mitigation proposals. It is felt that compulsory HA514442-MMGJV-GEN-SMW-RE-Z-10701 52 Revision A

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acquisition of the land is required to reduce the risk of Natural England refusing the licence.

This matter is currently under discussion. Highways England to compare the areas required for the ecological mitigation strategy and the parking provision along Church Road, to see if both can be accommodated with no reduction in area of the proposed dormouse mitigation measures. 016.05 3/16/b It is not necessary for the Applicant to acquire this plot for The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides the stated purpose of creating a balancing pond. The Interested full details of the Scheme’s proposals, including the new A2070 Link Road Party intends to construct a balancing pond in this location and balancing ponds, for which it will be necessary to permanently acquire pursuant to the planning permission for the Development and approximately 73966.8 square metres of land. Any increase in the size of has offered to the Applicant that it will create a sufficiently large this balancing pond will most likely affect the existing trees surrounding it pond that can be serve both the Development and the Scheme. and will affect our arboriculture assessment and landscape design. In This would create a significant saving to the public purse. If this theory it is possible for Highways England and Friends Life to share the plot is taken and the Applicant build a pond for its sole use, the balancing pond, although it would need to be enlarged to accommodate Interested Party will need to have to divert all surface water to run-off from both sites. the south of the Stour Park site, creating an environmental impact which has not been tested in the Applicant’s This matter is currently under discussion. Highways England will provide Environmental Statement. details of the proposed drainage areas, runoff rates and outfall locations, to allow Friends Life’s drainage proposals to be updated to accommodate both schemes. A legal agreement will be required to protect both parties in the event of a pollution incident. 016.06 3/16/cde It is not necessary for the Applicant to acquire these Highways England to discuss with Friends Life their proposal for plot 3/16/c. plots for the stated purposes. 3/16/c is land which the Interested The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides Party has planted with wild flora to provide ecological mitigation full details of the Scheme’s proposals. It will be necessary to temporary in relation to the Development. The Applicant’s compound could acquire land (plot 3/16/d) with rights to be acquired permanently be easily located on the neighbouring open land to the north approximately 1898.6 square meters of land located south of existing M20, west of this plot. new right to construct, divert, remove, use and maintain utility connections and equipment including a mains gas pipeline including access with or without vehicles plant and machinery. The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides full details of the Scheme’s proposals. As part of the Scheme’s proposals, it will be necessary to permanently acquire approximately 7897.7 square metres of land (plot 3/16/e) required for the construction of slip road. This area is included within our environmental masterplan. This area provides connective habitat and foraging areas for multiple protected species, and is HA514442-MMGJV-GEN-SMW-RE-Z-10701 53 Revision A

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included as replacement habitat for that lost on site. However, it is possible to carry out the works so that both the Junction 10a and Stour Park mitigation measures can be accommodated and discussions are ongoing with Stour Park to this effect.

Under Discussion Highways England to provide details of the works in plot 3/16/e, including timing of works. 016.07 4/16/ab Acquisition of these plots is unnecessary. More The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides comprehensive environmental mitigation is proposed by the full details of the Schemes proposals. It will be necessary to temporary Interested Party as part of the Development; acquisition of this acquire with rights to be acquired permanently approximately 1606 square land would prejudice the future development of Sevington (East) meters of land located south of Kingsford Street for the environmental envisaged in the local plan. mitigation purpose. Is proposed that the existing pumping station will be relocated to the back of the proposed maintenance lay-by.

Under Discussion 016.08 4/16/c This plot is the land upon which the Interested Party is Kent County Council are now installing a turning head under a S278 required under its section 106 agreement to provide a turning agreement with Friends Life. circle to enable vehicles to exit Highfield Lane. This is a legal obligation on the Interested Party which it would not be able to Highways England to discuss this plot with Friends Life. comply with if this plot were taken. 016.09 4/16/d It is not necessary for the Applicant to acquire these As part of the Scheme’s proposals, it will be necessary to permanently plots. More comprehensive environmental mitigation is acquire approximately 1903.3 square metres of land located back of proposed by the Interested Party and compulsory acquisition of Kingsford Street houses. The land is required for hedgerow planting this land would be contrary to best use of this land as promoted included within the environmental masterplan and dormouse mitigation through the local plan process. strategy. This habitat is to replace hedgerows lost due to the Scheme and will increase connectivity to the wider area. This hedgerow provides an important corridor for dormice that are being displaced during construction and whilst the replanted habitat along the M20 verge establishes. The hedgerow is also required to achieve a net gain in biodiversity. Agreement has been reached with Friends Life on this land parcel.

016.10 4/16/efg It is not necessary for the Applicant to acquire these Highways England to discuss with Friends Life their proposal for plots plots for the stated purpose. The creation of balancing ponds 4/16/efg. within the Scheme and elsewhere within the Development provide excellent habitat. Acquisition of this plot and its use for HA514442-MMGJV-GEN-SMW-RE-Z-10701 54 Revision A

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habitat would prejudice the future development of Sevington (East) envisaged in the local plan. 016.11 The Interested Party has throughout provided the Applicant with Highways England would like to cooperate with Friends Life and agree the all information necessary to avoid or minimise the above issues. solution regarding the land and productive discussions are underway. However the Applicant has not taken this into consideration and as such has not fully complied with its statutory to consult. Neither has the Applicant made a proper attempt to acquire land by agreement. The Applicant has failed to demonstrate a compelling case that the acquisition of the Interested Party’s land is necessary and that there is a compelling case for it.

1.17 RR-017 PINS Ref. Relevant Representation from Heidi Milner Response from Highways England (the Applicant) RR-017 017.01 I work on the Ashford Business Park and absolutely dread the Highways England understand concern regarding the Barrey Road exit onto drive to and from the estate five days a week. the A2070, we notice that a number of residents have raised similar There is only the one road in and out of the estate and to say it concerns in the relevant representations. is extremely dangerous and a major understatement. To enter the estate while travelling from the Junction 10 The last traffic assessment of the Barrey Road Junction was done prior to roundabout you need to 'play chicken' crossing two lanes of 2013 when permission to occupy the empty units in the Ashford Retail Park traffic which is travelling at 70mph !! was given, and at that time it was indicated that there would be a negligible To leave the estate you need to join the road, starting from zero impact on traffic overall. Therefore before the Scheme starts we have mph trying to join a road where the traffic is speeding along at already put in place enhancements to the A2070 and Barrey Road by 70mph, so dangerous I cannot believe that nobody has yet been improving signage and visibility at the junction, and we will be reducing the killed. speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for Nearly everyone I have spoken to has had their car hit up the right hand turns around the link road roundabout as part of the Scheme. rear where they are leaving the estate realise there isn't time to join the traffic where it is speeding over the hill, put their brakes Any subsequent amendment to this junction would require a Traffic on and subsequently gets hit by the car behind. Assessment of the Ashford Retail park and residential traffic impact to be To add to the misery new shops have been added to the park initiated by the local network authority at the request of local stakeholders, making the traffic a nightmare. which is not part of the Scheme as Highways England Major Projects deals If leaving the estate at 17.00hrs it takes at least half an hour just with Nationally Significant Infrastructure (NSIP) Construction. to get onto the Bad Munstereifel Road. I cannot imagine what it is like for those poor people living in the Furthermore after a meeting on 30 November 2016 with Local Authorities village of Sevington having to cope with the situation seven and local businesses further discussions between Highways England Area HA514442-MMGJV-GEN-SMW-RE-Z-10701 55 Revision A

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days a week. 4 Spatial Planning and Kent County Council were planned, and they are A set of traffic lights would surely be the most sensible solution currently on-going, to resolve any existing traffic issue ahead of the Scheme, which is supporting the discussion by providing the relevant data and additional traffic surveys.

1.18 RR-018 PINS Ref. Relevant Representation from Historic England Response from Highways England (the Applicant) RR-018 018.01 Summary In response to Historic England’s comments and as part of the Statement of Historic England agrees with the applicant’s Environmental Common Ground, the following has been produced to support the Statement (ES) that there would be serious harm to the application and has been provided to Historic England: significance of the grade-I listed St Mary’s Church, Sevington - A Statement of Significance for St Mary's Sevington and Court Lodge from the proposed development in its setting. However, we don’t Farm and Barn. This provides additional baseline information on the think this assessment provides all the information required to be evidential, contextual, historical, architectural and communal significance of clear about the precise nature or extent of that harm. It does the assets. not, for example, provide any illustrative materials, such as - An additional assessment of the potential of the effects of the operation of photomontages or 3-D modelling, to explain the visual impacts the Scheme on St Mary's Church. This found the effect to be negligible. in this case, which we consider to be a key consideration in this - A photomontage from the churchyard of the Scheme after year 1 and year case. Without fully explaining the impacts on significance, we 15. don’t think it has been possible to undertake a proper process of - A cross section (north west to south east) across the link road roundabout, minimising the harm (para. 5.129 of the National Planning noise barrier and proposed landscape planting. The drawing also includes Statement for National Networks (NPS)), and it is not in our view the retained tree/hedge line between the church and the link road. yet possible to balance the residual harm with public benefits in - Information on the current usage of the church and use of the surrounding the manner set out in paragraph 5.134 of the NPS. PROWs. This indicates a low level of usage. Because Historic England’s role is to advise principally on the most highly graded assets, this letter focuses on St Mary’s Church only. That should not, though, be taken as implying that effects on other aspects of the historic environment are not an issue in this case. We defer to Ashford Borough Council and the Council’s archaeological advisors at Kent County Council to give detailed advice on grade-II listed buildings, registered parks and gardens, conservation areas and undesignated heritage. This is because they are best placed to advise on local historic environment issues and priorities, including access to data held in the Historic Environment Record (formerly Sites and Monuments Record). HA514442-MMGJV-GEN-SMW-RE-Z-10701 56 Revision A

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018.02 Historic England Advice See 018.01 comments above. Historic England has been involved in pre-application discussions with the applicant and in our most recent letter of advice of 10 March 2016 we raised two issues in relation to the church of St Mary Sevington, a grade-I listed building. Firstly, we advised that there were likely in our view to be both visual and aural impacts of the scheme that would affect the way in which the church is currently experienced. We secondly raised the possibility of impacts on the future use and viability of the church. These issues were identified on the basis of the following assessment of the church’s significance. 018.03 Significance Further information has been provided to Historic England in the Statement Sevington is a small historic settlement to the southeast of of Significance for St Mary’s Church and Court Lodge. This can be found in Ashford. Until the twentieth century, Sevington, the the Statement of Common Ground (DCO Document 8.4, Appendix A). neighbouring parish of Willesborough and hamlet at Lacton Green, were all completely distinct from Ashford. They each consisted of small clusters of farmsteads and labourers’ cottages from which the expansive surrounding agricultural landscape was worked and its produce taken to market in Ashford. Despite later substantial expansion of Ashford that has subsumed Willesborough and Lacton Green, firstly with the introduction of the railway in the mid nineteenth century and then in more recent times as a government-defined growth area, Sevington has remained a distinct historic settlement in an agricultural setting. That setting has already been compromised to an extent by its close proximity to the A2070 by-pass of Ashford to its west and the M20 to the north. However, despite the physical and aural intrusions of this modern infrastructure, Sevington retains a strong sense of its historic setting. The church is still encircled by fields and sits on high ground above roads which are fairly well screened from it by trees. Sevington was recorded in Domesday as a small agrarian settlement served by a church. By the end of the eighteenth century the great Kent historian Edward Hasted described it in his The History and Topographical Survey of Kent (1798) as a

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parish of only eleven houses, with its church standing on rising ground overlooking the weald. That picture has remained remarkably and unusually unchanged up to the present, with the majority of those eleven houses still surviving and now listed at grade II; the spire of the grade-I listed church continues to stand proud on elevated ground and its physical presence is a reminder of its former dominance also in the lives of the local community. Together this largely unaltered ensemble provides an extraordinary sense of continuity with the past. The bulk of the church of St Mary, Sevington is Norman, i.e. it is in part the same church as, or at least a close successor to, the one mentioned in the Domesday Book. The adjacent farmstead at Court Lodge also has medieval origins and may either have been the manor house or, possibly, a grange to Christ Church Priory, Canterbury. Granges were outlying farming estates belonging to a monastery. They were concerned with food production and often contained barns for the collection of tithes. Around the central core of buildings would have been a system of fields farmed by the grange. Those fields illustrate why it would have been desirable for a grange or a more conventional farm to be based in this location. The other buildings in the settlement were all related in one way or another to working the land. Sevington’s landscape setting of fields and hedgerows is therefore not only a highly attractive buffer to the encroachment of Ashford and backdrop to the church, but is also of historical value for illustrating why this significant place came in to being. This setting therefore makes a key contribution to the significance of the place as a whole, as well as to its constituent heritage assets. The same is to some extent likely to be true of the heritage assets at Willesborough, Lacton Green and Mersham etc. that have been identified in the Environmental Statement as being within 1km of the application site, but for reasons stated above are not covered in detail in this letter. 018.04 Proposal Agreed, the impacts and effects will be identical. This application proposes a new junction 10a on the M20

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motorway at Ashford. It also proposes highway works to connect this new junction to the surrounding trunk and classified road network. The application also proposes an ‘alternative scheme’, which includes all of the above development, plus a new access roundabout in the event that a current planning application for the Stour Park Development, located immediately south of the proposed A2070 link road, is granted and implemented. We think that the heritage impacts of both the main and alternative schemes are almost identical. 018.05 Impact See 018.01 comments above. The significance of a heritage asset can be harmed both by physical change to it and by development in its setting (para 5.122 of the NPS). The DCO scheme (and the proposed alternative) does not propose alterations to any designated heritage asset, but it does propose major change within the settings of multiple assets. For the reasons stated above, our advice focusses on the impacts that this proposed development in the setting of the church of St Mary, Sevington will have on its significance. Setting is important in this case because of the way that the agricultural landscape surrounding the church continues to tell a centuries-old story of a rural community served by and, by virtue of the height of its spire, dominated by its parish church. The church consequently has a strong visual and historical link with that agricultural land, which, despite the intrusion of nearby infrastructure, provides tranquil and attractive surroundings from which the church’s aesthetic value can be appreciated. The proposed interchange junction and new roads linked to it would result in harm to the significance of the church by contracting the agricultural land around it, and by changing the character of that landscape so that it becomes much more dominated by highways infrastructure. These impacts are acknowledged at table 6.9 of the ES. We agree with the conclusion that there would be harm to the significance of the church, but there is no supporting analysis to explain how conclusions about the level of harm in this case have been

