SOUTH BUCKS DISTRICT COUNCIL AND BUCKINGHAMSHIRE COUNTY COUNCIL
LOCAL IMPACT REPORT
HIGHWAYS ENGLAND'S RESPONSE
1. INTRODUCTION
1.1 The Local Impact Report (LIR) should be used by Local Authorities as the means by which their existing body of local knowledge and evidence on local issues can be fully and robustly reported to the Examining Authority. It should draw on existing local knowledge and experience. Examples might be local evidence of flooding, local social or economic issues or local knowledge of travel patterns to community facilities.
1.2 This report has been prepared by South Bucks District Council (SBDC) and Buckinghamshire County Council (BCC) for the South Bucks District, one of the planning areas affected by the scheme, in accordance with advice and requirements as set out in the Planning Act 2008, the Localism Act 2011 and Advice Note one: Local Impact Reports (version 2, April 2012, The Planning Inspectorate).
1.3 The Advice Note states that a Local Impact Report is a ‘report in writing giving details of the likely impact of the proposed development on the authority’s area’.
1.4 The Advice Note states that when the Examining Authority decides to accept an application it will ask the relevant local authorities to prepare a Local Impact Report and this should be prioritised whether or not the Local Authority considers that the development would have a positive, negative or neutral effect on the area. The Report may include any topics that they consider to be relevant to the impact of the development on their area as a means by which their existing body of knowledge and evidence on local issues can be fully and robustly reported to the Examining Authority.
1.5 The Advice Note indicates that topics addressed in the LIR may include:
- Site description and surroundings/location
- Details of the proposal
- Relevant planning history and any issues arising
- Relevant development plan policies, supplementary planning guidance or documents, development briefs or approved master plans and an appraisal of their relationship and relevance to the proposals
- Relevant development proposals under consideration or granted permission but not commenced or completed
- Local area characteristics such as urban and landscape qualities and nature conservation sites
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- Local transport patterns and issues
- Designated sites
- Socio-economic and community matters
- Consideration of the impact of the proposed provisions and requirements within the draft Order in respect of all of the above
- Development consent obligations and their impact on the local authority’s area
1.6 The LIR may also comments on the development consent obligations and the requirements and also any relevant representations.
1.7 The LIR has been written so as to incorporate the subject areas suggested in the Advice Note (set out above), the subject areas in the Environmental Statement, and the obligations and proposed requirements submitted with the application for DCO.
2. SITE DESCRIPTION, SURROUNDINGS AND HISTORY
Site Description and Surroundings / Location
2.1 The M4 runs through two sections of South Bucks District, firstly bisecting Burnham and Dorney to the West of Slough and secondly forming the Southern border of the District at Iver to the East of Slough. Figure 1 shows the relevant study area including the currently proposed alignment for the scheme.
Details of the proposal
2.2 Highways England (HE) intends to improve the M4 by making it a ‘Smart Motorway’ between junctions 3 (Hayes) and 12 (Theale). The scheme forms part of the National Infrastructure Plan.
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2.3 The M4 is a major strategic route and the infrastructure enhancements aim to support economic success and decrease congestion along major arteries linking the Thames Valley, the West of England and Wales to Heathrow and London.
2.4 The scheme requires the improvement of a 32 mile stretch of the M4 motorway using the latest technology to improve journeys by monitoring traffic flows and converting the hard shoulder to a traffic lane to meet the requirement for extra capacity. The scheme is proposed to require a minimal amount of additional land take and requires the widening or replacement of a number of bridges where there is currently no hard shoulder.
2.5 The sections of the proposal that directly impact the South Bucks District are between Junctions 8/9 – 7 and Junctions 5 – 4b. Within these sections there are 4 bridges affected:
- Thames Bray Bridge will be widened to the north
- Lake End Road will be rebuilt off-line
- Marsh Lane bridge will be built on-line
- Old Slade Lane bridge will be rebuilt on-line
2.6 As well as bridge replacements the tarmac will be replaced with low-noise tarmac to be implemented along the whole scheme and potentially additional noise barriers constructed.
3. RELEVANT DEVELOPMENT PLAN POLICIES AND ISSUES ARISING
National
3.1 This scheme is a Nationally Significant Infrastructure Project (NSIP) for the purposes of Sections 14(1) (h) and 22 of the Planning Act 2008. The National Planning Policy Framework came into effect on 27 March 2012 however this Framework does not contain specific policies for nationally significant infrastructure projects. The NPPF must be taken into account in the preparation of local and neighbourhood plans, and is a material consideration in planning decisions. Of note paragraph 123 states that ‘’decisions should aim to avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development”. The National Networks National Policy Statement was adopted in December 2014 and sets out the need and government policies for NSIPs.
Highways England's Comment
3.1.1 Whilst it is correct that the NPPF does not contain specific policies in relation to Nationally Significant Infrastructure Project ("NSIPs"), the NPPF can be a relevant consideration in the Secretary of State's decision on whether to grant development consent pursuant to s.104(2)(d) of the Planning Act 2008.
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Local
3.2 The adopted South Bucks Local Plan was published in 1999 and the Core Strategy in 2011. These both set out the current and saved policies relevant to the district.
3.3 In line with paragraph 216 of the National Planning Policy Framework weight should be given to emerging documents. SBDC is currently in the process of preparing a new South Bucks Local Plan. The new Local Plan will replace saved policies in the existing Local Plan and Core Strategy. This is expected to be adopted in 2018 and as a consequence there is ongoing additional evidence bases being generated.
South Bucks Local Plan 1999
3.4 The following saved policies are relevant:
- GB1 Green Belt. The land is included within the Green Belt. Within the Green Belt approval will not be given, except in very special circumstances, for the construction of new buildings
- GB3 Green Belt Settlements. Within GB3 settlements the one for one replacement of existing dwellings and limited infilling within the boundaries will be considered.
- L4 River Thames Setting. The Council will seek to conserve and enhance the setting of the River Thames as defined on the proposals map and will not permit development which would have an adverse impact on the special character, landscape or amenity of the River Thames.
