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21/00924/EIA North West Road – Comments from Better Shrewsbury Transport (Best)

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21/00924/EIA North West Road – Comments from Better Shrewsbury Transport (Best) 21/00924/EIA North West Road – Comments from Better Shrewsbury Transport (BeST) 1 Introduction and Summary This document sets out Part I of the response of BeST (Better Shrewsbury Transport) to the above planning application registered by Shropshire Council (the Applicant) and validated on 1 March 2021. We will set out in a separate document the many ways in which the application is inconsistent with national legislation and guidance and with Shropshire Council’s own strategies and policies. BeST comprises a group of organisations1 and individuals that is keen to engage positively with Shropshire Council to promote active and sustainable solutions to the town’s transport challenges. We are campaigning for urgent action to promote active and sustainable modes of transport which are the only effective ways to reduce CO2 emissions from transport and to permanently reduce traffic congestion, poor air quality and road deaths/injuries in the town. These measures will also transform all our lives for the better. We are objecting to the planning application on the following grounds (hyperlinks have been used in this introductory section to allow the reviewer convenient access to the relevant part of document with more detail on each objection): Objection 3.1 – On the Grounds of the Ineffectiveness of the NWR in Reducing Traffic in Shrewsbury Objection 3.2 – Failure to consider alternatives to building a new road. Objection 3.3 – Design of new cycle infrastructure fails to meet standards to which Shropshire Council has committed. Objection 3.4 - Lack of Sensitivity analysis on benefits and impacts of recent design choices Objection 4.1 – on Grounds of Climate Change and Carbon Emissions Objection 5.1 – Landscape impacts of the scheme have been significantly understated Objection 5.2 – Visual impacts of the scheme have been significantly understated Objection 5.3 – Impacts on the tranquillity of Shrewsbury’s Green Wedge have not been properly assessed and are significant Objection 5.4 – Impacts on light pollution have not been properly assessed Objection 6.1 – Failure to adequately survey and assess the ecological implications of the proposed scheme Objection 6.2 – Biodiversity Loss Objection 6.3 – Failure to achieve Biodiversity Net Gain (BNG) Objection 6.4 – Fragmentation of ecological networks Objection 6.5 – Impact on internationally designated site Objection 6.6 – The proposed development conflicts with Shropshire local plan 1 BeST comprises Shropshire Wildlife Trust, Council for the Protection of Rural England, Friends of the Earth Shrewsbury Branch, The Green Party, Shrewsbury and Atcham Liberal Democrats, Extinction Rebellion Shrewsbury Branch, Sustainable Transport Shropshire Page 1 FINAL 27 April 2021 Objection 7.1 – Impact on Severn Trent Water’s Shelton Public Water Supply Source Protection Zone (SPZ) Objection 7.2 – Inadequacy of the Geological Assessment Objection 7.3 – Inadequate assessment of the potential impact on Hencott Pool Objection 7.4 – Inadequate Treatment of shallow groundwater Objection 8.1 – Unreliable noise modelling Objection 8.2 – The proposal conflicts with Shropshire Council’s adopted Masterplan for the Western Urban Extension Objection 8.3 – The proposal conflicts with the Adopted Core Strategy Objection 8.4 – The proposal conflicts with National Guidance on noise Objection 8.5 – The noise assessment has not considered the and are significant impact of the road on Tranquillity and in particular “The Green Wedge” Objection 9.1 – Air quality impacts on the Midland Meres and Mosses (Phase 1 and 2) Ramsar site at Hencott Pool Site of Specific Scientific Interest (SSSI) Objection 9.2 – The air quality modelling demonstrates that the NWR will not bring air quality in the Air Quality Management Area (AQMA No. 3) below legal limits Objection 9.3 – The Applicant has not fully considered the effect of the scheme on particulate matter concentrations Objection 10.1 – No consultation on the Viaduct Design Objection 10.2 – ‘Consultation questions’ designed to elicit the Applicant’s preferred answer Objection 10.3 – Question 12 from 2020 ‘consultation’ and lack of opportunity to express opposition or support Objection 10.4 – Misleading conclusions to the SCI We provide evidence to support each of these objections, organised by theme, in the main body of this response (see Table of Contents below). These include discussion of relevant legislation, guidance and policies where appropriate. As mentioned above, we will provide a structured cross reference to relevant legislation, guidance and policies in a separate document. In summary we object to this proposal on the grounds that it does not represent ‘sustainable development’ as set out in paragraph 8 of the National Planning Policy Framework: • It places an unsustainable burden on future generations in terms of increased dependence on private car use (Objection 3.2) and increased greenhouse gas emissions (Objection 4.1) leading to increased threats from climate change. In addition, some of the proposed mitigation measures (e.g. related to the protection of Shrewsbury’s water supply) will require complex and expensive management in perpetuity (Objection 7.1). There are significant cost risks with the proposed development (Objection 7.2) and Shropshire Council’s future financial stability is threatened by this exposure. • We have provided a detailed critique of the claimed rationale for the scheme in Section 3. The economic argument for the road is weak and grossly overstated whilst significant impacts have not been included in the benefit:cost ratio (for instance loss of natural capital and health impacts). The traffic modelling (albeit Page 2 FINAL 27 April 2021 flawed – See Objection 3.1 and Appendix 2) demonstrates that the road does not meet its core objective of removing congestion from the town centre whilst it does demonstrate that traffic will be significantly worse in several areas (see Sections 3.3.3 and 3.3.4). • The social impact of the road will be to destroy the tranquillity of Shrewsbury’s unique Green Wedge, a vital piece of green infrastructure at the heart of the town (Objections 5.3 and 8.5). The landscape, visual and noise impacts of the road on this aspect of the town have been significantly understated in the environmental statement (Objections 5.1, 5.2, 8.1 and 8.5). The measures that have been included to promote sustainable transport are poorly designed and do not meet the design standards that Shropshire Council has committed to (Objection 3.3). In addition, it represents a long term threat to the town’s water supply – a risk that has not been adequately addressed in this application (Objection 7.1). • The environmental impact of the road on the biodiversity of the area is significant both in terms of direct impacts and through fragmentation of habitats (Objections 6.2, 6.3). In particular, the impacts of the road on Hencott Pool (part of the Midlands Meres and Mosses RAMSAR site) (Objection 6.5) through impacts on air quality (Objection 9.1) and the water environment (Objection 7.3) have not been addressed to the level required for a site of international status. The applicant has failed to make any significant effort to investigate the potential for cheaper, more sustainable and less damaging alternatives (for instance as recently demonstrated in Hereford’s recent transport strategy) (Objection 3.2). The application is clearly rushed, with many of the required surveys incomplete (Objections 6.1 and 7.2) and many key documents at draft stage meaning that it is not possible to properly assess the impacts of the proposed development. Meanwhile, the implications of late design changes for impacts and achievement of scheme objectives have not been fully explored and presented (Objections 3.4). 2 Table of Contents 1 Introduction and Summary ....................................................................................................................................... 1 2 Table of Contents ...................................................................................................................................................... 3 3 Rationale for scheme ................................................................................................................................................ 8 3.1 Objectives .......................................................................................................................................................... 8 3.2 Legislative context .......................................................................................................................................... 11 3.3 Transport Assessment ..................................................................................................................................... 11 3.3.1 Objections ............................................................................................................................................... 12 3.3.2 Objection 3.1 On the Grounds of the Ineffectiveness of the NWR in Reducing Traffic in Shrewsbury .. 13 3.3.3 Traffic Figures .......................................................................................................................................... 13 3.3.4 Journey Times ......................................................................................................................................... 24 3.3.5 Omissions and Errors .............................................................................................................................
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