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reached. For example there is no assessment provided to explain the nature of the church’s significance or the particular contribution made by its setting. This is a requirement of paragraph 5.127 of the NPS. There is also no visual material provided, such as photomontages or 3-D modelling, to explain the visual impacts in this case (para 5.126). We would expect the ES to be more specific about the nature of significance and then to demonstrate in much greater detail the effects of the proposed change on that significance. Without this detailed assessment we find it difficult to support the conclusions of the ES. 018.06 We advised in our pre-application letter of 10 March 2016 that See 018.01 comments above. the harm in this case could be mitigated, but not eliminated, with soft landscaping buffers to shield views of the road from the churchyard. We are concerned that the red-line boundary of this application does not offer much of an opportunity for a dense landscape buffer in this case, and we consequently think that more could be done in this regard to mitigate the above harm. We think that photomontages would be helpful in demonstrating the effects of landscape buffering. Any noise associated with traffic on the new roads above and beyond the current situation may also erode what still remains of the rural tranquillity of that setting. Again this potential effect on the setting of the church is acknowledged in tables 6.9 and 6.10 of the ES, but there is no information provided to explain the overall impacts of traffic noise from the proposed network of roads around the church. We note, however, at paragraph 11.9.2 of Chapter 11 of the ES (Noise and Vibration, Volume 6.1), that because of lower speed limits along the A2070 traffic noise along this route would reduce. Although this is the road is closest to the church, there would be additional noise generated from the roundabout and dual-carriageway link to the north of the church that has not be quantified in relation to the church. 018.07 Policy See 018.01 comments above. Paragraph 5.131 of the NPPS requires that when considering the impact of a proposed development on the significance of a

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designated heritage asset, the Secretary of State should give great weight to the asset’s conservation. He should also take into account the desirability of sustaining and, where appropriate, enhancing the significance of heritage assets, the contribution of their settings and the positive contribution that their conservation can make to sustainable communities – including their economic vitality. This point about economic vitality is reinforced by the Planning Practice Guidance (Conserving and Enhancing the Historic Environment: paragraph 13), which states that when considering the impact of development within the settings of designated heritage assets, ‘they [the determining authority, in this case the Secretary of State] may also need to consider the fact that developments which materially detract from the asset’s significance may also damage its economic viability now, or in the future, thereby threatening its ongoing conservation (PPG, para. 13). We set out our concerns above about the effects of the proposed development on the viability of St Mary’s Church, but this guidance may also apply to other assets around the development site, such as the farm at Court Lodge Farm. As stated above, paragraph 5.127 of the NPS requires that applicants describe the significance of any heritage assets affected, including any contribution made by their setting. We are not satisfied that this has been done in sufficient detail to then be able to assess the impacts on that heritage significance in the manner of paragraph 5.126, and to then minimise those impacts as required by paragraph 5.129. Where there is harm to heritage significance resulting from a scheme, the NPS requires that this has ‘clear and convincing justification’ (para. 5.131) and is weighed against the public benefits of the application (para. 5.132). In this case we think it is likely that serious harm would result to the significance of the grade-I church of St Mary, Sevington, but as described above we do not think this harm has been adequately explained. We nonetheless think it is unlikely that this harm would reach the threshold of substantial, and it should therefore be treated in

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accordance with paragraph 5.134. Prior to this exercise of balancing of harm and public benefit, the harm first needs to be minimised (para 5.129), for example with landscape buffering to reduce the visual impact if the scheme from the church. 018.08 Recommendation See 018.01 comments above. Historic England recommends that further information is required to explain the nature of the church’s heritage significance and the extent of impact on that significance. We recommend that this information should then be used to minimise the harm to significance, before this is weighed against the public benefits of the application.

1.19 RR-019 PINS Ref. Relevant Representation from Ian Scollick Response from Highways England (the Applicant) RR-019 019.01 As a Sevington resident my property will be in the vicinity of the Noted. proposed road scheme and I will be directly affected by J10A which I expect to use on a daily basis. I would like to be able to make comment on the scheme, and on any proposed modifications to the Barrey Road/A2070 junction which provides the only access to the estate on which I live

1.20 RR-020 PINS Ref. Relevant Representation from Janet Oakley- Hills Response from Highways England (the Applicant) RR-020 My concerns are as follows: 020.01 That the capacity of the A2070 has been underestimated, that Standard DfT guidance has been followed to derive the 'most likely' traffic there is a failure to consider the additional growth and forecasts, which show that the A2070 has sufficient capacity to 2033. If the developments that will feed onto this road. total Core Strategy development were to be completed by 2033, it is likely that the road would reach capacity by then. 020.02 That there is a failure to address the issue of the M20 London The Scheme proposes the new junction and new slip road onto M20 bound access from A2070 at existing J10. London bound, the main traffic will be directed through the new junction so existing M20 J10 and slip roads should have less traffic and should in future accommodate only local traffic.

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020.03 The addition of traffic lights in such close proximity on A2070 The Scheme is not proposing any additional traffic lights. The traffic signals will cause even more tail-backs around J10. were considered in the early scheme options investigations but they are now replaced with roundabouts. 020.04 That there is total failure to assess the needs of residents of Outside the Scheme extent. It is proposed to introduce 40 mph speed limit Church Rd/Cheeseman's Green lane trying to access A2070. for part of the A2070 from Church Road junction to both M20 J10 and M20 J10a. This should ease access to A2070 from Church Road. 020.05 That there is total failure to assess the needs of residents and Highways England understand concern regarding the Barrey Road exit onto customers of Barry Rd and Retail Park trying to access the the A2070, we notice that a number of residents have raised similar A2070. concerns in the relevant representations. The last traffic assessment of the Barrey Road Junction was done prior to 2013 when permission to occupy the empty units in the Ashford Retail Park was given, and at that time it was indicated that there would be a negligible impact on traffic overall. Therefore before the Scheme starts we have already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

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Masterplan proposals (DCO Document 6.2, Figure 2.6f) including the use of thin surface course (low noise) surfacing and noise bunds/barriers (DCO Document 6.2, Chapter 11, Paragraph 11.7.2)

1.21 RR-021 PINS Ref. Relevant Representation from Jennifer Mills Response from Highways England (the Applicant) RR-021 021.01 A20 between J10A and Junction 10 Use of this piece of road will Traffic on this section of the A20 is expected to decrease in the future as a increase. Drivers coming from Ashford and Kennington wanting result of the Scheme. This is because eastbound and westbound traffic that to use the J10A eastbound slip road onto the M20 to go towards currently accesses the A20 at Junction 10 to/from the M20 will now be able Folkestone/Dover and some of those drivers exiting the M20 on to do so more efficiently at Junction 10A, effectively by-passing the section the J10A westbound slip road to go into Ashford or Kennington of the A20 in question. This more than offsets any local increase arising will use this section of the A20 to avoid going via the link road, from the point made. another roundabout and the A2070. This short stretch of road also has to cope with drivers going to and from Tesco via a small but busy roundabout. This will generate tailbacks at peak shopping times and add to the risk of gridlock. 021.02 Highfield Lane and Kingsford Street, Mersham. In AXA/DMI's Highways England considers this request to be outside of the schemes application 14/00906 it is proposed that Highfield Lane be kept scope. There is no justification from traffic modelling to justify this more-or-less on its current alignment and not widened, and that incorporation in the scheme. Highways England have been informed by access from Highfield Lane to Kingsford Street will be retained. Stour Park developers that this work has been included in their section 106 The draft design for Junction 10A shows that Highfield Lane will agreement with ABC. Highways England will work closely with Stour Park not be connected to the A20 when Junction 10A is built so that Developers to ensure that this will be incorporated. any traffic using Highfield Lane to go to or from the A2070 and the A20, or will have to pass along Kingsford Street and The Highways England have also been informed by Kent County Council that Street in Mersham. they will forward fund this work and will implement before the opening of the Although this route is less direct, drivers frustrated with the Scheme. They will work with Stour Park Developers to form an agreement. inevitable peak-hour congestion or gridlock on the J10/J10A/link road 'triangle' due to an accident, or simply wishing to avoid the roundabouts and traffic lights, will be tempted to rat-run to and from the A2070 and A20 via Church Road through the U19 site, Highfield Lane, Kingsford Street and The Street in Mersham as they do already. As there will be a link between Highfield Lane and the AXA/DMI site, drivers going to and from the businesses there may also be tempted to use this route as a 'back way' in and out of the development. HA514442-MMGJV-GEN-SMW-RE-Z-10701 64 Revision A

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Many Mersham residents want Highfield Lane to be closed at its junction with Kingsford Street to prevent dangerous rat-running. A petition to this effect was presented to KCC in June 2014. Highways England should co-operate with Kent Highways to ensure that this closure is incorporated in the plans for Junction 10A or carried out by the developer of U19, or Kent Highways before the Highfield Lane/A20 junction is closed off. Highfield Lane is very narrow in places, and in the past there have been jams caused by large vehicles trying to avoid Junction 10 approaching from opposite directions unable to pass each other. Kingsford Street is a narrow, winding lane, with blind bends and no pavements. However, there are many residential properties along it and pedestrians use it to walk to the village shop and school and to the playing field off Kingsford Street. If, as currently planned, a pedestrian/cycle bridge is built from Kingsford Street to the A20 as part of the Junction 10A scheme, this will also attract more pedestrian and cycle use from those who live in the western half of Kingsford Street wishing to reach the A20. Any intensification of traffic along this lane will be extremely dangerous to pedestrians and cyclists and there is the danger of vehicle collisions at the narrowest places in the road, especially at a blind bend near Ransley House. 021.03 Safety and access at Barrey Road junction. The Barrey Road Highways England understand concern regarding the Barrey Road exit onto exit onto the A2070 is obstructed when traffic queues back from the A2070, we notice that a number of residents have raised similar Junction 10. This is likely also to happen with the new link concerns in the relevant representations. road/A2070 roundabout, which is even more likely to get snarled up by a tail-back as it is closer to J10. This will affect residents The last traffic assessment of the Barrey Road Junction was done prior to of Church Road whose only vehicular access to Ashford and 2013 when permission to occupy the empty units in the Ashford Retail Park elsewhere is via Barrey Road and the A2070, as the other end was given, and at that time it was indicated that there would be a negligible of Church Road is a cul-de-sac, and also the staff and impact on traffic overall. Therefore before the Scheme starts we have customers of the many firms of the Ashford Business Park. Also already put in place enhancements to the A2070 and Barrey Road by very important to note is that when this road is blocked by a tail- improving signage and visibility at the junction, and we will be reducing the back, access for emergency vehicles is also affected. speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

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1.22 RR-022 PINS Ref. Relevant Representation from John Eastwood Response from Highways England (the Applicant) RR-022 022.01 The closure of Kingsford at the bottom end means the bus Highways England considers this request to be outside of the Scheme’s service which currently runs Through cannot continue scope. There is no justification from traffic modelling to justify this incorporation in the Scheme. Highways England have been informed by Stour Park developers that this work has been included in their section 106 agreement with ABC. Highways England will work closely with Stour Park Developers to ensure that this will be incorporated.

Highways England have also been informed by Kent County Council that they will forward fund this work and will implement before the opening of Scheme. They will work with Stour Park Developers to form an agreement. The bus route will have to be diverted. 022.02 Residents will no longer have access to it. As above. 022.03 Kingsford Street traffic will have to exit into The Street Mersham As above. which is a busy very narrow road. 022.04 The road junction where the Street Mersham meets the A20 As above. (Hythe Road) will be even more congested with the extra traffic which is difficult to enter at present. Will traffic lights be installed.

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1.23 RR-023 PINS Ref. Relevant Representation from Jonathan Mayes Response from Highways England (the Applicant) RR-023 023.01 Hi, even though I don't agree with the whole scheme, I would Highways England considers this request to be outside of the Scheme’s like to express the need for Kingsford Street to be closed at the scope. There is no justification from traffic modelling to justify this end with Highfield lane to prevent a rat run through Mersham. incorporation in the Scheme. Highways England have been informed by The road is not big enough to cope with it, as well as a danger Stour Park developers that this work has been included in their section 106 to the current cyclists, horses and children that use the road. agreement with ABC. Highways England will work closely with Stour Park There was a serious incident this week with a turned over car Developers to ensure that this will be incorporated. which was going too fast Highways England have also been informed by Kent County Council that they will forward fund this work and will implement before the opening of the Scheme. They will work with Stour Park Developers to form an agreement.

1.24 RR-024 PINS Ref. Relevant Representation from Julia Miller Response from Highways England (the Applicant) RR-024 024.01 As a homeowner who is going to be directly affected by the Survey of the property foundation can be carried out prior to construction proposed plans. works to ensure that the vibration from the proposed works will not affect the property. The whole scheme will result in me living right next door to a busy motorway with a slip road right outside my front door. For the compulsory purchase and compensation documents please see There will be a lot of disruption during the build with potential Highways England compensation documents. damage to the foundations and structure of my house. The scheme will ultimately reduce the value of my property.

024.02 There will be increased light, noise and air pollution with the Response based on assumption that the homeowner is located on dust and dirt during the construction which will continue once Kingsford Street. the works are complete with the volume of traffic that is expected to use the motorway and slip road. I will be faced with Light, noise and air pollution (dust) during construction will be mitigated looking out onto a solid sound barrier. The design of the through the implementation of the Construction Environment Management footpath and barriers alongside the solid sound barrier will Plan (DCO Document 6.3, Appendix 17.1) destroy the whole rural character of this section of Kingsford Street; this will not enhance the environment. The lighting impacts of the Main and Alternative Schemes are assessed in DCO Document 6.1, Chapter 7 and DCO Document 6.1, Chapter 8. The This section of Kingsford Street should not be lit overhead as lighting scheme includes the introduction of LED lanterns (96 LED) mounted HA514442-MMGJV-GEN-SMW-RE-Z-10701 67 Revision A

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the environmental analysis shows this road is a recognised flight on 8m columns along the new slip road and low directional LED bollards on path for Bats to local roosts and should be maintained in its Kingsford Street. present form. Destroying the roadside, wooded copse and replacing it with a wooden wall will not improve the environment. The impact of the lighting on bats was assessed in DCO Document 6.1, Chapter 8; Nature Conservation. This assessment concluded that the additional lighting and the operation of the A2070 link road would have a Minor Adverse impact at Local level, but this would be offset by the creation of additional habitat (3 balancing ponds; 14.19ha of grassland; and 4.89ha of tree, scrub and woodland habitats) and the provision of bat boxes, which would result in an overall Slight Beneficial residual effect is predicted in the long term once the habitats have become established.

The visual impact of the lighting was assessed in DCO Document 6.1, Chapter 7; Landscape. This assessment concluded that while the lighting would be at odds with the existing immediate landscape, the lighting design would limit light spill and would be set in the context of lighting found within the wider landscape and the visual containment provided by local topographical variations.

The proposed acoustic barrier along Kingsford Street will be set behind a new native hedge with intermittent specimen tree planting, which will provide a more naturalistic green screen to the timber acoustic barrier once planting matures.

024.03 Currently Kingsford Street is a country lane and this will either Highways England considers this request to be outside the Scheme's change whereby it will become a rat run for Ashford traffic scope. There is no justification from traffic modelling to justify this avoiding the roundabout or it will be closed at the Kingsford incorporation in the Scheme. Highways England have been informed by Street/Highfield Lane junction and would mean that I would Stour Park developers that this work has been included in their section 106 have to travel an extra 2 miles plus each way in order to get into agreement with ABC. Highways England will work closely with Stour Park Ashford. Developers to ensure that this will be incorporated.

Highways England have also been informed by Kent County Council that they will forward fund this work and will implement before the opening of M20 J10a Scheme. They will work with Stour Park Developers to form an agreement.