- L10 Felling trees protected by a TPO. In the case of any tree for which felling consent is granted, the Council will normally impose a condition requiring replacement planting to be carried out.
- C1 Development within a conservation area. Development within a conservation area that fails to preserve or enhance its character will not be permitted except for very special circumstances.
- EP4 Landscaping. Development proposals will be expected to where appropriate provide for the planting of appropriate additional trees and shrubs including native species.
- TR5 Accesses, Highway works and traffic generation. The Council will have regard to their effect on safety, congestion and the environment.
- TR10 HGVs. Movements should not adversely affect the character on nearby properties nor use an access involving a residential road, rural lane or other road which is not suitable for such traffic.
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- TR12 West Drayton to Poyle Railway. Development that prejudices the potential use of the railway will not be permitted.
Highways England's Comment
3.4.1 The currently applicable planning policy for the Council outlined above is noted as were the planning policies against which the Application was assessed in the Planning Statement (Application Document Reference . 7-1). Whilst Highways England notes the reference to the emerging Local Plan, the publication of the draft plan is not expected until early 2017. As such, in view of the preliminary stage in the plan’s preparation, it is not considered material to this Application.
3.4.2 A response to each of the Plan policies referred to within the Adopted South Bucks Local Plan is provided below:
- GB1 Green Belt: The Scheme's compliance against this policy is assessed within the Planning Statement (Application Document Reference 7-1) in Table 7 (Appendix 1) and summarised at paragraph 5.4.33.
- GB3 Green Belt Settlements: Policy GB3 refers to the residential infilling in green belt settlements and is not considered relevant to the proposed development.
- L4 River Thames Setting: The Scheme's compliance against this policy is assessed within the Planning Statement (Application Document Reference 7-1) in Table 7 (Appendix 1).
- L10 Felling trees protected by a TPO: It is acknowledged that Policy L10 provides more specific policy guidance in relation to protected trees than Policy EP4 below on Landscaping. The Environmental Statement (Application Document Reference 6-1) notes that some trees protected by a TPO within the District may need to be removed as a result of the Scheme’s construction (Paragraph 8.8.14 refers). Consent for the felling of trees subject to a TPO is provided in Article 40 of the Draft DCO and the full list of trees subject to TPOs to be felled is provided in Schedule 8 of the Draft DCO (Application Document Reference 3-1). In the event that protected trees are affected by the Scheme, measures will be adopted to agree with the Council replacement planting of, and/or work to, any affected trees. These provisions are therefore considered to be in compliance with the requirements of Policy L10.
- C1 Development within a conservation area: Policy C1 prohibits development within a conservation area that fails to preserve or enhance its character. There are no conservation areas within the Council's area within which development will take place. The Scheme complies with Policy C1 as the development that is proposed does not fail to
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preserve or enhance the character of any conservation areas, as explained in detail below at paragraph 3.8.
- EP4 Landscaping: The Scheme's compliance against this policy is assessed within the Planning Statement (Application Document Reference 7-1) in Table 7 at Appendix 1.
- TR5 Accesses: Highway works and traffic generation: The Scheme's compliance against this policy is assessed within the Planning Statement (Application Document Reference 7-1) in Table 7 at Appendix 1.
- TR10 HGVs. Policy TR10 provides that development which would generate heavy goods vehicle trips will only be permitted in certain circumstances. The Scheme itself will not generate significant additional heavy goods vehicle trips than those predicted without the Scheme. Policy TR10 provides one of the permitted circumstances is where the proposal would comply with all other policies in the Local Plan, in particular Policy TR5. Such compliance is addressed both above and below.
- TR12 West Drayton to Poyle Railway: Policy TR12 provides that development will not be permitted where it would prejudice the potential use of the West Drayton to Poyle Railway Line. The Scheme will not prejudice the potential use of the West Drayton to Poyle Railway Line.
South Bucks Core Strategy 2011
3.5 The following saved policies are relevant:
- CP6 Local Infrastructure Needs. Existing physical, social and Green Infrastructure will be protected (unless clear that it is no longer needed or appropriate provision elsewhere is provided).
- CP7 Accessibility and Transport. The Council seeks improved accessibility to services and a safer and more sustainable transport network.
- CP8 Built and Historic Environment. The protection and enhancement is of paramount importance.
- CP9 Natural Environment. Priority given to the conservation and enhancement of the Chilterns AONB, Colne Valley Park and Burnham Beeches.
- CP13 Environmental and Resource Management. Ensure the sustainable management of the District’s environmental resources including incorporating SUDs in development, protecting and enhancing water quality and seeking improvements in air quality.
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Highways England's Comment
3.5.1 A response to each of the Plan policies referred to within the emerging South Bucks Core Strategy is provided below:
- CP6 Local Infrastructure Needs: Core Policy 6 is concerned with protecting existing local infrastructure and facilitating the provision of additional infrastructure for new developments required to support the Core Plan. Infrastructure is defined broadly to cover physical (roads, cycleways, sewer and other utilities), social (education, health, cultural facilities and emergency services), and green (linked networks of green spaces such as woodland, parks, waterways, rights of way networks and open countryside) infrastructure. The cross-reference to the Infrastructure Schedule in Appendix 6 to the Core Plan relates to local infrastructure requirements identified by South Bucks DC to support the Core Plan and excludes reference to the M4 smart motorway Scheme. The development of the Scheme design has taken account of local infrastructure adjoining the highway boundary. The potential impacts of the Scheme on physical and social infrastructure are covered in Chapter 14 of the ES and green infrastructure is covered in Chapter 9 of the ES (Application Document Reference 6-1). The mitigation of construction-related effects are described in the Outline Construction Environmental Management Plan in Appendix 4.2A to the ES (Application Document Reference 6-3), which is secured under Schedule 2, Requirement 8 of the Draft DCO (Application Document Reference 3-1).