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024.04 The road plan currently proposed will result in a significant While any local traffic to and from Mersham that currently uses Kingsford increase in the volume of traffic using Kingsford Street. Street to access for example the A2070 south is likely to continue to do so Kingsford Street is very narrow, has poor horizontal alignment, post-scheme, any local diversion between the A20 (east) and A2070 (south) poor junction visibility and does not have a proper drainage is unlikely as the new Junction 10A provides a considerably quicker route. system. Deep flooding regularly occurs at three locations along the road.

1.25 RR-025 PINS Ref. Relevant Representation from Julia Spooner Response from Highways England (the Applicant) RR-025 025.01 Request to extend the low noise surface being used at junction The area between Junction 9 and 10 is outside the Scheme area. 10a to the surface between junction 10 and 9. Highways England will specify thin surface course surfacing which will mitigate noise from the Main and Alternative Schemes (refer to DCO Document 6.1, Chapter 11, Paragraph 11.7.2) on all scheme roads except A20 which will be still managed by KCC. 025.02 Improvement to the junction of Barrey Road and the A2070 Highways England understand concern regarding the Barrey Road exit onto the A2070, we notice that a number of residents have raised similar concerns in the relevant representations.

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and local businesses further discussions between Highways England Area 4 Spatial Planning and Kent County Council were planned, and they are currently on-going, to resolve any existing traffic issue ahead of the Scheme, which is supporting the discussion by providing the relevant data and additional traffic surveys.

1.26 RR-026 PINS Ref. Relevant Representation from Kent County Council Response from Highways England (the Applicant) RR-026 026.01 Following the Planning Inspectorate’s notification of decision to Noted. accept an application for examination for an order granting development consent (dated 11 August 2016), Kent County Council (KCC) requests that this letter be considered as a Relevant Representation and to be registered as an Interested Party for this application.

KCC fully supports the proposal for the construction of the M20 J10a. In the Ashford Borough Council - Kent County District Delivery Deal (2015), the new junction is listed as one of the ‘Big 8’ strategic projects that have been identified as having the greatest collective ability to unlock thousands of jobs and homes in the Ashford Borough.

KCC has set out its full commitment to work closely with Ashford Borough Council (ABC) in delivering the ‘Big 8’ strategic projects and in supporting the delivery of the Borough Council’s growth agenda, which is set out in the emerging Local Plan 2030.

The submission of this application for a Development Consent Order by Highways England (HE) is welcomed, particularly as there is compelling need in principle for a new Junction 10a and link road to provide further capacity to facilitate residential and employment development in the Ashford growth area, as identified in Ashford’s existing development plan documents.

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KCC will continue the constructive dialogue with ABC and Highways England throughout the process to address outstanding matters. KCC has noted the letter sent from the Planning Inspectorate to HE on 21 September 2016, which identifies areas in which additional information is required during the pre-examination stage, including updated Works Plans and Book of Reference. In addition, KCC, in collaboration with ABC, has commissioned an Independent Review of the Environmental Statement (ES) (APP-029- APP-208 in the Examination Library, covering air quality, noise and vibration, effects on all travellers and landscape and visual impacts), with the objective to ensure that the ES is compliant with the EC Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment. This may result in a recommendation for further areas of work, and KCC will welcome the opportunity to comment on matters of detail at future stages of the NSIP process.

This letter sets out a summary of the main aspects of the application with which KCC agrees and/or disagrees, together with an appropriate explanation, in accordance with the Planning Inspectorate’s Advice Note 8.3. In summary, an outline of the principal submissions that KCC intends to make in relation to the application will concern:

- All matters concerning KCC as Local Highway Authority; - Asset management/ maintenance; - Public Rights of Way impacts; - Cultural heritage impacts; - Biodiversity impacts; - All surface water management aspects of the scheme covered by KCC as the Lead Local Flood Authority; and - Minerals and waste.

Local Highway Authority

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The Local Highway Authority has made comments in respect of the status of the A20 Hythe Road in the context of M20 J10A. 026.02 The A20 Hythe Road currently forms part of the local road Highways England will not trunk the A20 Hythe Road between M20 J10 and network. However, the closure of the east-facing slips as part of M20 J10a for the following reasons: the proposal for M20 J10A would result in a greater volume of 1. Traffic modelling (PP.56-57 on the published TAR) clearly shows a coast-bound traffic using the A20 Hythe Road. Accordingly, it is significant reduction of traffic flows on this section with the new J10a necessary for the Local Highway Authority to raise this as a (remarkable for northbound/westbound vehicles). This confirms that the matter requiring further discussion with HE. The Local Highway traffic using this section would be mainly local traffic with local destinations Authority considers that a suitable way forward would be for HE (i.e. Tesco, William Harvey Hospital, Ashford centre to/from south-eastern to take on maintenance responsibility for the section of A20 area of A20). Therefore this would not fully align to the objectives of Hythe Road between the extent of HE’s asset at M20 J10 and Highways England Strategic Road Network; the proposed connection of M20 J10A with the A20 Hythe Road. 2. There will be a cost to Highways England to upgrade the assets to the It makes operational and strategic sense that this short section appropriate standards; of road is picked up by HE, as it directly links the two junctions. 3. This will mean changes to Service Provider contracts as it is an increase in responsibility. This request will not have implications on the cost of constructing the M20 J10A scheme, as maintenance is an ongoing requirement post-scheme implementation. It is commonplace for such discussions to take place in respect of long-term asset status, and the Local Highway Authority is mindful that the matter should be resolved as soon as practicable.

It is understood that the Project Sponsor is checking this proposal with their legal team as this area sits outside of the “red line” for the scheme, but that should not discount the requirement, especially as HE was made aware of the request some 18 months ago. 026.03 The draft DCO at section 12(4) (APP-018) also suggests that Highways England will be responsible for the maintenance of both new the Local Highway Authority may be liable for the maintenance structures: Church Road Footbridge and Kingsford Street Footbridge. of the surface over the two new footbridges. KCC requests confirmation that HE will be responsible for the structures in Highways England will not take on the maintenance responsibility for the their entirety. maintenance of the Swatfield Bridge and Highways England will not trunk the A20, see 026.02 above. In addition, KCC proposes that HE should be the operators and maintainers of the adjacent sections of the A20, including the The existing A2070 road is a Trunk Road and should be in Highways

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Swatfield Bridge, that it will strengthen as part of this proposal. England ownership. Highways England and Kent County Council are in the The increase in traffic here will be very significant and is process of transferring the ownership of the existing A2070 to Highways appropriate that HE takes responsibility for such infrastructure. England. This will be reflected in an updated Book of Reference once completed. It is understood that the new A2070 link from 10a down towards Church Road will be part of the strategic trunk road network and therefore, for HE to manage. 026.04 KCC is aware that there have been a large number of Highways England considers this request to be outside of the Scheme’s complaints about potential HGV movements along Highfield scope. There is no justification from traffic modelling to justify this Lane. It has been stated before that this lane should be closed incorporation in the Scheme. Highways England have been informed by and a turning area provided, but HE has not acknowledged this Stour Park developers that this work has been included in their section 106 as being part of their responsibility. KCC’s view is that this is not agreement with ABC. Highways England will work closely with Stour Park a local road network issue, and rather that residents/parish Developers to ensure that this will be incorporated. concerns should be addressed by HE and that HE should provide both the closure and turning area as part of the scheme. Highways England have also been informed by Kent County Council that they will forward fund this work and will implement before the opening of the Scheme. They will work with Stour Park Developers to form an agreement. 026.05 In respect of street lighting, clear ownership will need to be Lighting on the strategic road network which belongs to Highways England identified. Issues around ownership, access and shared will be Highways England maintenance responsibility. Those on A20 will networks need to be established with HE in order to prevent remain with KCC responsibility as Highways England will not be trunking future maintenance problems. KCC would seek confirmation the A20. from HE that lighting will be under the ownership of HE so that there will be no impact on KCC street lighting and maintenance issues. 026.06 The DCO draft (APP-018) at Part 2, Section 8, gives a 1m limit Yes, they have been covered in the Environmental Statement. of deviation, the consequences of which will need to be considered and clarification is sought as to whether these limits have been covered in the Environmental Statement. 026.07 The General Arrangement Plans still refer to the Kingsford Kingsford Street Footbridge has been designed to provide future equestrian Street Bridge (APP-010, sheet 2 of 4) as a footbridge (without provision as and when it will be needed by KCC. Currently discussing with an equestrian access), so KCC would like to see evidence of KCC. how this has been arrived at through the design stage process. The proposed drawings for Public Rights of Way (PRoW) extinguishments are as expected and requested. 026.08 The only other concern is in relation to the retained PRoW PRoW number AE338 and AE337A (located on the south side of the new connections to the south side of the new A2070 access road, A2070 Link Road) are located on the land owned and managed by the HA514442-MMGJV-GEN-SMW-RE-Z-10701 73 Revision A

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shown on the Rights of Way and Access Plans 03 and 04 (APP- Friends Life, looking into their planning application 14/00906/AS new 008). There appear to be level changes and drainage channels building (Plot 6) is proposed in this location. The stopping up or re-directing that would prevent access to the new footway/cycleway. Access of those two footways should be managed by Friends Life. points and suitable ramps and access will be required to connect the retained Footpaths AE337A and AE338. 026.09 Cultural Heritage 026.09a In summary, the assessment of Cultural Heritage issues is A Cultural Heritage Assessment has been undertaken (DCO Document 6.1, reasonable. In addition to the points raised below, further Chapter 6; Cultural Heritage) in accordance with: detailed comments are provided in Appendix A. • Design Manual for Roads and Bridges, Environmental Assessment There is potential for the scheme to impact on prehistoric, (Volume 11, Section 3, Part 2 – Cultural Heritage) . Roman, Early Medieval and Medieval remains which may be • Historic England (2008) Conservation Principles, Policies and Guidance . considered of greater importance than “low local value” only. • Historic Environment Good Practice Advice in Planning note 2 (GPA2) – The evaluation work so far is too limited to suggest there are no Managing significance in decision taking in the historic environment). significant remains within the scheme area. • Historic Environment Good Practice Advice in Planning note 3 (GPA3) – The setting of heritage assets. • Chartered Institute for Archaeologists Standard and Guidance for historic environment assessment . 026.09b The designated milestone (HA no: 1276471) (Table 6.5, p 16 A second visit was undertaken on the 7th July 2015. This visit was partly and p18, APP-034) should not be excluded from mitigation undertaken to carry out a thorough search of the roadside along the A20 in solely on the basis only of a site visit made in 13 October 2014 the area of the missing milestone. The roadside was not significantly (para. 6.7.15, APP-034). overgrown and areas under trees and shrubs were visible. There was no evidence of the presence of the milestone. In addition it was noted during the assessment of the earlier M20 J10a scheme that the milestone was absent. No record of where the milestone has gone has been found. Historic England have been notified of the findings, as reflected in the Statement of Common Ground (DCO Document 8.4). 026.09c Archaeological mitigation needs to be integrated into all aspects Discussions are ongoing between Highways England and the County of the scheme, including the initial enabling works, ecological Archaeologist to agree the mitigation measures required for the construction and drainage works. of the Scheme. Agreements on all mitigation will be detailed in the Statement of Common Ground (DCO Document 8.4). 026.09d Assessment of St Mary’s Church should reflect the complexity Discussions are ongoing between Highways England and Historic England of its significance and be more detailed. Historic England has to agree the mitigation measures required for St Mary’s Church. noted that there is likely to be considerable harm from the Agreements on all mitigation will be detailed in the Statement of Common proposed Stour Park scheme but that suitable mitigation Ground (DCO Document 8.4). measures for both schemes could reduce the level of harm HA514442-MMGJV-GEN-SMW-RE-Z-10701 74 Revision A

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(APP-199 and APP-043, page 13, 14/00906/AS). Mitigation for St Mary’s Church needs to be agreed with Historic England. 026.09e HE needs to put forward a meaningful construction programme Discussions are ongoing between Highways England and Historic England with mechanisms in place to ensure archaeological mitigation is to agree the mitigation measures. Agreements on all mitigation will be suitably dealt with, including County Archaeologist sign off of detailed in the Statement of Common Ground (DCO Document 8.4). detailed mitigation and agreement of post-excavation works. 026.10 Biodiversity 026.10a KCC is satisfied that HE’s ecologists have a sound Advanced habitat enhancement and creation has been considered in the understanding of what species and habitats are present and Ghost licenses and approved by Natural England. A Letter Of No what mitigation is required. Impediment has now been issued by Natural England. These letters can be found in the Statement of Common Ground (DCO Document 8.5), Appendix However, there is a need to ensure that the time to B. create/enhance the habitat for the required mitigation is factored in to the development timetable. This will ensure that development works are not delayed waiting for habitat to establish before the mitigation is implemented, nor that substandard mitigation is carried out at the risk of the mitigation being unsuccessful (e.g. species dying as there is not sufficient food to support them). 026.10b Habitat enhancements should be carried out as soon as Advanced habitat enhancement and creation has been considered in the possible to give them sufficient time to establish. For instance, it Ghost licenses and approved by Natural England. A Letter Of No is noted that the dormouse mitigation is proposing to create a Impediment has now been issued by Natural England. These letters can be dormouse feeding station; this can only be a short-term found in the Statement of Common Ground (DCO Document 8.5), Appendix mitigation measure, and long-term habitats must be created that B. provide suitable foraging habitat for dormouse. Measures must be in place to ensure the feeding station is stocked up for as long as required. 026.10c To address this and wider concerns about the timetable for such Advanced habitat enhancement and creation has been considered in the works, it is suggested that a timetable is produced, clearly Ghost licenses and approved by Natural England. A Letter Of No setting out the programme for the proposed habitat Impediment has now been issued by NE. These letters can be found in the enhancements/creation and species/habitat mitigation. This will Statement of Common Ground (DCO Document 8.5), Appendix B. ensure the development timetable can be designed accordingly. 026.10d In respect of long-term management, there is a need to ensure Advanced habitat enhancement and creation has been considered in the that the created/enhanced management is managed long-term Ghost licenses and approved by Natural England. A Letter Of No to ensure that the mitigation will be successful. This means Impediment has now been issued by NE. These letters can be found in the either changing long-term management plans for HE land or Statement of Common Ground (DCO Document 8.5), Appendix B. HA514442-MMGJV-GEN-SMW-RE-Z-10701 75 Revision A

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ensuring landowners (where enhancements will be carried out) can, and are willing to, manage the habitat appropriately. For example, the receptor site for reptiles is proposed to be located on the London Bound M20 Highways verge which is currently unsuitable for reptiles (as it is regularly cut), so there is a need to ensure that the maintenance team understands that the management of this area has changed. 026.10e It is also worth noting that there are other developments being Noted. delivered or proposed within this area. The ecologists for the M20 J10A application should ensure they are aware of any developments within the surrounding area to confirm the mitigation proposed remains suitable; there may be a need to tweak / change the mitigation due to other works being carried out within the immediate area. 026.11 Lead Local Flood Authority 026.11a KCC has reviewed the flood risk assessments and drainage Noted strategy information and is generally satisfied with the proposals for the management of surface water generated by the scheme.