- CP7 Accessibility and Transport:
- The policy reflects the Council’s aim to seek to improve accessibility to services and ensure a safe and sustainable transport network. The Scheme will provide improved accessibility through the provision of additional capacity and improved reliability. As part of a wider transport strategy the Scheme will be complementary to the Council’s policy by removing traffic from less suitable roads, thus providing an increased opportunity for the Council to rebalance the local transport system. The Council’s concerns expressed in the supporting text to the policy over traffic issues on the A355 around Beaconsfield and through Iver are noted, as these are pertinent issues to SBDC and BCC in the context of the construction and operation of the Scheme. These issues are considered and addressed separately within the report, together with Highways England’s responses.
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- CP8 Built and Historic Environment: The Scheme's compliance against this policy is assessed within the Planning Statement (Application Document Reference 7-1) in Table 7 at Appendix 1 and summarised in paragraph 5.4.29.
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- CP9 Natural Environment: The Scheme's compliance against this policy is assessed within the Planning Statement (Application Document Reference 7-1) at Appendix 1 and summarised in paragraph 5.4.29.
- CP13 Environmental and Resource Management: Core Policy 13 states that the Council will seek to ensure the prudent and sustainable management of the District’s environmental resources by reference to policy criteria, including the following of relevance to the proposed development:
‘Seeking improvements in air quality, especially in the Air Quality Management Area adjacent to the motorways and close to Burnham Beeches SAC.’
3.5.2 The planning assessment undertaken within the Planning Statement (Application Document Reference 7-1) of the South Buckinghamshire District Council Transport Strategy (2010) notes that the guidance seeks, ‘to improve local air quality, especially in Air Quality Management Areas:’’
3.5.3 In response the assessment comments that:
"Chapter 6 Air Quality of the ES assesses the potential air quality impacts of the Scheme,
based on ambient concentrations of key road traffic pollutants - NO2 and PM10 during the construction and operation phases. The assessment notes the location of the South Bucks
AQMA along this section of the M4 and advises that concentrations of NO2 are predicted to be above the annual average objective value in 2022 without the Scheme. The assessment undertaken identifies a single area south of the M4 at Oak Stubbs Lane which
exceeds the objective value for NO2 as a result of the Scheme."
3.5.4 With specific regard to air quality, CP13, referenced above, states that “The Council will seek to ensure the prudent and sustainable management of the District’s environmental resources by:… Seeking improvements in air quality, especially in the Air Quality Management area adjacent to the motorways…”.
3.5.5 Negligible improvements in annual mean concentrations of nitrogen dioxide (“NO2”) are predicted due to the Scheme at sensitive receptors located within the Air Quality Management Area (“AQMA”) along the M40 (paragraph 6.14.27 of the ES (Application Document Reference 6-1). However, some negligible to medium worsenings are predicted at sensitive receptors located within the AQMA adjacent to the M4.
3.5.6 Whilst the above air quality effects are not considered to be significant, as outlined in paragraph 6.15.16 and Tables 6.21 and 6.22 of the ES (Application Document Reference 6.1), Highways England has agreed to consider a trial using innovative air quality mitigation solutions (e.g. planting). This is documented within the Statement of Common
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Ground agreed between Highways England and South Bucks District Council in paragraph 3.29.
Bucks County Council Minerals and Waste Local Plan 2004-2016 ‘Saved’ policies and Minerals and Waste Core Strategy
3.6 There are two sets of adopted policies with respect to minerals extraction and waste management in Buckinghamshire. The majority of the policies in the Buckinghamshire Minerals and Waste Local Plan 2004-2016 (BMWLP) were ‘Saved’ by Direction by the Secretary of State in 2009. The Buckinghamshire Minerals and Waste Core Strategy (MWCS) adopted in 2012 replaced some of these Saved policies, but not all of them. Policies that may be relevant to this proposed scheme includes:
- Policy 5 on Borrow pits, since temporary mineral workings may be sought by contractors employed on the scheme to supply aggregate minerals. If this happens then policies 28 (Amenity), 29 (Buffer Zones), 34 (Aviation Safeguarding Areas), CS18 (Protection of Environmental Assets of National Importance), CS19 (Protection of Environmental Assets of Local Importance), CS20 (Green Belt), CS22 (Design and Climate Change), and CS23 (Enhancement of the Environment), may apply.
- MWCS policy CS8 Waste Prevention in New Development. This policy seeks to minimise the production of wastes and encourage reuse and recycling, and promotes separation, recycling and storage of waste generated on site.
- MWCS policy CS9 states the levels of provision that will be made for waste management capacity to 2026. (See comment below).
- MWCS policy CS10 Recycling and composting capacity to be provided for MSW and C & I waste by 2026. This is to be implemented by the development of a new local plan called the ‘Replacement Minerals and Waste Local Plan’.
- MWCS policy CS15: Landfill. This policy states that no additional capacity will be provided for non-hazardous and inert materials. However new mineral workings are expected to be restored using inert waste materials. However construction demolition and excavation wastes arising from the redevelopment of previously developed land has been in short supply in recent years, as well as being increasingly recycled to produce recycled aggregates.
Highways England's Comment
3.6.1 The planning assessment undertaken within the Planning Statement (Application Document Reference 7-1) has not considered minerals extraction and waste management issues and therefore no reference is made to Buckinghamshire County Council’s waste and mineral plans.
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3.6.2 A full and detailed assessment of the potential impacts resulting from the use of material resources and waste management in the construction, demolition and excavation phases of the M4 smart Motorway Scheme is provided in Chapter 11 of the Environmental Statement (Application Document Reference 6-1). The Bucks County Council Minerals and Waste Local Plan 2004-2016 ‘Saved’ policies and Minerals and Waste Core Strategy is addressed in Appendix 11.3 to the Environmental Statement, demonstrating that it has been taken account of in the environmental impact assessment for the Scheme.
Policy Summary
3.7 The proposal affects land currently located in the designated Green Belt however paragraph 90 of the NPPF states that local transport infrastructure which can demonstrate a need for a Green Belt location is not inappropriate. However this does not apply for NSIPs. The National Policy Statement for National Networks (NPSNN) was written to clarify the NSIP process. Paragraph 5.178 identifies that should the proposal comprise inappropriate development in the Green Belt; this should be given substantial weight when considering the application and require very special circumstances to justify it.
3.8 HE identify that the majority of work will take place within the existing boundaries of the M4. However the plans do involve the clearance and use of Green Belt land and protected trees. Additionally there is a likely impact on the local Huntercombe Conservation Area. All the land in the Dorney area and the majority of land in the Iver area is included in Flood Risk Zone 2 and Zone 3. It is essential that the impact is kept to a minimum and that there are adequate mitigation measures, wherever practicable.
Highways England's Comment
3.8.1 The Council’s reference to the M4 smart motorway Scheme as not comprising local transport infrastructure (within the context of the NPPF) is addressed in paragraphs 5.2.163 and 5.2.164 of the Planning Statement (Application Document Reference 7-1). The relevance of Paragraph 5.178 of the NPPF is also noted within the Planning Statement (paragraph 5.2.159) as are the special circumstances in the consideration of the proposed development in paragraphs 5.2.163 – 5.2.159.
3.8.2 A detailed assessment of the impacts of the Scheme within the District is provided within the Planning Statement (Application Document Reference 7-1). Table 1 (Appendix 1) demonstrates the Scheme’s compliance in relation to the key policy provisions within both the Adopted Local Plan 1999 (Saved Policies 2007) and Adopted Core Strategy (Adopted 2011). Policy GB1 of the Adopted Local Plan assesses the Scheme’s compliance regarding development within the Green Belt, Policy L4 in relation to the setting of the River Thames, and Policy EP4 on landscaping, with reference to the mitigation measures in place through the environmental masterplan. Core Policy 8 of the
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Core Strategy considers the Scheme’s compatibility in relation to the protection and enhancement of the built and natural environment and Core Policy 9 in relation to the conservation and enhancement of the natural environment.
3.8.3 An assessment of the impacts of the M4 smart motorway Scheme in relation to protected trees, heritage assets and flood risk, along with appropriate mitigation measures have been fully considered within the Environmental Statement (Application Document Reference 6-1).
Relevant development proposals under consideration or granted permission but not commenced or completed
3.9 Wyeth Pharmaceuticals, Huntercombe Lane South, Burnham, SL6 0PH
Permission has been granted for the redevelopment of the above site to provide a replacement office building (application reference 15/00803/FUL). The eastern boundary of the site adjoins the Huntercombe Spur road.
Highways England's Comment
3.9.1 The details provided in relation to the above development within the context of the M4 smart Motorway Scheme are noted. However, this scheme has not formed part of the assessment undertaken of committed developments identified within Chapter 4 of the Planning Statement (Application Document Reference 7-1) and Appendix 16.1 of the ES (Application Document Reference 6-3), as the assessment was based on committed development identified by December 2014, prior to submission of the DCO Application in March 2015. The Wyeth Pharmaceuticals planning application was submitted to the Council on 1 May 2015 and consented on 23 July 2015. Highways England considers that the onus was on the promoter of Wyeth Pharmaceuticals and South Bucks District Council to consider whether the application would be affected by the M4 smart motorway Scheme.
4. HIGHWAY JUSTIFICATION / TRAFFIC IMPACT ON LOCAL ROADS
Introduction
4.1 SBDC and BCC have actively engaged with Highways England on the options for ensuring the construction process is not detrimental to the District. SBDC and BCC are generally supportive of the scheme as it improves a strategic motorway into London and provides the potential to decrease local traffic within South Bucks due to the increased capacity of the M4. However SBDC and BCC do have concerns over the impact on the local road network during construction that the proposal will create, and which is identified later in this section.
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4.2 HE has built a Variable Demand Model (M3M4DM) and a Highway Assignment Model (M3M4HAM) to assess the impacts of smart motorway operations on both the M3 and M4. The models have been calibrated and validated in accordance with TAG guidance.
4.2.1 Highways England welcomes the expression of support from SBDC and BCC. Responses to the concerns of the two Councils over the impact on the local road network are provided below against the respective detailed comments.
4.3 Average daily traffic flows taken from HE’s traffic counting system along the M4 between J8 and 7 indicate this section to carry approximately 124,200 vehicles per day, 9% of which are HGVs. It is anticipated that this stretch of road will be at 100% capacity for the London Commute in the am peak by 2037 in the ‘do nothing’ scenario.
4.4 Average daily traffic flows taken from HE’s traffic counting system along the M4 between J5 and 4b indicate this section to carry approximately 145,700 vehicles per day, 9% of which are HGVs. It is anticipated that this stretch of road will reach 76% capacity for the London Commute in the am peak by 2037 in the ‘do nothing’ scenario.
Highways England's Comment
4.4.1 Highways England agrees with the summary of conditions between junctions 8 and 7 and junctions 5 and 4b that will exist if the Scheme is not implemented. Table 2 in the Engineering and Design Report (Application Document Reference 7-3) provides the volume to capacity ratios without the Scheme.
4.5 BCC does however have concerns over the negative impact on the A4 with predicted increases in traffic flows and journey times between Langley and Chiswick, as a result of the implementation of the scheme. BCC are of the view that further information is required to understand the implications of the scheme on the future operation of the A4.
Highways England's Comment
4.5.1 The impact of the Scheme on the A4 in relation to journey times is considered and the journey time comparisons in the do-minimum and do-something scenarios are detailed in Tables A-26 to A-29 of the Traffic Forecasting Report, which was provided at Appendix 1 to the Response to Relevant Representations at Deadline I. It is correct that the results shown in those tables demonstrate that journey times on the A4 increase between Langley and Chiswick by up to 3%. However, this figure is only applicable to the section between Chiswick and Hounslow in the pm peak in 2037 and arises from an additional 37 vehicles assigned to this link under the Do-something scenario during that hour in that year. A more representative summary based on the modelled results for all time periods would be that journey time changes on the section of the A4 between Langley and Chiswick change
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by between a reduction of 2% (between Hounslow and Langley in the pm peak period in 2037 due to a reduction of 29 vehicles in that hour) and the 3% increase quoted above.