KCC is supportive of the proposed new junction and the positive contribution that it will make towards the growth agenda of the Borough Council. KCC looks forward to working with ABC and HE as the project process progresses and will welcome the opportunity to comment on matters of detail in the Examination. 026.12 Appendix A 026.12a 6.7.8 – milestone (MM43) – a Listed Grade II milestone not A Cultural Heritage Assessment has been undertaken (DCO Document 6.1, identified on site. May be buried and needs to be looked for Chapter 6; Cultural Heritage). This visit was partly undertaken to carry out a more robustly. It was observed and listed in 1989 so there thorough search of the roadside along the A20 in the area of the missing needs to be assessment as to what might have happened to it. milestone. The roadside was not significantly overgrown and areas under 6.7.17 suggests that as the milestone was not observed during trees and shrubs were visible. There was no evidence of the presence of a site walkover it must have been removed or misallocated. the milestone. In addition it was noted during the assessment of the earlier However, October would still be a time of high vegetation cover M20 J10a scheme that the milestone was absent. No record of where the and a small object could easily be buried. It should not be milestone has gone has been found. Historic England have been notified of assumed that it is no longer present. Suggestion that it is the findings, as reflected in the Statement of Common Ground (DCO premature to state in Table 6.8 and paragraph 6.11.3 that this Document 8.4). asset is missing and therefore does not require any mitigation. HA514442-MMGJV-GEN-SMW-RE-Z-10701 76 Revision A

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Recommendation that this designated asset is still subject to mitigation until it is definitively clarified whether it survives on site or not. 026.12b 6.7.12 – need to check the visible impact on Lacton Green A Cultural Heritage Assessment has been undertaken (DCO Document 6.1, Conservation Area, 150m north of scheme boundary. Robust Chapter 6; Cultural Heritage). As part of both heritage walkovers the Lacton consideration is needed in view of scale and height of new Green Conservation Area was visited. It was clear from the walkovers that roundabout and possible increased traffic flows. the conservation area was inward facing, with the key views being contained along 'The Street'. Filtering from the existing tree lines (to the rear of the properties) visually separates the asset from the A20 and the existing M20 junction and would also (along with the natural topography) filter the visibility of the new junction. 026.12c 6.7.13 – Hatton Park should be Hatch Park. Agreed. 026.12d 6.7.13 – a designated heritage asset is generally considered to The methodology of the Cultural Heritage Assessment in DCO Document be of national importance. Disagrees with the Cultural Heritage 6.1, Chapter 6; Cultural Heritage is in accordance with Design Manual for assessment which suggests that some designated heritage Roads and Bridges, Environmental Assessment (Volume 11, Section 3, assets, such as Hatch Park parkland, can be of “High regional Part 2 – Cultural Heritage). value”. 026.12e 6.7.30 should highlight that the scheme area has only been Agreed. A pre-construction intrusive evaluation and a watching brief during partially evaluated. Many of the trenches were not excavated, construction have been agreed will be provided between Highways England partly due to ecological constraints. As such, there are areas and Historic England. These agreements have been documents in the north of St Mary’s Church, which will be impacted by both the Statement of Common Ground (DCO Document 8.4). scheme and by the proposed site compound, which have not been reasonably evaluated. Further archaeological evaluation of this area ahead of initial scheme works is essential. 026.12f 6.8.6 – the prehistoric background data is fine but there have Noted. been some more recent findings from Ashford Orbital Park including 3 Iron Age funerary enclosures (Oxford Archaeology East 2015). 026.12g 6.8.13 and 6.8.14 – there is no mention of a Lime kiln and its The site of the lime kiln is located outside of study area described in the associated quarry which are identifiable on the 1st Ed OS map Environmental Statement (DCO Document 6.1, Chapter 6; Cultural immediately north of the new motorway roundabout. It is not Heritage), which uses a (20m north of the redline boundary). In addition, the clear whether this post medieval structure is within the scheme area of the lime kiln was subject to quarrying activities in the mid 20th or not but recommendation that some assessment of this century and has subsequently been used as a landfill site. feature is required to ensure suitable assessment and mitigation if necessary.

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026.12h 6.8.19 – assessment of importance level of Palaeolithic remains The methodology of the Cultural Heritage Assessment in the Environmental is debateable. Palaeolithic remains are so rare that they are Statement (DCO Document 6.1, Chapter 6; Cultural Heritage) is in generally considered to be of importance, subject to their accordance with Design Manual for Roads and Bridges, Environmental context. It should also be noted that river valleys, including the Assessment (Volume 11, Section 3, Part 2 – Cultural Heritage). For an Aylesford Stream one, were favourable areas for prehistoric asset to be of moderate value then it has to be of equivalence of a activity. This valley could also have high potential for palaeo- Conservation Area/Grade II Listed building. The evidence at this stage environmental evidence which could provide valuable (which may change following further evaluation) does not support a higher information on the development of the stream in relation to the value. River Stour and the local environment during the Prehistoric and later periods. Palaeo-environmental evaluation and assessment would need to be fully integrated into the formal programme of archaeological works. 026.12i 6.8.20 – Disagree with the assessment that the scheme is likely The methodology of the Cultural Heritage Assessment in the Environmental to only contain prehistoric or Roman features of “Low local Statement (DCO Document 6.1, Chapter 6; Cultural Heritage) is in value”. The archaeological fieldwork so far has been minimal accordance with Design Manual for Roads and Bridges, Environmental and there was evidence of prehistoric activity. There is potential Assessment (Volume 11, Section 3, Part 2 – Cultural Heritage). The for this scheme to have an impact on archaeology of greater evidence to date from the Stour Park site and M20 J10a trenches and significance than “low local value”. geophysics point to only a discrete pattern of archaeological remains (largely associated with agricultural activity) around the Main and Alternative Schemes area, with significant settlement located to the south Court Lodge (rather than north of the Church). For an asset to be of moderate value then it has to be of equivalence of a Conservation Area/ Grade II Listed building. The evidence at this stage (which may change following further evaluation) does not support a higher value. 026.12j 6.8.21 – Disagree with the assessment that the scheme is likely The methodology of the Cultural Heritage Assessment in the Environmental to contain early medieval or medieval remains of “low local Statement (DCO Document 6.1, Chapter 6; Cultural Heritage) is in value”. Early medieval remains are not common and in view of accordance with Design Manual for Roads and Bridges, Environmental the proximity of St Marys Church Sevington and Court Lodge, Assessment (Volume 11, Section 3, Part 2 – Cultural Heritage). The suggestion that there is reasonable potential for remains which evidence for early med/medieval (largely associated with agricultural may be of greater significance than “low local value”. activity) is limited. The evidence from the geophysical survey and trial trenches (although limited) to the north of the church do not support the presence of significant settlement in the area of the proposed Scheme. The settlement pattern in the wider area for this period indicates a historic core of a farm (Court Lodge) and a church. With further settlement taking place at a remove from the church. As seen at Willesborough, Mersham and Aldington. For an asset to be of moderate value then it has to be of

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equivalence of a Conservation Area/ Grade II Listed building. The evidence at this stage (which may change following further evaluation) does not support a higher value. 026.12k 6.8.19 The Archaeological Potential and Value Assessment Further documents have been produced and can be found in the Statement does not provide reasonable statement of significance for St of Common Ground (DCO Document 8.4): Mary’s Church Sevington. St Mary’s Church is a significant and - A Statement of Significance for St Mary's Sevington and Court Lodge complex archaeological and historic site and there is potential Farm and Barn. This provides additional baseline information on the for the scheme to impact on remains directly associated with evidential, contextual, historical, architectural and communal significance of this asset as well as on its setting and character. As such, there the assets. needs to be a robust assessment of this designated heritage - An additional assessment of the potential of the effects of the operation of asset dealing with all areas of significance and value. Mitigation the scheme on St Mary's Church. This found the effect to be negligible. needs to be clearly informed and evidence-based. - A photomontage from the churchyard of the Scheme after year 1 and year 15. - A cross section (north west to south east) across the link road roundabout, noise barrier and proposed landscape planting. The drawing also includes the retained tree/hedge line between the church and the link road. - Information on the current usage of the church and use of the surrounding PROWs; this indicates a low level of usage.

This document documents the further discussion between Highways England and Historic England. 026.12l 6.8.19 and vol 6.3 App 15.1 - The comments from Historic As per 026.12K above. England submitted with the application details are noted, although it is focused on the proposed industrial development off Highfield Lane. HE’s comments repeat the concerns over the level of harm to St Mary’s Church and consider it is “substantial” but that mitigation could effectively reduce the level of harm. In view of this, there is a need for this Highways England scheme to also ensure that mitigation measures for St Mary’s church are robust and agreed with Historic England. 026.12m 6.9 Mitigation and Compensation Measures need to be more A written scheme of investigation for the intrusive archaeological evaluation robust. Mitigation for heritage needs to be scheduled well in of the scheme area is being produced and will be issued to the Kent County advance of construction work and integrated into every aspect Council (KCC) Historic Environment Service for discussion/approval. The of the scheme, including site compound set up, landscaping, archaeological evaluation works will be completed in advance of drainage schemes etc. If there are intentions to undertake construction works. The strategy for archaeological mitigation will be agreed geotechnical work, especially along the Aylesford Stream area, with the Kent County Council Historic Environment Service on completion of

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it would be advantageous to include archaeological palaeo- the archaeological evaluation (and well in advance of construction). The environmental work. strategy for archaeological mitigation will follow the requirements detailed in Schedule 2 of the dDCO (DCO Document 3.1). 026.12n Fig. 6.2 (volume 6.2) Non Designated Assets drawing does not The geophysical survey did not highlight any specific areas of significant indicate the presence of known archaeological remains within archaeological potential within the Schemes footprint. The result show a the scheme area or within the study area, as suggested by the significant amount of disturbance across most of the survey area, with a Archaeological Evaluation of Land West of Highfield Lane and sparse spread of anomalies which may have archaeological potential. A by the Geophysical Survey. small number of evaluation trenches have been excavated within the Schemes footprint but this did not identify any significant remains and did not cover the whole of the scheme area. An archaeological evaluation strategy is being developed (to be agreed with the Kent County Council Historic Environment Service). This will be used to highlight the areas of archaeological potential (including an archaeological potential plan) and inform the archaeological mitigation strategy. 026.12o Cannot not find any appendices for heritage assessment These were produced as part of another scheme but have been used to including copies of the evaluation report and the geophysical inform the baseline for the in the Cultural Heritage Assessment of the survey report. These reports need to be consulted as part of this Environmental Statement (DCO Document 6.1, Chapter 6; Cultural scheme and should be available. Heritage). The documents will be included in the KCC Statement of Common Ground (DCO Document 8.2) as Appendix A. 026.12p There seemed to be only two figures showing heritage assets An archaeological potential impacts map would be useful but due to the and areas. This is a bit limited and it would be helpful to have limited nature of the evidence, this is not possible at this time. As stated in more detailed Cultural Heritage figures, especially ones showing 026.12n the evidence for archaeological remains in the footprint of the areas of impact on known heritage assets. Scheme is currently limited. However an archaeological potential impacts map will be produced as part of the report for the proposed archaeological evaluation.

1.27 RR-027 PINS Ref. Relevant Representation from Kent Downs Area of Response from Highways England (the Applicant) RR-027 Outstanding Natural Beauty(AONB) Unit 027.01 While the site of the proposed interchange is some distance Effects on the AONB have been considered and are detailed in the from the boundary of the Kent Downs Area of Outstanding Landscape and Visual Impact Assessment (DCO Document 6.1; Natural Beauty (AONB), the nature of the AONB, which is based Environmental Statement, Chapter 7). This assessment covers not only the on the North Downs scarp, means that it is likely that views of site itself, but also a wider area of approximately 1km to provide an insight the proposed works will be visible from the AONB. into the effects of the Main and Alternative Schemes on the surrounding landscape. Kent Downs AONB, whilst outside of the study area, has been HA514442-MMGJV-GEN-SMW-RE-Z-10701 80 Revision A

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Areas of Outstanding Natural Beauty are a nationally important addressed within the visual assessment (refer to Visual Impact Schedules, and protected landscape that have the same status in planning DCO Document 6.3, Appendix 7.4, Volume 6.3) in relation to a key terms as National Parks. Section 85 of the Countryside and viewpoint identified at the Devil’s Kneading Trough. Given the distance from Rights of Way Act 2000 requires all public bodies and relevant site and expansive nature of this long distance view it is considered that the authorities to have regard to the conservation and enhancement Main and Alternative Schemes would be barely perceptible from this of AONBs in carrying out their duties. This duty of regard needs location. to be properly considered throughout the decision making process. It is important to note that the ‘Duty of Regard’ applies Mitigation for landscape and visual impacts has been incorporated into the not just in respect of proposals within AONBs but also to public Environmental Masterplan proposals (DCO Document 6.2, Figure 2.6f). bodies in exercising their functions “so as to affect” land in an Mitigation for noise impacts will be provided through the use of thin surface Area of Outstanding Natural Beauty. course (low noise) surfacing and noise bunds/barriers (DCO Document 6.2, In view of the potential for the scheme to impact on the setting Chapter 11, Paragraph 11.7.2). The landscaping proposals include native of the Kent Downs AONB, it is important that that suitable hedges with intermittent trees, native tree planting and specimen trees mitigation is incorporated. The Kent Downs AONB Unit would along the length of the proposed A2070 Link Road, which would provide like to ensure that the scheme incorporates appropriate visual screening of the Main and Alternative Schemes and associated traffic landscaping. In respect of consideration of the cumulative and a strong vegetative northern boundary to the proposed Stour Park impact of the proposed works, in terms of potential impact on development area. the AONB it is considered that proposed developments at Sevington need to be carefully considered and mitigation The Lighting Design for the Main and Alternative Schemes is shown on planting considered in the context of screening this development Figures 2.5a to 2.5d, Volume 6.2. Lighting columns would range from 5 to too. 10m in height supporting LED lanterns for greater light control mounted at It is noted that new lighting is proposed both on the gyratory zero degree inclination to avoid upward light spillage. The new footbridges and for all new junctions in the scheme. In order to assist in would be lit utilising LED handrail lighting. Kingsford Street would be lit by maintaining dark skies at night, the AONB Unit would also like to bollards along its length to reduce visual intrusion. see careful design and the use of new technologies to minimise light pollution.

1.28 RR-028 PINS Ref. Relevant Representation from Lee Evans Planning on behalf Response from Highways England (the Applicant) RR-028 of Broad Oak Motor Group Limited 028.01 RESPONSE TO CONSULTATION IN RESPECT OF M20 - Thank you for your support of the Scheme. JUNCTION 10A

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support the long awaited scheme to provide the new Junction 10A on the M20. Broad Oak Motor Group Limited wish to establish a further motor dealership on Orbital Park, Ashford - the town’s principal Business Park. Orbital Park was established as a key element in the growth of Ashford and has been developed over the last 20 years. However, a number of plots remain undeveloped due to the stance taken by Ashford Borough Council and the then Highways Agency that no further development at Orbital Park could take place until capacity at M20, Junction 10 was increased.