4.6 Most of the work will be carried out within the existing M4 corridor. However there is additional land take in the South Bucks District (identified later) and as part of the construction process the contractors are anticipated to use a number of sites for operational processes. There are 2 identified that are likely to have an impact on the South Bucks District:
- Compound 6 (within Junction 7) – the plan is to use the spare land located within the middle of the junction. This should therefore mean little impact on the district.
- Compound 9 (Colnbrook Landfill Site, Sutton Lane) – this is located out of the district to the south of Junction 5. With its good access links via the A4 there should be no need for additional travel along Sutton Lane linked to the scheme. A routing agreement is therefore required to ensure this does not happen.
Highways England's Comment
4.6.1 Highways England notes that South Bucks District Council ("SBDC") is of the view that there will be little impact as a result of the use of Construction Compound 6.
4.6.2 In relation to the routing of construction traffic from Construction Compound 9, the detailed routes to be used by construction traffic will be addressed in the Outline Construction Traffic Management Plan (Annex E of Appendix 4.2A of the ES. ‘Outline Construction Environmental Management Plan’) (Application Document Reference 6.3). This document will be adopted, developed, and implemented in consultation with the highway authorities, including Buckinghamshire County Council ("BCC") as the highway authority. It will address (among other matters) details of access/egress to construction sites and compounds in the County, including construction compound 9, and construction traffic routes. The preparation and implementation of the Construction Environmental Management Plan, including approval by the relevant authority, is secured under Schedule 2, Requirement 8 of the Draft DCO (Application Document Reference 3.1.
4.7 A major concern for SBDC and BCC is the closure of roads during the construction period, namely Old Slade Lane and Marsh Bridge Road. The outline Construction Traffic Management Plan has been of little information to date regarding construction routes, in particular to local bridge sites. More information is required to ensure that routes are not chosen that will lead to unacceptable levels of HGV traffic. In particular it is advised that traffic to Old Slade Lane should be via the South (along Lakeside Road) due to the unacceptably high volumes of HGVs already experienced in the Richings Park and Iver areas to the North. This is an aspect that has been monitored yearly as part of the SBDC Annual Monitoring Report.
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Highways England's Comment
4.7.1 As noted at paragraph 4.6.2 above, further detail for the CTMP will be developed in consultation with South Bucks District Council and Buckinghamshire County Council in accordance with Schedule 2, Requirement 8 of the Draft DCO (Application Document Reference 3-1). This will include the routes for construction traffic to sites where bridge works are taking place, and routeing for HGVs. Highways England notes the comments made in relation to Old Slade Lane, which South Bucks District Council will be able to feed into the development of the CTMP via the consultation on the development of the CTMP referred to above.
4.8 It is requested that mitigation packages are developed for each of the local schemes. The impact of severance in closing Old Slade Bridge over 12 months is considered to be highly severe however HE have proposed a diversion route that adds a further 4miles (figure 2).
Highways England's Comment
4.8.1 Highways England acknowledges that a round trip route from one side of the Old Slade Lane bridge to the opposite side travelling via the nearest overbridge at Sutton Lane would involve a diversion totalling some 4 miles in length. As stated in paragraph 13.7.21 of the Environmental Statement (Application Document Reference 6-1) and based on the criteria set out in paragraph 13.7.15 of that document, the severance incurred during the period of reconstruction would be adjudged as severe.
4.8.2 The Old Slade Lane overbridge carries an accommodation track over the M4 to provide access for farm use, local pedestrians and cyclists as part of the Colne Valley Trail. Accordingly, Highways England recognises that there are a number of interested parties with differing needs to be taken into consideration.
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4.8.3 Paragraph 13.7.1 of the Outline Construction Environmental Management Plan (Appendix 4.2A to the ES (Application Document Reference 6-3)), confirms that the Contractor will consult with relevant local authorities and paragraph 13.7.2 states that “Where separate routes used by pedestrians and other NMUs are affected, the Contractor will provide alternative routes within the traffic management Scheme being implemented. Once agreed, the specific right of way affected will need to be scheduled with appropriate nomenclature and diversion routes suitably signposted throughout the works. Diversion works will require to be confirmed in consultation with the relevant local authority and consent applied for under s257 of the Town and Country Planning Act 1990.”
4.8.4 Accordingly, and as stated above, Highways England will fully engage with the Councils and other interested parties on the development of a suitable diversion route during the period of reconstruction of the Old Slade Lane bridge.
Local Roads
4.9 Chapter 13 of the ES “Effects on all Travellers” includes an indicative assessment of the impact of construction on the M4. 2018 was selected as this is likely to be the time when traffic management has been introduced to substantial portions of the M4 to support the construction works. The results show a reduction in average peak hour flow per lane both in the eastbound and westbound directions between junctions 8/9 – 4b. The ES predicted an adverse effect on driver stress as a result.
Highways England's Comment
4.9.1 Tables 13.12 to 13.17 in chapter 13 of the ES (Application Document Reference 6-1) set out the predicted levels of driver stress for the M4 in 2018 without the Scheme and with the Scheme partially constructed. Paragraph 13.7.5 provides a summary for the results of the driver stress assessment on the Scheme extents, noting that only 3 out 9 links eastbound and 4 out of 9 links westbound showed changes in assessed levels of driver stress and from which it was concluded the adverse impact is assessed as minor.
4.10 SBDC and BCC have concerns over the impact on the local road network during construction that the proposal will create. BCC are of the view that the scheme will place additional pressure on local roads within the region during the construction period. Traffic displacement as a result of construction works on the M4 is especially of concern along the A4 and A355, which has not been properly considered in the ES.
Highways England's Comment
4.10.1 The effects of the proposed traffic management regime and phasing of the works during the construction of the Scheme on road users is described in paragraphs 8.3.1 to 8.3.6 of the EDR. To assess the possible effect of the construction traffic management on users of
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the M4, the Highways England bespoke software program QUADRO (QUeues And Delays at ROadworks) was run. Analysis of the delays predicted by the program shows that the delays arising from the additional time to travel through the works during the first phase of works reached a maximum predicted journey time extension of 10 minutes in each of the Monday – Thursday peak periods. Only during the Friday PM peak in the westbound direction do journey extensions exceed 10 minutes and queues occur.
4.10.2 During phase 2 of the works, the capacity of three narrow lanes is exceeded during peak periods between junctions 3 and 4 and between junctions 5 and 6. The initial effect as capacity is reached is that vehicles will start to queue but there is the risk that diversion to other routes may occur. Should all vehicles above the capacity limit choose to divert, the potential level of diversion as assessed by QUADRO is limited in number, totalling 106 vehicles per day, two-way Monday to Thursday between junctions 3 and 4 and a total of 296 vehicles per day, two-way Monday to Thursday between junctions 5 and 6.
4.10.3 The assessment that a limited amount of traffic diversion will occur during the construction of the Scheme is also reinforced by a comparison of traffic flow data captured during roadworks on the M4 in 2014. Two sets of works were undertaken – resurfacing between junctions 8/9 and 10 and bridge works between junctions 10 and 11, each using 3 narrow lanes of traffic management. Comparisons were made between traffic flows over the period May to September during which the works were carried out and the same period the previous year using data from Highways England’s Traffic Flow Data System (“TRADS”). The comparisons showed that flows in 2014 were marginally lower than the preceding year only during the peak periods. During the remainder of the day outside the peaks, flows in 2014 were typically 2-3% higher than 2013. This suggested that if diversion was occurring, it was limited to the peak periods.
4.10.4 On the basis of the above, Highways England maintains that proper consideration has been given to the issue of traffic displacement as a result of construction works. Responses to the specific concerns raised by the Councils on the impacts on the A4 and A355 are provided following the points raised below.
4.11 Bath Road (A4) runs parallel to the M4 through the District. It is currently a highly used A-road servicing Slough and Maidenhead. BCC has capacity and safety concerns relating to additional traffic volume as a consequence to the construction phase of the scheme.
4.12 The A355 runs north from Slough to Beaconsfield. In recent years it has been used as a ‘rat-run’ for motorway traffic when either the M40 or M4 are blocked. This is combined with it being increasingly used by HGV traffic. This is a use that is unsuitable for this road and could have potentially significant ramifications for the near-by Burnham Beeches SAC (figure 3).
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Highways England's Comment
4.12.1 Having concluded that construction-related diversion was most likely during peak periods, the M3/M4 traffic model was run to simulate the effects of traffic management during the am and pm peak periods. Figures X and Y attached to this response illustrate the road links where diversion exceeds the environmental assessment threshold of a total of 1000 vehicles per day based on the sum of the two modelled periods. From the two Figures it can be seen that the traffic model suggests that no local road in the county would be subject to increased traffic flows above the threshold in 2017 during the initial phase of construction of the Scheme. Based on this assessment, it is concluded that construction of the Scheme will not have a material effect on the A4 or A355 routes.
4.12.2 In 2020, during the second phase of construction, the model runs suggested that there is the possibility that a section of the A412 Uxbridge Road west of the Crooked Billet roundabout could be subject to increased traffic flows above the one thousand vehicles a day threshold (+1240 vehicles per day). No potential impacts were identified on the A4 or A355 routes.
4.13 Marsh Lane will be shut whilst a new bridge is constructed on-line. The potential diversion route is via Lake End road.
4.14 Lake End Road will experience increased construction traffic as part of the planned off-line development.
4.15 Huntercombe Lane South links Bath Road to Lake End Road. Increased traffic along Lake End Road is likely to impact along this road too, especially with the planned new office building (see 3.7).
4.16 The B3026 is the only road that runs south from Dorney to Windsor. With disruption to road crossing the Motorway to the North, it is likely that this road will experience increased traffic too.
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4.17 Old Slade Lane is a small residential road in the South East of the district.
4.18 North Park / Richings Way is a popular HGV route through the district and as such experiences a high amount of traffic
4.19 Ongoing consultation with the local Parish Council and further research for the District Local Plan identify that there is a popular alternative route for HGVs through the district from Richings Park to the M40. This route involves the Village Centre of Iver and is already experiencing unacceptable levels of HGV traffic. Assurances must be made that the scheme will not add to this either directly or indirectly. The common roads affected are Thorney Lane South, Iver High Street, Bangors Road South, Bangors Road North and Southlands Road (A412).
Highways England's Comment
4.19.1 Highways England notes the concerns raised by the Councils over the route used by HGVs between Richings Park and the M40 and is able to confirm that the assessment of traffic diversion during construction did not show any diversion on to the Thorney Lane South, Iver High Street, Bangors Road South, Bangors Road North, Denham Road and Southlands Road route.
5. AIR QUALITY
5.1 The Environmental Statement considers the local and regional effects on air quality in order to meet the EU Directive limits, which are absolute and must be met at all costs. The LIR should specifically consider the local impacts to ensure the set limits are met in the shortest time possible and ensure air pollution is not added to at all from the scheme.
5.2 The Local Air Quality Management (LAQM) process is set out in Part IV of the Environment Act 1995. It places an obligation on all Local Authorities to regularly review and assess air quality in their areas, and to determine whether or not the air quality objectives are likely to be achieved.
5.3 Where exceedances are likely, an Air Quality Management Area (AQMA) must be declared and an Action Plan produced outlining the measures it intends to put in place to work towards achieving the objectives. In South Bucks, the AQMA spans the routes of the 3 motorways passing through the district; the M40, M25 and M4 (figure 4).
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5.4 The existing M4 corridor is designated as an AQMA because of the likely breach of the N02 annual mean objective at residential properties in close proximity to the motorway.