We submitted a planning application to Ashford Borough Council in 2008 for the motor dealership. The application remained undetermined for many years whilst the issues relating to capacity at Junction 10 were considered. The planning application is only now moving forward following an assessment of the additional capacity created by the Junction 10 interim works. It is clear that this situation has delayed construction and economic growth at Ashford - this is clearly not in accordance with Planning Policy and particularly the NPPF and the Government’s emphasis on economic growth.

We, therefore, fully support the proposal to increase capacity through the construction of the New Junction 10A - the first objective of the scheme.

We welcome the acknowledgement of the importance of this key scheme which is designed to accommodate traffic generated by the future growth of Ashford - a major growth area in the South East.

We do not have any comments on the design of the new M20 junction itself but would stress the importance of proceeding

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through the planning process and construction as quickly as possible, to ensure that Ashford can continue to grow through the delivery of employment development and residential development within the Ashford area.

We do support the proposal to provide direct access to the new Stour Park development site from the new A2070 link-road (the alternative scheme) as this will assist economic growth.

1.29 RR-029 PINS Ref. Relevant Representation from Linda Arthur Response from Highways England (the Applicant) RR-029 029.01 I live in XXX and in the immediate vicinity of the proposed J10a. Highways England considers this request to be outside of the Scheme’s I am also involved with the J10a Community Consultation and scope. There is no justification from traffic modelling to justify this attend the meetings held by Ashford Borough Council and HE. I incorporation in the Scheme. Highways England have been informed by am concerned about: Stour Park developers that this work has been included in their section 106 agreement with ABC. Highways England will work closely with Stour Park - The continued link of Highfield Lane and XXX Street. Because Developers to ensure that this will be incorporated. the design of J10a includes the closure of the connection from Highfield Lane to the A20, the continued link of Highfield Lane Highways England have also been informed by Kent County Council that and XX street will mean this will become a rat run. I am they will forward fund this work and will implement before the opening of the concerned because inevitable delays on the A20 during Scheme. They will work with Stour Park Developers to form an agreement. construction will mean traffic using these lanes to avoid congestion. These are narrow, single track lanes with blind The limited space available along Kingsford Street will necessitate the bends, and no pavements and a children's play area, used by removal of existing vegetation to allow the construction of the new shared pedestrians, children, joggers, cyclists and horse riders. There footway/cycleway and noise barrier. A noise barrier will be provided north of is a potential for a serious accident. HE are ignoring this Kingsford Street, with native tree and scrub planting in front of the noise problem and not addressing it - it will arise as a direct result of barrier, providing screening for the properties along Kingsford Street. The their plans to close the Highfield Lane access to the A20. There Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides full are plans submitted by Friends Life to Ashford Borough Council details of the Scheme’s proposals. 14/00906 to permanently close xx Street from Highfield Lane which will prevent the problem, but the timeline for this is The lighting impacts of the Main and Alternative Schemes are assessed in unknown. HE need to acknowledge they will be responsible for DCO Document 6.1, Chapter 7. The lighting scheme includes the any future congestion on Highfield Lane and Street and include introduction of low directional LED bollards on Kingsford Street and the new the closure as part of their plans for J10a. Kingsford Street Footbridge.

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- I am concerned that the rural hedge at the end of Street will Highways England will specify thin surface course surfacing which will be lost. The footpath could be put behind the hedge which could mitigate noise from the Main and Alternative Schemes (refer to DCO be retained and help protect residents opposite, who otherwise Document 6.1, Chapter 11, Paragraph 11.7.2) on all scheme roads except will be facing enormous sound panels. A20 which will be still manged by KCC.

- only low level lighting should be used to light the path and footbridge.

- low noise level road surface as far as possible to protect Mersham and Willesborough.

- adequate landscaping for slip road.

1.30 RR-030 PINS Ref. Relevant Representation from Michael Cremonesi Response from Highways England (the Applicant) RR-030 030.01 I live in XX Mersham. I am concerned that proposed changes to Highways England considers this request to be outside of the Scheme’s local roads will result in traffic using Mersham village as a 'rat scope. There is no justification from traffic modelling to justify this run' via Kingsford Street, in order to avoid Junction 10. In order incorporation in the Scheme. Highways England have been informed by to protect the village, it is imperative that Kingsford Street is Stour Park developers that this work has been included in their section 106 closed off at the junction with Highfield Lane agreement with ABC. Highways England will work closely with Stour Park Developers to ensure that this will be incorporated.

1.31 RR-031 PINS Ref. Relevant Representation from NATS LTD Response from Highways England (the Applicant) RR-031 031.01 NATS anticipates no impact from this proposal and has no Thank you for response. objections to the development.

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1.32 RR-032 PINS Ref. Relevant Representation from North Willesborough Response from Highways England (the Applicant) RR-032 Community Forum 032.01 North Willesborough Community Forum made many comments during the Highways England consultation phase expressing our concerns and objections. These may be summarised as follows: 032.02 There is no provision for public transport. There are currently bus routes (numbers 125 and 111) between Mersham and Ashford Town Centre running along Kingsford Street, across Highfield Lane Bridge and then on to the A20 and Tesco superstore. There is an alternative route from Mersham which buses could use, across the M20 via The Street, but this is less direct.

In the future if required provision for the bus can be provided along new A2070 Link Road, but at this stage we haven't received any information from the Bus Company or ABC that this is required. 032.03 The A2070/Barrey Road junction should be an all-direction Highways England understand concern regarding the Barrey Road exit onto signalised junction for safety reasons. the A2070, we notice that a number of residents have raised similar concerns in the relevant representations.

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4 Spatial Planning and Kent County Council were planned, and they are currently on-going, to resolve any existing traffic issue ahead of the Scheme, which is supporting the discussion by providing the relevant data and additional traffic surveys. 032.04 The A2070/Church Road junction should be an all-direction Outside the Scheme extent, the issue will need to be raised with ABC and signalised junction for safety reasons. Stour Park Developers. Highways England will introduce 40 mph speed limit for part of the A2070 from Church Road junction to both M20 J10 and M20 J10a. This should ease access to A2070 from Church Road. 032.05 The A2070 “Y” junction should be redesigned to: The 'Y' type junction was considered in the early scheme options 1 Encourage London Bound traffic to use Junction 10a rather investigations but they are now replaced with roundabout. The proposed than Junction 10. roundabout is designed to standards and is no requirement to provide filter 2 Have a filter lane for traffic travelling from J10 to J10a. lane taking to account traffic figures. (low volume of traffic travelling from west to east in this location). 032.06 There should be provision for A20 traffic to by-pass J10a in both Highways England has carried out additional design reviews of this section directions (especially as much of this is local traffic seeking only of the Scheme following the consultation. The reviews showed no overall to use the Tesco store). benefits to include a jet lane bypass on the A20 bypassing junction 10a and are therefore not included in the application 032.07 The “redundant” J10 slip roads should be “recycled” to provide a This option was looked in previous stages of the project and was connection between J10 and J10a discounted. 032.08 We also found inconsistencies in the traffic modelling figures, for Traffic modelling has been carried out in accordance with DfT standards. which we received no conclusive response - we are therefore It is assumed that this refers to Mr Young's questions of 11 April 2016. Of unconvinced that the modelling technique and data forms a these the first one (regarding A292 Hythe Road Eastbound towards J10) valid basis for the Scheme design was subject to a follow-up question on 5 May 2016 from Mr Young and therefore additional clarity to the original response is provided below.

A292 Hythe Road Eastbound towards J10: The change observed is in response to wider routeing on the network, which is not shown on the fairly focussed local network flow diagrams presented in the consultation leaflet. The traffic forecasts indicate that with the Scheme in place, and in particular with the delivery of the proposed new link road connecting the A2070 with M20 Junction 10a, there will be time savings for Ashford traffic wishing to travel South East on the M20. Without the Scheme, a large proportion of this traffic gains access to the M20 at J10 using Hythe Road as the A2070 alternative takes relatively longer. With the Scheme and link road in place in place, the route via the A2070 to J10a is forecast reverse this position, bearing in mind that this traffic will have to join the M20 at J10a and not J10 HA514442-MMGJV-GEN-SMW-RE-Z-10701 86 Revision A

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as the east facing slips will no longer be available. As a result a certain amount of route transfer is anticipated, with drivers shifting away from the A292 Hythe Road eastbound with the Scheme in place to focus on the A2070 alternative. It is this shift that underpins the difference in traffic volumes when the two scenarios are compared. This is not to contradict Mr Young's point; we agree it is likely that traffic from the Willesborough/Henwood area will continue to access the A292 directly. It is that 'through' traffic currently accessing the A292 from areas further south and west of Willesborough (e.g. South Willesborough) shows a shift in the modelling to the A2070 and it is the net effect of this that suggests the slight reduction in traffic.

A20 Eastbound Traffic from J10: Under the present regime, traffic on the M20 travelling coastbound (eastbound) wanting the A20 must exit at Junction 10. With the Scheme in place it is forecast that drivers will realise time saving benefits by staying on the motorway and exiting at J10a as it will offer a more attractive alternative. It is also forecast that J10a will intercept traffic from the A20 seeking the M20 in the opposite direction for similar reasons. As a result reduced traffic flows are forecast for the section of the A20 between J10 and 10a. This can be noted to a large degree by the relative change in traffic flows using the M20 eastbound offslip, the mainline flows between the junctions and the forecast flows for the proposed J10a eastbound offslip when the two diagrams are compared. It should also be noted that the Scheme will see the removal of the east facing slip roads at M20 J10 and as a consequence there will a variation in M20 mainline flows between the junctions to reflect this change.

A2070 Northbound from J10: For the 2018 year it is forecast that there will not be any noticeable change as despite the inclusion of J10a, the desire for traffic to use the A2070, northbound from J10, remains as there is currently no alternative. Any journey both to and from this section of the A2070 will therefore still need to pass through M20 J10. 032.09 Finally, we believe that the scheme has been designed to The Scheme is being promoted as a key transport requirement in support of benefit national traffic to the detriment of local residents and that future development south of Ashford. With the expected level of growth, the a few minor modifications would rectify this future capabilities of M20 Junction 10 have been identified as an issue, especially given its location along an international route that is used by

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large volumes of heavy goods vehicles and holiday traffic.

Looking to the future, there is a need to accommodate the level of housing and employment growth throughout Kent, but mainly focussed at Kent Thameside, Ashford, Maidstone and Canterbury. Local and Regional Growth will place more stress on M20 J10, which is already recognised as a ‘hot-spot’. Faced with this growth the existing M20 Junction 10 will suffer from further congestion and long delays in the future if additional capacity is not provided. The M20 is an international route that is used by large volumes of heavy goods and holiday traffic. Long distance traffic from the M20, A20 and A2070 (south of Ashford) conflicts with local traffic from Hythe Road and Kennington Road.

The Scheme is therefore a key transport requirement that is essential to the future development of South Ashford.

1.33 RR-033 PINS Ref. Relevant Representation from Paul Bartlett Response from Highways England (the Applicant) RR-033 033.01 Comments on J10A Environmental Scoping Report The document commented on in the relevant representation has been superseded by the ES and significant scheme details have changed. 033.02 The retention of the existing Highfield Lane bridge requires the The Scheme will not affect Lagonda Lodge property, only Highfield southern crossing arm of the new junction to be moved east of Bungalow needs to be demolished, and on A20 side Willesborough Garden its originally intended position and therefore closer to housing at Centre and Sweatman Mowers. Beauchamp Clerk Nurseries as we are the end of Kingsford Street (p12 refers). If the southern arm of aware is not in use now. the new junction is located where Highfield Lane currently crosses the M20, J10A will have less impact on the housing in Kingsford Street and may result in Lagonda Lodge being retained rather than falling within the scheme footprint. The loss of residential accommodation is a large adverse impact of the scheme (p113 refers) so the loss of Lagonda Lodge and Highfield, added to the loss of commercial property at Beauchamp Clerk Nurseries, Willesborough Garden Centre and Sweatman Mowers is to be avoided. It is noted that there are three garden related businesses operating on the footprint and the concentration of these three businesses in a single place is HA514442-MMGJV-GEN-SMW-RE-Z-10701 88 Revision A

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unique and advantageous to the community and would be impossible to replicate elsewhere. 033.03 There are a large number of properties affected by the loss of The Scheme is not affecting Court Lodge Farm land. land from their properties. They are Ransley House (note this Ransley House, we are only acquiring part of the land between Kingsford will doubtless have commercial effect on the kennels business Street and M20 motorway. The Scheme will not affect listed properties. located there as the land lost is integral to the business operations), Court Lodge Farm, The Hanchins and numbers 46, 86, 96 and 98 in Church Road. These are listed on p111. Ransley House and Court Lodge Farm are listed properties and the permanent land take from listed properties will be of regional significance (page 39 defines). 033.04 The list of roads affected by the Scheme are listed on p96 but The detailed (where junctions are modelled) traffic model study area this list should be expanded to take in the full effect of addition covered the urban area of Ashford, as for the previous modelling exercise, traffic flows into Ashford not just via Hythe Road (which is listed) but was also extended further to the north east to cover more of the minor but past the Designer Outlet Village (which is already a roads in that area. Not every road was modelled as this was not appropriate congestion spot). The point is that we know the Scheme will or practicable, but the majority of significant roads were included. A Kent- result in building a further 12,989 houses and 19,756 jobs wide 'buffer' network (where junctions are not modelled, and speed/flow (these are listed on page 136) and this will have very significant effects provide the capacity restraint) was added to ensure that longer- traffic movements in and around Ashford. The Environmental distance diversions could be represented. Impact Report should carefully consider whether Ashford can cope, and not just look at roads 250m from the new Scheme. 033.05 In the number of jobs created by the Scheme, 2,500 jobs at Noise and Air Quality assessments used the traffic data provided. The Sevington Phase II are included. This land is outside the land Consideration of Combined and Cumulative Effects chapter of the allocated for development and including these jobs would lead Environmental Statement was based on the Planning Inspectorate's residents to conclude that the development is given de facto guidance and incorporated proposed developments included within the support and will happen. Sevington Phase II is said to be part of Traffic Model Uncertainty Log, as well as additional developments within a a list of “proposed developments within Ashford Borough [that] 2km buffer. Refer to DCO document 6.1 Chapter 15 Consideration of have been identified”. This statement is incorrect as ABC has Combined and Cumulative Effects, and 6.2 Figure 15.1. not identified Phase II Sevington so the Environmental Impact Report should not consider unallocated developments sites in Sevington Phase 2 was dependent on the Scheme, and in line with DfT Ashford as it leads stakeholders to conclude that the required guidance was not included in the Core Scenario used for the Noise and Air procedures to allocate sites for development are not being Quality assessments. followed. 033.06 Developments and strategic planning decisions that have been Lydd Airport Expansion lies over 25km from both the Main and the taken in surrounding districts should be taken into account. A Alternative Schemes. This development lies outside the study area for the good example here is Lydd Airport. If this expands it will result in assessment of combined and cumulative effects (the 2km ZOI and the HA514442-MMGJV-GEN-SMW-RE-Z-10701 89 Revision A

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more traffic at the scheme and this will result in noise, air larger Traffic Model study area). Any effects associated with Lydd Airport pollution, vibration, and driver stress. The report says at page expansion are therefore not anticipated to interact with the environmental 111 that “other planned developments in the study area have effects associated with the Main and Alternative Schemes. Refer to DCO not yet been assessed”. It is essential that all schemes are document 6.1, Chapter 15. assessed as to their impact on traffic flows. This would be incorporated within general background growth applied via DfT's National Trip End Model (NTEM) forecasts. 033.07 The Development Consent Order for the SELEP scheme is on The SELEP scheme has been removed from the PINS website and is no hold (p137 refers). For this reason the planning applications longer a DCO scheme. which are dependent of the SELEP scheme (i.e. the AXA scheme and Kent Wool Growers) should also be put on hold as it is impossible to determine these two planning applications until the outcome of the SELEP scheme is known. For that reason I would urge the Highways Authority to object to these two applications. 033.08 The scheme would result in the loss of 12ha of permanent The Communities and Private Assets chapter of the ES (DCO Document agricultural land which is classified as Grade 2 and Grade 3a 6.1, Chapter 13) identifies impact on agricultural land as a result of Main (page 112). Both of these grades are good quality land and are and Alternative Schemes. During construction and operation the impacts on therefore the most productive and flexible. NPPF says “Planning best and most valuable agricultural land was not considered to be authorities should take into account the economic and other significant during construction and operation. There are currently no plans benefits of the best and most versatile agricultural land. Where to revisit alternatives the Main and Alternative Schemes. significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality” (this rule came out in 2012). Alternative arrangements must therefore be investigated again to the Scheme, such as expanding existing J10. The options considered in December 2005 should be reassessed in the light of the new planning guidance issued in 2012 for agricultural land and it is very likely that in the light of these new planning rules that Option 1 (from the original 2005 option assessments listed in page 11) would now be the preferred option. 033.09 There are significant access issues between Highfield Lane and Highways England considers this request to be outside the Scheme's Kingsford Street and the scheme will result in additional traffic scope. There is no justification from traffic modelling to justify this flows through the centre of Mersham if this is not addressed. It incorporation in the Scheme. Highways England have been informed by is necessary to ensure that traffic cannot travel directly from Stour Park developers that this work has been included in their section 106

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Highfield Lane to Kingsford Street as this will increase traffic agreement with ABC. Highways England will work closely with Stour Park through the sensitive village centre. Unless a way can be found Developers to ensure that this will be incorporated. to address this the Scheme must not proceed. Highways England have also been informed by Kent County Council that they will forward fund this work and will implement before the opening of the Scheme. They will work with Stour Park Developers to form an agreement. 033.10 Part of the Scheme lies in Flood Zone 3a – High Probability. DCO Document 6.3, Appendix 14.1 the Flood Risk Assessment (FRA), has This means that there is a greater than 1 in 100 probability of assessed the flood risk from the Main and Alternative Schemes. Following river flooding (page 121 refers). Clearly a lot more work is receipt of comments from the Environment Agency, the FRA will be updated required here before the Scheme can proceed, not only is there during the detailed design stage to assess the effects of the proposed a risk to flooding in the area but there is the added complication structures within Flood Zone 3. This will include flood modelling, to of runoff water from the scheme being contaminated with petrol, determine the extent of the changes in the flood zone and any mitigation diesel and the like so that when there is a flooding event it will measures required as a result. These mitigation measures will ensure that cause extreme damage to property if the water is mixed with there will be no increase in flood risk as a result of the Main and Alternative fuel. Whilst the water quality in the Aylesford Stream is classed Schemes, in accordance with the NPPF, and the Bridgefield and Finberry as High Quality we do know that water quality in the Great Stour properties will therefore not be at greater risk. and East Stour is of Medium Quality (page 124 refers). There may therefore be an effect of run off from the Scheme where An assessment of the potential water quality effects of the Main and water that flows into the Aylesford Stream is contaminated with Alternative Schemes has been carried out using the Highways England petrol and diesel during operation and construction. This may Water Risk Assessment Tool (HAWRAT). The HAWRAT assessment (DCO ultimately affect the Great Stour quality. It is quite likely that Document 6.3, Appendix 14.3) concluded that there would be no adverse properties near or on the floodplain (e.g. Bridgefield and effects on the surrounding watercourses during construction or operation, Finberry) will be at risk of greater flooding due to the changes to due to the mitigation measures proposed in the Construction Environmental the extent of the floodplain downstream from the scheme. Management Plan (DCO Document 6.3, Appendix 17.1) and the drainage design (DCO Document 6.3, Appendix 14.2). 033.11 The scheme is near to and will be built partly on the old Ashford The Contaminated Land Risk Assessment (CLRA) (DCO Document 7.4) Corporation Tip in Mersham. Drilling through the old landfill site assessed the potential for contamination from the historic landfill. Following may release a number of contaminants as record keeping in the receipt of comments from the Environment Agency, groundwater monitoring 60’s and 70’s was not as diligent as they are today. The risk is will be carried out on a quarterly basis, using standpipes installed for the that once breached the landfill site will cause harmful purposes of the Ground Investigation (GI) carried out in 2015. substances to leach into the groundwater and such sites are best left free from development. 033.12 There was a significant pollution incident near to the site of the The Contaminated Land Risk Assessment (CLRA) (DCO Document 7.4) Scheme in 2003 (page 68 refers) and greater detail of what this and the ES Chapter (DCO Document 6.1, Chapter 9) notes a pollution was needs to be sourced so that the effect of construction in incident in 2003, although this was scoped out of the assessment as it was areas affected by the pollution incident can be assessed. We do 1.45km.

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know that the Scheme land has been contaminated by Mercury (page 68, presumably these two facts are linked) so there is a question whether the construction of the scheme will release this and other pollutants into the Aylesford stream or into the atmosphere during construction. 033.13 The views from the Wye and Crundale Downs site including the The view from the Devils Kneading Trough view has been assessed and Devil’s Kneading Trough must be assessed. There is a terrific included in the Landscape and Visual Impact Assessment (DCO Document vista from these areas into Sevington and Mersham and the 6.1, Chapter 7). The assessment has concluded that given the distance view from these important sites must be protected from from site and expansive nature of this long distance view it is considered development. that the Main and Alternative Schemes would be barely perceptible from this location. 033.14 The loss of the footbridge over the A2070 (page 112) and The bridge is no longer being replaced by signal controlled crossing, but will replacement with two signalised crossings at the southern end instead be replaced by a new bridge structure, which will be compliant with of the link road would result in significant longer journey times the Equalities Act 2010 and accommodate pedestrians and cyclists. for pedestrians who use the bridge. It will also impact cyclists who use the bridge. The journey to cross the A2017 from one part of Sevington to the other will be much more difficult than is currently the case and the footbridge must be retained. 033.15 There is great confusion over what is planned for the link road – We are not proposing signalised junctions in the Scheme. It is clear on the page 112 refers to two signalised crossings and page 12 refers Scheme drawings that the new roundabout will be constructed to connect to a roundabout. Before an Environmental Impact report can be A2070 link road with existing A2070. written the designers need to be clear. The impact of each will The noise calculation process includes a component of additional noise due be different, particularly on the noise on the Highfield Estate and to gradients. Sevington Church. Now the residents suffer from the noise of lorries moving slowly to the J10 in a low gear as J10 is at the top of an incline. Will this get better or worse with the inclusion of either a roundabout or traffic lights at the southern end of the link road? There is also the very important question of the gradient of the link road along with at least one set of traffic lights on the link road – will residents on Kingsford Street be faced with the same noise pollution as the Highfield residents currently suffer? 033.16 Sevington Church is a delightful, well used Church. It is Grade I. The noise impact of the Main and Alternative Schemes on St Mary's Church One very pleasant aspect of the Church is the pealing of the at Sevington have been assessed in DCO Document 6.1, Chapter 11. bells (often change ringing) and there is fear that this unique Mitigation in the form of a bund/barrier will screen noise from the western attribute of the Kent Countryside will be lost from Sevington for end of the proposed Link Road and the roundabout. In response to Historic HA514442-MMGJV-GEN-SMW-RE-Z-10701 92 Revision A

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good. This is because the southern end of the link road will be England's relevant representation, a further assessment of noise impact within about 70 yards of the Church. The southern end of the upon the church has been undertaken which is reported in the Statement of link road will have either a roundabout or signalised crossing Common Ground with Historic England. This additional assessment which will cause additional noise of stop starting vehicles concluded that for both the Main and Alternative Schemes without the (especially air breaks from HGVs) which will drown out the proposed barrier/bund there would be noise increases of approximately pealing. It will also cause the loss of amenity land between the 1dB, whereas with the bund/barrier there would be noise changes of Church and Aylesford Stream. There is a popular and well used between -1dB and 1dB. To put these values into context, a change of 1dB tract past the Church towards the stream which is popular with is the smallest that is considered perceptible, thus changes of less than 1dB dog walkers and for general amenity use. would be considered negligible.

The land between St Mary's Church and Aylesford Stream is private land, currently under agricultural use. Public Right of Way AE337A and AE388 between the church and the Aylesford stream falls within the Stour Park development and will not be affected by either the Main or Alternative Schemes. 033.17 The junction of Barrey Road and the A2070 is badly in need of Highways England understand concern regarding the Barrey Road exit onto upgrading to traffic lights or a roundabout. There have been a the A2070, we notice that a number of residents have raised similar good number of accidents where slow moving traffic joins fast concerns in the relevant representations. moving traffic. This must be included as part of the Scheme if The last traffic assessment of the Barrey Road Junction was done prior to the Scheme is to proceed. 2013 when permission to occupy the empty units in the Ashford Retail Park was given, and at that time it was indicated that there would be a negligible impact on traffic overall. Therefore before the Scheme starts we have already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

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currently on-going, to resolve any existing traffic issue ahead of the Scheme, which is supporting the discussion by providing the relevant data and additional traffic surveys. 033.18 The access to the William Harvey Hospital from Mersham and Journey time reliability to The William Harvey Hospital will generally be Sellindge will be greatly hampered by the new road layout as improved as less congestion is forecast to occur at junction 10 in the future car journeys will have to cross two big roundabouts at new J10A with the addition of junction 10a. See the Consultation Report (chapter 6, and old J10. This will add over 250m to journey lengths and will para 6.5.23) for further explanation add significant stress to those seeking to get to the hospital. For similar reasons it is important that the access to the A2070 from London is maintained at J10 so traffic can more quickly access the hospital. Without it journey distances will increase by over 500m.

1.34 RR-034 PINS Ref. Relevant Representation from Peter Twaite Response from Highways England (the Applicant) RR-034 034.01 To consider the possibility of traffic lights or a roundabout at the Highways England understand concern regarding the Barrey Road exit onto junction of Barrey Road and the A2070. This could be achieved the A2070, we notice that a number of residents have raised similar by a slight re- routing of the proposed buildings access road concerns in the relevant representations. The last traffic assessment of the Barrey Road Junction was done prior to 2013 when permission to occupy the empty units in the Ashford Retail Park was given, and at that time it was indicated that there would be a negligible impact on traffic overall. Therefore before the Scheme starts we have already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

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1.35 RR-035 PINS Ref. Relevant Representation from Pilgrims Hospices Response from Highways England (the Applicant) RR-035 035.01 The Ashford Hospice is situated on the Hythe road and is a Highways England will not be requiring all of the land opposite the Pilgrims peaceful sanctuary for dying and very ill people. Hospice on a permanent basis. Any private arrangements for the use of the land will be a matter for the Hospice and the relevant landowner(s). We manage the end of life for over 2,500 local people in any one year. There is the potential of a small site compound to be located opposite Hospice. The main site compound would be situated off the A2070 away The proposal to build a motorway fly off in front of our building from the Hospice. Any compound located opposite the Hospice would be will have severe implications on the peace and tranquillity that is subject to measures laid out by the local environmental health officer. integral to the last weeks of our patients’ lives. Highways England contractors would also be required to apply for the ‘Considerate Constructors Scheme’. Part of the Schemes focus is on Our gardens are currently an oasis, vital for the wellbeing of the respecting the community. Highways England is committed to meeting with patients and the visitors and residents. These gardens face the Hospice representative to talk through proposals. directly onto the Hythe road. Clearly having motorway traffic coming past in the numbers Noise impacts on the Hospice were assessed in the Environmental proposed will decimate these peaceful settings, and severely Statement (DCO Document 6.1) Chapter 11; Noise and Vibration. This disrupt the end of life experience of thousands of local assessment concluded that levels of noise from the A20 once the Scheme residents, not to mention the impact it will have on the relatives is in place are expected to reduce. Highways England has also incorporated who need to be able to rest in a peaceful environment and come an acoustic bund 2m high to the rear of Summerhill Place, adjacent to the to term with the reality of the situation they are experiencing. M20 junction 10a eastbound off-slip.

It is also important to understand the layout of the wards, our The Council's interactive website map did not show any trees within the bedrooms are on the first floor facing the gardens, looking out to boundaries of the Scheme when used at the time of compiling. However the right they can see the Hythe road (therefore it is not possible now the Tree Preservation Orders (TPO) trees at Pilgrims house are to shield the bedrooms from the road with bushes or fences). identified the design has been altered and no trees within Pilgrim house The additional noise, congestion and fumes, will mean that it will land will be affected. A site visit to ascertain the full arboricultural impact on be almost impossible to open the doors onto the bedroom woodland W1 on 15th November can also be used to review Root balconies, as you can imagine this will have the effect of Protection Areas of trees bordering Pilgrim house land to make assurances incarcerating dying patients in their rooms making access to of this. HA514442-MMGJV-GEN-SMW-RE-Z-10701 95 Revision A

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meaningful nature impossible. I am sure nobody would wish this on our patients.

The gardens cannot be moved, and to add insult to injury, we now hear that a large part of our car park and our only entrance is going to be compulsory purchased ostensively for a builder’s complex. I am sure you can imagine the noise that will emanate from that use, heavy Lorries, early starts, possible 24 hour working, shouting builders, hot tarmac, etc., etc.

Apart from this noise the loss of the car park will severely restrict access for visitors, relatives and staff, the hospice is not well served by public transport and it will be especially difficult for our elderly volunteers to get to the Hospice. Without these volunteers we will have no choice but to shut the site for the duration of the build. If we were to shut the site the consequences for the NHS would be dire as they would have to deal with all the patients that we could no longer house, over 2,500 more NHS beds would be needed.

The local people would rightly be up in arms if we had to shut the hospice due to this scheme and I think the public outcry would be massive. On a personal note having used the roundabout where the alleged congestion is, for almost 2 years, I would also like to question the rationale of spending money on a scheme to alleviate only a minute or two of queuing at worst, when there are far more needy schemes crying out for money and investment. The most relevant being the Wincheap works to move traffic away from the Wincheap train bridge, congestion there means that cars are stuck in traffic for at least half an hour EVERY DAY. Surely we want to put our precious money into relevant schemes that help many instead of pointless schemes that help a few.