5.5 Dust is an inevitable side effect of demolition and construction works. All worksites and compounds should follow good construction practice to minimise the generation of dust or mud from the site including wheel and body washing prior to leaving site and the sheeting of loaded vehicles. Sensitive properties in the vicinity of work sites or compounds should be identified and provided with local mitigation as required.
5.6 Transport routes must be kept clear of the build-up of dust and mud to reduce the impact on properties away from the immediate working area.
5.7 HGV movements on new roads or minor roads not currently used regularly for heavy vehicles will have the potential to cause nuisance due to noise and vibration in addition to traffic disruption. All haulage traffic should be managed to minimise unnecessary nuisance to minimise the generation of respirable fine particles
5.8 In excess of fifty properties will be impacted directly as a result of the works on carriageway or bridges, in addition to a minimum of 3 sensitive businesses in close proximity including an Ostrich Farm, an Animal Sanctuary and a commercial Caravan Park. Properties will also be impacted directly as a result of compounds and haulage/traffic routes.
Highways England's Comment
5.8.1 An assessment of the risk that the Scheme would delay the compliance of any zones affected by the Scheme has been undertaken. The assessment has been based on Highways England guidance presented in IAN 175/13 ‘Updated air quality advice on risk assessment related to compliance with the EU Directive on ambient air quality and on the production of Scheme Air Quality Action Plans for user of DMRB Volume 11, Section 3, Part 1 Air Quality’, as explained in paragraph 6.15.4 of Chapter 6 of the ES (Application Document Reference 6-1).
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5.8.2 The IAN 175/13 assessment has identified that there is a low risk of the Scheme causing any delays in the dates that zones affected by the Scheme become compliant with EU Limit Values. On this basis, the Scheme would not interfere with the requirement of the UK to prepare a revised air quality action plan to bring the UK back in to compliance with the ambient air quality directive. In relation to South Bucks District Council, the relevant zone is the South East zone. No non-compliant road links were identified with or without the Scheme in the opening year of 2022.
5.8.3 The Air Quality Management Area (“AQMA”) designations for South Bucks District Council are noted within the ES (paragraphs 6.8.1, 6.11.1, 6.12.1 and 6.14.4).
5.8.4 The following responses address the points raised by South Bucks District Council in relation to construction effects.
5.8.5 The environmental management of construction-related impacts, specifically the control
of dust and PM10, mud, haulage/traffic movements, and spoil are addressed in sections 6.2 and 6.3 of the Outline Construction Environmental Management Plan (“CEMP”) (Appendix 4.2A of the ES, Application Document Reference 6-3)
5.8.6 An assessment of construction dust has been undertaken for the Scheme and is presented in Chapter 6 of the ES (Application Document Reference 6.1), and specifically in paragraphs 6.8.12 to 6.8.14 for areas west of Junction 7 and paragraphs 6.11.8 and 6.11.13 for areas between Junctions 5 and 4b in South Bucks District Council's boundaries.
5.8.7 A wide range of air quality mitigation measures for the construction phase, including both demolition and construction, have been identified, as described in Appendix 6.1 of the ES and in Chapter 6 of the Outline Construction Environmental Management Plan (Appendix 4.2A of the ES). These measures are based on Institute of Air Quality Management (“IAQM”) guidance. The mitigation measures include standard mitigation measures (Section 6.2 of the Outline Construction Environmental Management Plan) and additional mitigation measures (Section 6.3 of the Outline Construction Environmental Management Plan) where residential properties are close to construction compounds. Section 5.6 of the Outline Construction Environmental Management Plan (Appendix 4.2A of the ES) also
includes measures on site construction layout to control dust and PM10, mud, haulage/traffic movements and spoil. The above has been discussed and agreed between Highways England and South Bucks District Council when drafting the Statement of Common Ground in paragraphs 3.30 to 3.32.
5.8.8 With the proposed mitigation measures in place, the effect of construction dust on receptors has been evaluated as not significant, as summarised in Table 6.23 in the ES.
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5.8.9 It is recognised that construction works along the Scheme are within the South Bucks Air Quality Management Area, see paragraphs 6.8.1 (b) and 6.11.1 (c) of the ES (Application Document Reference 6.1). General provisions are outlined within Section 6.3.4 of the Outline Construction Environmental Management Plan (Appendix 4.2A of the ES) to minimise plant and vehicle emissions where possible.
5.8.10 In the current Statement of Common Ground between Highways England and South Bucks District Council (paragraph 3.27), it is agreed that low emission initiatives should be adopted to limit the impacts of the Scheme on air quality. Standard measures in the recommendations include ensuring all vehicles switch off engines when stationary, no idling vehicles, and identifying that all construction plant should use fuel equivalent to ultra-low sulphur diesel (“ULSD”) where possible. Additional measures include avoiding the use of diesel or petrol powered generators and using mains electricity or battery powered equipment where practicable and implementing a travel plan that supports and encourages sustainable travel (e.g. public transport, cycling, walking and car-sharing).
5.9 In light of the AQMA and potential to breach the national mean objective for NO2 there is sensitivity to any additional pollutant burden to the area. Measures to reduce the impact on air quality by utilising emergent mitigation techniques including living barriers, nitrogen reducing materials in addition to low noise surfacing are to be encouraged.
Highways England's Comment
5.9.1 Further requirements to seek innovative solutions to reduce the levels of NOx and Particulates are not necessary as the Scheme will not have a significant effect on such levels. Paragraph 6.2.44 of the ES (Application Document Reference 6.1) concludes that there is no significant effect caused by the Scheme on air quality and that mitigation is not required. Moreover, the use of barriers is not currently an approved technique for
mitigating air quality effects (for nitrogen dioxide (NO2) and particulates) on Highways England schemes, as there remains uncertainty over the effectiveness of this type of measure. However, this is something that Highways England is currently investigating in a field trial as a potential future targeted mitigation measure and Highways England has agreed to explore the possibility of a trial using innovative air quality mitigation solutions (e.g. planting). This is documented within the current Statement of Common Ground between Highways England and South Bucks District Council in paragraph 3.29.