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I look forward to a more in-depth review of this scheme that will not affect the last few weeks of life of thousands of Ashford residents, and will put the money into other schemes where it will really make a difference.

1.36 RR-036 PINS Ref. Relevant Representation from PSP Consulting on behalf of Response from Highways England (the Applicant) RR-036 Taylor Wimpey 036.01 We have reviewed the DCO Application and in particular the See under 036.02. Scoping Opinion and the AECOM Transport Assessment (TA). We are concerned that ‘Commitments’ to establish the correct baseline may have been understated and that ‘Planned Development’ for future year testing may not have been properly considered. Thus the TA does not appear to be consistent with ‘The Development Plan’ as set out in the Planning Inspectorate’s Scoping Opinion. 036.02 We can see from TA paragraph 3.1.3 that the AECOM updated The development quanta in the Core Scenario (and all other scenarios) traffic model “has its origins based upon the M20 J10a 2010 were updated independently of the old AHTS model, and to a newer base Transport demand Model, which was an updated version of one year. Consequently the development data in the two models is not directly used for the Ashford 10a Highway Traffic Study (AHTS) founded comparable and should not be compared one against the other, not least as on data collected in 2003” and at paragraph 3.1.4 “as part of the the newer model will include new builds between 2003/2009 (the two AHTS latest revision, the model has been further updated to a 2014 demand model updates – see ASR 4.1.2) and 2015, the base year of the base year and develops it sufficiently to enable testing for current model. planned development and consideration of the wider assessment needs that arise within the M20 corridor”. 036.03 Under ‘Local Growth Forecasts’ at TA paragraph 3.4.10 “the Our approach is consistent with DfT’s current WebTAG guidance, and was traffic modelling process requires the production of a ‘Core’ also agreed with ABC. It may differ from what was current guidance at the Scenario. The ‘Core’ Scenario is founded on the most unbiased time of the AHTS modelling work. and realistic set of assumptions that form the central case for the Main and Alternative Scheme. This includes assumptions on local uncertainty in terms of delivery, which is typically dependent on whether developments or other planned transport schemes go ahead in the vicinity of the scheme “. We consider this approach to be inconsistent with the analysis undertaken by the Highways Agency in the preparation of AHTS which set out

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detailed assessments of commitments and then modelled the full Core Strategy development. 036.04 The March 2015 Scoping Opinion from the Planning In terms of the Transport Assessment the derivation of the Core Scenario Inspectorate explains at paragraph 2.4 “Ashford has been that was used in the network modelling was pursued in accordance with identified as a major growth area in Kent with 31,000 additional DfT’s WebTAG guidance, a process outlined briefly within the TAR by homes and 28,000 new jobs anticipated in the area by 2031”. paragraphs 3.4.10 to 3.4.12 as noted by Mr Gurner. And at paragraph 3.73 “The assessment of cumulative and combined effects is particularly important for a number of Overall the Uncertainty Log explicitly accounted for 11,189 dwellings being environmental topic areas, as noted above, and the ES should developed in Ashford over the period 2015 to 2031 (and 14,270 jobs). This address each topic area fully”. was compared with the Strategic Housing Assessment that had identified a need for 14,345 dwellings in Ashford between 2011 and 2030. It was agreed with ABC that the difference in numbers of some 3,000 dwellings equated to completions between 2011 and 2015 and developments in rural areas outside the study area.

The quanta of dwellings and job growth outlined in Table 3.9 of the TAR was therefore compiled to reflect the overall number of developments that were expected to accumulate over the period 2015 to 2031; i.e. up to approximately 11,189 prior to categorisation under the various WebTAG headings of ‘Near Certain’, ‘More Than Likely’, ‘Reasonably Foreseeable’, and ‘Hypothetical’. The entire list was compiled in response to discussions and agreement at the time with ABC, and moved forward from base to forecast year. The level of development between the former base year and that revised for the TAR therefore accounted for known development delivery over the intervening period.

From data available at the time the balance of dwellings recorded as the

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accumulated total over the period 2015 to 2031 and included in the Core Strategy (10,589) set against the equivalent provided by the overall log (11,189) equated to a difference of only 600 dwellings. 036.05 Ashford Borough Council’s 18TH February 2015 response to One of the main concerns from the above representations is that the the HA’s Scoping Report advised that “The Development Plan Development Plan position may have been understated in the DCO comprises the saved policies in the adopted Ashford Borough documentation. The purpose of the Uncertainty Log is to ensure that local Local Plan 2000, the adopted LDF Core Strategy 2008, the developments in the appropriate certainty categories are represented adopted Ashford Town Centre Area Action Plan 2010, the explicitly in the modelling, to increase local accuracy. However overall Tenterden and Rural Sites DPD 2010, the Urban Sites and growth in households and jobs at district level is constrained to official DfT Infrastructure DPD 2012, the Chilmington Green AAP 2013.” forecasts. In the modelling this ‘background growth’ is applied by scaling traffic levels up across each district having first removed the effects of the developments to be treated explicitly. In this way, allowance for growth up to official forecasts is maintained.

However, it is accepted that the PINS Scoping Opinion quotes the original dwellings and employment forecasts from the 2008 Core Strategy and sensitivity tests were run assuming full build-out at Finberry (and neighbouring Waterbrook) by 2033 with a corresponding reduction in background growth. These tests represented the situation both with and without assumptions to take into account measures to reduce car usage, as referenced in the Core Strategy. Without these measures, the results led to some local network stress by 2033, mainly on the development access roads; with the additional measures, these accesses were considerably improved.

This process is explained in greater detail in the Traffic Forecasting and Economic Assessment Reports. 036.06 In our opinion, the AECOM TA does not provide an assessment The forecasts for the current work are all estimated from the base year of of cumulative and combined effects consistent with the 2015, on the basis that traffic associated with all completed developments Development Plan and the ‘realistic’ assessment described in up to 2015 is implicitly accounted for in the observed base year traffic flows the AECOM TA appears to be a ‘sensitivity test’. Given that M20 and conditions that the base model is set up to replicate as closely as J10a is necessary to unlock development to 2031, we believe practicable. that the Development Plan position has been understated in the DCO documentation. The forecasts are then split into two parts: development from 2015 in the We wish to present our views at the Examination. local area, which is modelled explicitly to increase model accuracy in the Patrick Gurner BSc CEng MICE areas of greatest interest; and ‘background’ growth associated with more

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Director PSPconsulting widespread developments that it is not practicable to attempt to model On behalf of Taylor Wimpey and Persimmon Homes explicitly. The latter are instead dealt with by factoring up base year trips not The developers of Park Farm, Ashford associated with explicitly-modelled developments according to official DfT growth forecasts at district level.

The overall growth must be controlled to these official forecasts at district level. Thus the more developments that are modelled explicitly, the greater the reduction in the background growth factors such that the total number of trips remains constant.

This process is set out in DfT’s WebTAG guidance, and was agreed with ABC. There may be differences in approach and assumptions since the AHTS model, but in principle the quanta of development for each proposed scheme, the likelihood of these schemes being built, and the dependency of each scheme on the M20 J10a in the final Uncertainty Log were as per the best opinions of all relevant bodies, including ABC, at the time that the Uncertainty Log was finalised.

Also see responses to RR-004 and RR-009.

1.37 RR-037 PINS Ref. Relevant Representation from Public Health England Response from Highways England (the Applicant) RR-037 037.01 PHE notes that the applicant has provided a health impact Any works on areas of potentially contaminated land will be carried out with assessment navigation document (Appendix 4.3 Volume 6.3) the agreement of the Local Authority and Environment Agency such that it within the Environmental Statement (ES). We consider that the will not lead to off-site impacts on receptors. public health impacts likely to arise from the development on air, land and water have been adequately considered in the related The impacts of the Main and Alternative Schemes on Air Quality are sections of the submission. described in DCO Document 6.1, Chapter 5. It is not proposed to do any We note that the scheme crosses or passes close to several operational air quality monitoring as the results of the assessment sites which may be contaminated by historical activities. Whilst concluded effects were not significant. Uncertainty in the assessment is the main risk is posed to workers on-site, we expect that any dealt with through the methodology used and specifically the inclusion of a works on areas of potentially contaminated land should be with model verification which compare modelled outputs against monitored the agreement of the Local Authority and Environment Agency values in the base year of the assessment and the use of the HE’s Long such that it will not lead to off-site impacts on receptors. Term Trends calculator to deal with uncertainty in future emission projections. Accordingly, no mitigation or operational air quality monitoring HA514442-MMGJV-GEN-SMW-RE-Z-10701 100 Revision A

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The proposer’s air quality assessment is dependent on a is required. number of assumptions, for example related to traffic flows and traffic emissions, and our review is based on the assumption Additional monitoring is currently being undertaken in the area where that the traffic modelling undertaken is both robust and predicted concentrations are above the air quality objectives. The impacts validated. The proposer’s air quality assessment indicates that of the Main and Alternative Schemes at these locations are ‘imperceptible’ concentrations of nitrogen dioxide (NO2) are predicted to however due to changes in elevations between the carriageway and the exceed air quality standards with or without the Scheme at location of the receptors the modelled concentrations are likely to be some locations in the study area. However, the proposer states conservative. that no exceedances are predicted to be caused by the Scheme and any changes in NO2 concentrations are predicted to be imperceptible. It is unclear if the proposer intends to undertake air quality monitoring once operational to verify the assessments. 037.02 The majority of the potential impacts on public health during the Highways England will consult with the Environment Agency and Local construction phase will be controlled by the implementation of a Authority to ensure the proposals for control, mitigation and monitoring suitable and sufficient Construction and Environmental contained within the Construction Environmental Management Plan are Management Plan (CEMP). PHE requests that, prior to the appropriate. issuing of a Development Consent Order (DCO), the Planning Inspector confirms that both the Environment Agency and Local Authority are satisfied with the proposals for control, mitigation and monitoring contained within the CEMP or equivalent document. 037.03 On the basis of the submitted documentation PHE does not Noted. envisage any significant further involvement in the development consent process but requests that we be notified and consulted should there be any significant changes to the currently submitted proposals or should any public health concerns be raised by a third party. 037.04 PHE reserves the right to make additional comments or Noted. observations at a future date.

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1.38 RR-038 PINS Ref. Relevant Representation from Rebecca Cowling Response from Highways England (the Applicant) RR-038 038.01 I would like to request that during your M20 Junc 10A works you Highways England understand concern regarding the Barrey Road exit onto can please consider improvements to the Barrey Road Junction the A2070, we notice that a number of residents have raised similar from Ashford Business Park - I notice in the plans the Bad concerns in the relevant representations. Munstereifel Road / A2070 will be altered, it would be wonderful if a roundabout or traffic lights from Barrey Road onto the A2070 The last traffic assessment of the Barrey Road Junction was done prior to could be incorporated into the plans with an option for the traffic 2013 when permission to occupy the empty units in the Ashford Retail Park to go right and not only have the option to go left up to Junc 10 - was given, and at that time it was indicated that there would be a negligible this would elevate congestion at the junction of Barrey Road impact on traffic overall. Therefore before the Scheme starts we have and reduce the amount of traffic going to Junction 10 already put in place enhancements to the A2070 and Barrey Road by inadvertently, just to come back on themselves and hopefully improving signage and visibility at the junction, and we will be reducing the reduce the amount of accidents at this junction speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

1.39 RR-039 PINS Ref. Relevant Representation from Savills on behalf of Wyevale Response from Highways England (the Applicant) RR-039 Garden Centres Limited 039.01 WYEVALE GARDEN CENTRE, HYTHE ROAD, Noted. WILLESBOROUGH, ASHFORD, KENT, TN24 0NE PROPOSED M20 JUNCTION 10 IMPROVEMENT

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On behalf of our client Wyevale Garden Centres Holdings Limited (Wyevale), Savills wish to make a representation to the proposed M20 Junction 10a improvement consultation.

Wyevale own the freehold title in Wyevale Garden Centre, Hythe Road, Willesborough, Ashford, Kent, TN24 0NE (the Property). The Property is situated on Hythe Road, located between the M20 and A20 approximately 750m from Junction 10 of the M20.

The Wyevale Garden Centre has been operating a successful and profitable business at the Property since 1952 trading gardening and household goods to the local community and beyond. Wyevale enjoys the loyalty of many returning customers along with passing trade due to its prime location as a result of its proximity to Ashford, the M20 and the A20. The Garden Centre also provides employment for thirteen people within the area, jobs which may be lost if the Garden Centre is forced to close as a result of the road proposals. The Garden Centre is very conveniently located along the A20 and is highly accessible for customers from a wide area. The creation of an enjoyable shopping experience with a wide range of products for both the garden and in the house, in a well laid out centre is an important element in the attraction of the site.

The preferred option application for a DCO has been submitted and accepted by the Planning inspectorate. This scheme proposes to construct a new, partially signalised junction 10a with two 3 lane bridges on the M20 and link road to the A2070 at Ashford as well as connections to A20 Hythe Road. This option will result in the proposed new junction being located directly where the Property is situated currently. It will not be possible for Wyevale to continue their operation on the site. 039.02 Objection

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039.03 The application, if approved, will result in the removal of our Noted. Client’s business at the Property and the loss of this valuable The impact of the closure of the garden centre has been assessed in the trading site. economic and land use report, reflected in the DCO Document 6.1, Chapter 13; Communities and Private Assets. The net impact on the area of the Scheme is a positive one in terms of jobs and economic growth. The specific loss of the garden centre is acknowledged as a significant adverse effect, however. 039.04 It will also result in the loss of a number of other businesses on Noted. the site. 039.05 A consequence of this may be significant loss of employment in Noted. the area. 039.06 The closure of the Garden Centre is likely to reduce shopping Yes, we agree that A20 shopping area will decline but other areas are capacity in the locale. expanding. 039.07 The number of shoppers and visitors to the area may decline. Yes, we agree that A20 shopping area will decline but other areas are expanding. 039.08 Whilst or clients have responded to the formal consultations Noted, Highways England will work with Garden Centre to ensure that both produced by Highways England, there has been no dialog with parties are happy with the proposal. Highways England, as they have not responded to our consultation responses. Thus the “consultation” has been somewhat one sided. 039.09 If the DCO is confirmed, it is not certain, from the plans Highways England to discuss with the landowner their proposal. submitted that Highways England intend to take the whole of our client’s site permanently. Certainly, parts of property in our client’s ownership are scheduled to be acquired temporarily. As it will not be possible to continue trading from the site after the works, we will be seeking to ensure that all of our client’s land holding at this location is acquired permanently. 039.10 It is not clear whether the approach of providing a multiple Highways England has discussed with PINS multiple options submission, option application for a DCO was envisaged under the Planning they accepted Highways England submission and them taking through Act 2008, nor whether this is therefore a lawful application by examination. We are following the PINS advice. Highways England. We therefore reserve the right to challenge this approach to the application and the Planning Inspectorate’s acceptance of the application in the future. 039.11 Our client’s therefore intend to oppose the daft Development Consent Order which seeks to confer compulsory purchase

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powers and rights to acquire an interest in our Client’s Property as set out above.

1.40 RR-040 PINS Ref. Relevant Representation from Sharon Swandale Response from Highways England (the Applicant) RR-040 040.01 I live next to the proposed site. I am particularly concerned Response based on assumption that the homeowner is located on about safety, pollution both noise and fumes and trying to Kingsford Street. minimise damage to our listed property. Light, noise and air pollution (dust) during construction will be mitigated through the implementation of the Construction Environment Management Plan (DCO Document 6.3, Appendix 17.1)

Mitigation for noise impacts will be provided through the use of thin surface course (low noise) surfacing and noise bunds/barriers (DCO Document 6.2, Chapter 11, Paragraph 11.7.2). A noise barrier will be provided north of Kingsford Street, with native tree and scrub planting in front of the noise barrier, providing screening for the properties along Kingsford Street. The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides full details of the Scheme’s proposals.

Survey of the property foundation can be carried out prior to construction works to ensure that the vibration from the proposed works will not affect the property.

1.41 RR-041 PINS Ref. Relevant Representation from Southern Gas Networks PLC Response from Highways England (the Applicant) RR-041 041.01 Southern Gas Networks PLC (“SGN”) is a statutory undertaker, The Protective Provisions contained in Schedule 8 of the draft DCO are responsible for the management of a network of gas apparatus appropriate and acceptable. that is used to distribute gas to 5.8 million homes and businesses across Scotland and the south of England. SGN is responsible for the safe and reliable operation of the said network and as such must ensure that the said network is not adversely impacted by Highways England’s construction project

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known as M20 Junction 10a (“the Project”).

SGN is prepared to discuss the terms of the Project with Highways England with a view to ensuring its successful delivery. However, SGN wishes to make it clear that its agreement, to the terms of the Project, can only be granted on the condition that Highways England provides SGN with an assurance that the safety and integrity of the network, operated by SGN, will not be adversely affected by the Project. In particular SGN wishes to make it known to Highways England that the Project encroaches into land under which a Major Accident Hazard Pipeline (“the Existing Utility”) is situated and that as a result SGN expects Highways England to take all necessary measures to ensure that the Existing Utility is properly protected prior to the implementation of any works associated with the Project.

Please note that ‘all necessary measures’ extends to SGN being provided, by Highway England and at Highway England’s sole cost, with all the necessary land, and ancillary rights, that SGN might reasonably require in order that they might divert the Existing Utility to an area unaffected by the Project.

1.42 RR-042 PINS Ref. Relevant Representation from Stuart John Ramsay Response from Highways England (the Applicant) RR-042 042.01 In respect of this planning my issues surrounding the building of Ransley House and the grounds in which it sits are owned by Mr Stuart Jct10a are not limited to but include the following. John Ramsey. The site (ref: K609528) occupies 3,641.73m2 to the south of the existing M20 carriageway. It is accessed via Kingsford Street, which run My property is both residential and a working kennel and cattery parallel to the M20 on this stretch. The land itself sits either side of business which has served the local community for well over 35 Kingsford Street. years of which the last 10 years has been in my hands. Any land to be compulsory purchased from me could mean the end The land owned by Mr Ramsey is used a private residence and is also of my business in its current form as I may not be able to serves as a boarding kennels and cattery, run by Mr Ramsey for the past 10 operate to a level required in todays world as my storage years. The majority of the business operation is located on the land to the HA514442-MMGJV-GEN-SMW-RE-Z-10701 106 Revision A

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facilities, exercise areas to name just two things could be south of Kingsford Street, where Ransley House itself, Mr Ramsey’s reduced to a level rendering me unable to operate. residence and the majority of the buildings for the kennels and cattery are located. The road lay out also causes issues and customers would then have to drive through Mersham and onto Kingsford Street from The land to the north includes a storage shed and exercise areas used as the far end causing an increase in traffic through the village part of the kennels business. which in the height of my busy period could cause more issues. The entirety of land to the north of Kingsford Street is permanently required The related noise, dust and overall up disruption will also deter for the construction of the Scheme. No land is required from the area to the people from bringing their animals to me for boarding as the south of Kingsford Street. building work is literally a stones throw away. Delivery of the Main and Alternative Schemes will require land take totalling 2,246.3m2 from Mr Ramsey’s plot. This will affect the exercise area and My property is also Grade II listed, dates back to the 1600’s and storage facilities that form part of the cattery and kennels business operated is well known and documented as a part of local smugglers from the site. gang the “Ransley’s”. The property has remained largely undeveloped and therefore to build this so close to cause blight The total land take represents 61.7% of the total area of land owned by Mr and reduce its appeal should be avoided at all costs. Ramsey and while the area to be taken by the Scheme does not include the residential property or key facilities of the cattery and kennels, the area is I hope these points will be taken into consideration on considered important to the effective running of the business. examination Because of the extent of the land take (almost two thirds of the total plot is required) and the lack of alternative equivalent premises adjacent or nearby, the receptor is considered to be of high sensitivity.

Because the land take is permanent, irreversible and substantially affects the receptor in question, the magnitude of the impact is considered to be high.

Compensation at market rate will be offed to Mr Ramsey for the loss of property to mitigate some of the effects. However, the residual effect on the business is considered to be significant.

This assessment does not include the impacts on the heritage aspects of Ransley House, which was considered as part of the cultural heritage chapter of the Environmental Statement.

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Impacts on local traffic, noise and air quality are discussed in the relevant chapters of the Environmental Statement and are subject to mitigation through the Construction Environmental Management Plan and traffic management measures proposed during both construction and operational phases.

A socio-economic assessment has been undertaken and can be found in Appendix A of the Environmental Update Report (DCO Document 10.13).

1.43 RR-043 PINS Ref. Relevant Representation from Sue Appleby Response from Highways England (the Applicant) RR-043 043.01 As a resident of Hythe, I believe the plans for these changes are Noted. Awaiting further details. relevant to me.

1.44 RR-044 PINS Ref. Relevant Representation from The Village Alliance Response from Highways England (the Applicant) RR-044 044.01 Does the construction of J10a represent good use of in excess The Scheme will provide as well new A2070 Link Road, which will support of £85m, when in essence it is only providing an additional two and allow the delivery of residential and employment development either slip roads, because of it's proximity to J10, the two east bound proposed or permitted within Ashford growth area. The proposed Scheme slip roads will be lost. will provide new route for traffic into Ashford.

For full details of the economic assessment, benefits and dis-benefits associated with the Scheme see Volume 7 - 7.1 Case for the Scheme, Chapter 5 - Economic Case. 044.02 Traffic modelling - how accurate are future HGV movements The HGV numbers were obtained from the Transport Assessment carried which will be generated by the proposed warehouse out for Sevington and phasing correspondence with ABC. The resulting development at U19 Sevington? Will the increased HGV traffic level of HGV trip generation is not sufficient to use up all the spare capacity use all the additional capacity provided by J10a? at J10A according to the modelling work carried out for future years. 044.03 No significant improvement is proposed for the Barrey Road Highways England understand concern regarding the Barrey Road exit onto junction. A signalised junction has been requested, to allow right the A2070, we notice that a number of residents have raised similar hand exit and for safety. There is serious concerns over safety concerns in the relevant representations.

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for vehicles wishing to turn right out of Barrey Road and having to filter right to access the new roundabout on the link road. The last traffic assessment of the Barrey Road Junction was done prior to 2013 when permission to occupy the empty units in the Ashford Retail Park was given, and at that time it was indicated that there would be a negligible impact on traffic overall. Therefore before the Scheme starts we have already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for right hand turns around the link road roundabout as part of the Scheme.

Furthermore after a meeting on 30 November 2016 with Local Authorities and local businesses further discussions between Highways England Area 4 Spatial Planning and Kent County Council were planned, and they are currently on-going, to resolve any existing traffic issue ahead of the Scheme, which is supporting the discussion by providing the relevant data and additional traffic surveys. 044.04 A petition has been presented to KCC Joint Transportation Highways England considers this request to be outside of the Scheme’s Committee signed by 234 residents to close Highfield Lane to scope. There is no justification from traffic modelling to justify this Kingsford Street and this had been passed to HE. The J10a incorporation in the Scheme. Highways England have been informed by scheme proposes closing the Highfield Lane and Kingsford Stour Park developers that this work has been included in their section 106 Street access to the A20. This leaves the continued link of these agreement with ABC. Highways England will work closely with Stour Park two lanes open to "rat running" through the centre of Mersham Developers to ensure that this will be incorporated. from the A2070 and the A20. This happens at the slightest Highways England have also been informed by Kent County Council that congestion. This scene will also leave Mersham with a they will forward fund this work and will implement before the opening of the connecting road to the proposed warehouse scheme. at U19 Scheme. They will work with Stour Park Developers to form an agreement. Sevington. The closure of these two lanes must be considered as part of the J10a scheme, before construction starts. Any inevitable delays on the A20 will result in traffic from A20 and A2070 using this rat run. Highfield Lane and Kingsford Street are narrow, single track lanes, with blind bends, no pavement

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and a children's play park, used by pedestrians, joggers, children, cyclists and horse riders. Rat running through the centre of Mersham village would be extremely hazardous and must be prevented prior to commencement of scheme. 044.05 There is concern that ambulances travelling from the east Journey time reliability to The William Harvey Hospital will generally be (Folkestone) will have to negotiate J10a and J10, thus improved as less congestion is forecast to occur at junction 10 in the future increasing journey time and putting lives at risk. with the addition of junction 10a. See the Consultation Report (chapter 6, para 6.5.23) for further explanation 044.06 There is concern over increased traffic, particularly HGVs, using Highways England acknowledges that local traffic will use the A20 in the section of the A20 between J10 and 10a. The road is not preference if this is perceived as being a quicker route. The traffic numbers wide, has many entrances and exits and a roundabout and may are expected to be relatively small; the traffic model forecasts this to be in become a potential bottleneck. the order of 5 to 10 vehicles an hour. Please refer to Chapter 6, para 6.5.36 of the Consultation Report for further details.

The main traffic travelling east towards Dover or west towards London will be directed through new A2070 Link Road and new M20 J10a. A20 will be signed as a local road. Please see our Signing Strategy document (Volume 7, 7.5 Signing Strategy) for the detailed information about our signing strategy for the existing M20 J10 and new M20 J10a. 044.07 There is grave concern over air quality, both at the William The Scheme traffic data showed that there were no changes in traffic Harvey Hospital and Pilgrims Hospice. characteristics that trigger the need for an air quality assessment within 200m of the William Harvey Hospital. Roads that trigger an air quality assessment are referred to as the affected road network (ARN) and are presented in DCO Document 6.2, Figure 5.2 Operation Phase Study Area for Main and Alternative Schemes. Beyond 200m, the effect of changes in traffic characteristics, and therefore emissions, can no longer be distinguished from ambient concentrations. Therefore the William Harvey Hospital was not included as a receptor in the air quality assessment. Concentrations predicted close to the Pilgrims Hospice are well below the relevant air quality objectives. Additionally, there are predicted improvements in air quality along the section of the A20 adjacent to the Pilgrims Hospice during the operation of the Main and Alternative Schemes. 044.08 The country lane nature of Kingsford Street next to the new slip The limited space available along Kingsford Street will necessitate the road should be protected by retaining the existing country hedge removal of existing vegetation to allow the construction of the new shared and constructing a footpath behind the hedge. If lighting is footway/cycleway and noise barrier. A new hedgerow with intermittent trees will form part of the planting design for the area north of Kingsford Street. HA514442-MMGJV-GEN-SMW-RE-Z-10701 110 Revision A

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necessary on the footpath it should be low level and discrete. Proposed native tree and scrub planting will be provided to the rear of the Lighting on the foot bridge should be the same. noise barrier, providing screening for the new slip road and the existing M20 corridor. The Environmental Masterplan (DCO Document 6.2, Figure 2.6f) provides full details of the Scheme’s proposals.

The lighting impacts of the Main and Alternative Schemes are assessed in DCO Document 6.1, Chapter 7. The lighting scheme includes the introduction of low directional LED bollards on Kingsford Street and the new Kingsford Street Footbridge. 044.09 Low noise surfaces should be used, extending as far as Highways England will specify thin surface course surfacing which will possible to protect Willesborough and Sevington residents mitigate noise from the Main and Alternative Schemes (refer to DCO Document 6.1, Chapter 11, Paragraph 11.7.2) on all scheme roads except A20 which will be still manged by KCC.

1.45 RR-045 PINS Ref. Relevant Representation from Vivian Blaney Response from Highways England (the Applicant) RR-045 045.01 I believe a simple solution to the problems arising trying to exit Highways England understand concern regarding the Barrey Road exit onto Ashford Business Park at Sevington is to add traffic lights. the A2070, we notice that a number of residents have raised similar concerns in the relevant representations. If traffic could be taken away from Jct 10 if it didn't need to use it by adding the lights traffic would not build up plus when the M20 The last traffic assessment of the Barrey Road Junction was done prior to is closed during Operation Stack or after a serious accident, 2013 when permission to occupy the empty units in the Ashford Retail Park traffic would be able to find an alternative route by turning at the was given, and at that time it was indicated that there would be a negligible lights, either those coming up to jct10 from south of Ashford or impact on traffic overall. Therefore before the Scheme starts we have off the Business Park. already put in place enhancements to the A2070 and Barrey Road by improving signage and visibility at the junction, and we will be reducing the I suppose it requires fatalities to all of a sudden make it viable; speed limit to 40mph on Bad Munstereifel Road and re-routing traffic for the speed of traffic going past the entrance to the Business Park right hand turns around the link road roundabout as part of the Scheme. and not moving over to allow traffic to join means we may not be far from that! Any subsequent amendment to this junction would require a Traffic Assessment of the Ashford Retail park and residential traffic impact to be initiated by the local network authority at the request of local stakeholders, which is not part of the Scheme as Highways England Major Projects deals with Nationally Significant Infrastructure (NSIP) Construction.

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1.46 OD-003 PINS Ref. Relevant Representation from Royal Mail Group Response from Highways England (the Applicant) OD-003 OD Highways England should set out its framework for consultation Highways England prepare communication strategies for all their projects 003.01 with major private road which list stakeholders both national and local to the schemes. For this users, including Royal Mail; scheme, Royal Mail were a named stakeholder and had consultation information sent to them. OD The ‘Community Relations Strategy’ should include proposals to Highways England will ensure that Royal Mail are included as part of the 003.02 implement a communication Community Relations Strategy. programme with key transport and haulage businesses such as Royal Mail, to enable such businesses to plan ahead when key traffic management measures are programmed; OD The proposed ‘Traffic and Transport Management Plan’ should This document will be developed over the next few months and there is no 003.03 be prepared, at least in draft, intention to submit to it as part of our DCO application. There are details of as part of the DCO application; and the proposed construction phases in the submitted Environmental Statement. OD Highways England should fully consider cumulative traffic Using the preliminary construction programme, the main construction 003.04 effects during the construction phases were modelled at a high level to feed into the economic case for the programme. Scheme. However, the operational implications of construction cannot be assessed in greater detail until Highways England and the appointed contractor consider this at the Detailed Design stage when Construction Logistics Plans will be developed.

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