6. NOISE POLLUTION
6.1 As of yet there is no information on the timing of construction. All works should be subject to prior agreement via a detailed proposal under s61 of the Control of Pollution Act. There will undoubtedly be
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significant impact throughout the project including noisy activities close to residential properties at night. Sleep disturbance needs to be minimised.
Highways England's Comment
6.1.1 An indicative construction programme is provided in Appendix 4.1 of the ES (Application Document Reference 6.3), assuming the notice to proceed in September 2016 through to a 12 week commissioning period between June and September 2021.
6.1.2 Once the contractor has developed the detailed construction programme and associated plant schedule, the likely noise and vibration effects will be verified, including those from operation of the construction compounds. This will include an appraisal of necessary night-time working and the associated noise and vibration effects.
6.1.3 The contractor will be required by the CEMP to employ best practicable means to minimise noise and vibration levels during the works. There will be close liaison between the contractor and Local Authority Environmental Health Officers, affected residents and commercial operations, to ensure that noise and vibration during construction are effectively managed. The contractor will enter into Section 61 Agreements (under the Control of Pollution Act 1974) with relevant local authorities , including South Bucks District Council. Noise and vibration limits will form part of these Section 61 Agreements.
6.1.4 The procedures for managing noise and vibration during construction, including a protocol for compliance monitoring, will be documented in the Construction Environmental Management Plan. An Outline Construction Environmental Management Plan was submitted in support of the Application (Appendix 4.2A of the ES) and this will be finalised by the contractor, and agreed with relevant local authorities, prior to commencement of construction works (pursuant to Requirement 8, Schedule 2 of the Draft DCO (Application Document Reference 3.1)) and the contractor will then be obligated to follow this approved plan.
6.1.5 Paragraphs 12.4.32 to 12.4.87 of the ES (Application Document Reference 6.1) and Appendix 12.3 of the ES (Application Document Reference 6.3) address construction noise and vibration effects.
6.1.6 For the South Bucks District Council area, the assessment concludes that construction noise and vibration effects are predicted to be generally slight adverse for daytime, evening and night-time works.
6.1.7 Where more significant noise effects are identified for particular activities, it is noted that these activities are dynamic in nature, as the works move along the Scheme, and that
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these higher noise levels would prevail for only a relatively short period of time, resulting in a slight adverse effect overall.
6.1.8 Vibration effects are predicted to be generally slight adverse. Stand-off distances to ensure negligible / minor impacts from piling and ground compaction works are provided in Tables 12.13 and 12.14 of the ES. Where more significant effects are identified to receptors within these stand-off distances, the contractor will assess the need for alternative means of working to maintain vibration effects as slight.
6.1.9 Construction traffic will, wherever possible, be confined to the Scheme corridor. On-site HGV movements have been included for construction activities, as shown in Table A12.3.5 in Appendix 12.3 (Application Document Reference 6-3).
6.1.10 Construction compounds 6 and 9 are relevant to the South Bucks area. For each construction compound, it was assumed that there would be 150 HGV movements over the day and evening, and 25 HGV movements over the night, to service the compound (paragraph 12.4.81 of the ES).
6.2 We believe that the increased noise and lighting could adversely affect the health and amenity of those in proximity to the M4 and its connecting roads, given the number of junctions affected by the changes designed to increase traffic use. Sleep disturbance will need to be minimised, with residents being notified in advance of the date and times of work to take place.
Highways England's Comment
6.2.1 Please refer to Highways England’s response above to paragraph 6.1.
6.3 Residents close to work sites will be adversely impacted as a result of noise associated with site work, compounds and increased construction traffic.
Highways England's Comment
6.3.1 Please refer to Highways England’s response above to paragraph 6.1 which addresses construction noise and vibration effects.
6.4 Should the development go ahead, the Contractors are expected to follow the following guidelines:
- Give neighbours who may be affected by particular operations at least 48 hours’ notice
- Keep working hours between 8am and 6pm, Monday to Friday and 8am to 1pm on Saturdays. There should be no working on Sundays or bank holidays
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- Select and properly maintain the quietest suitable equipment and machinery, and observe safe working practices
- Make sure all sub-contractors are told to carry out their work in compliance with agreed guidelines on noise, dust and other matters
- For long-term and complex projects, arrange for detailed liaison with the local community, through structured meetings with residents
- Avoid the need to park on the street by providing on-site parking wherever possible
- Inform the council's environmental health department where their activities might be expected to cause disturbance
- Care must be taken to avoid damage to neighbouring property
- Take all reasonably practicable steps to prevent noise and dust from causing nuisance
Highways England's Comment
6.4.1 Consultation with all stakeholders will take place throughout the development and construction phases of the project. The Communications Plan prepared during the development phase of the scheme will outline the means by which the Contractor will communicate with the community, local authorities, business and traveling public about the Scheme and when work will be undertaken that may impact the area.
6.4.2 Section 61 applications will be developed and submitted to the local authorities to ensure noise levels are assessed and appropriate noise control measures are implemented.
6.4.3 Notice will be given to neighbours in advance via mail drops, public consultation, local meetings and general publicity well in advance of operations that may affect the area. This will be done with the lead and coordination of Highway England.
6.4.4 The site working hours will be in accordance with the core working hours within the CEMP. It should be noted that by the nature of the work some specific works will be required to be undertaken at night outside the core working hours. Construction best practice will be used to minimise the disturbance to the surrounding inhabited areas and works will be undertaken in accordance with Section 61 requirements. Consultation with the local communities and local authorities will be undertaken well in advance of night time working operations.
6.4.5 All site vehicles will be parked either on site or within the site compounds.
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7. NATURE CONSERVATION AND ECOLOGY (LANDSCAPE & TREES)
Introduction
7.1 The proposed ‘M4 Smart Motorway Junctions 3 – 12’ scheme has the potential to have an adverse impact on a number of sensitive ecological receptors in the South Bucks District. These are discussed below.
Protected Trees
7.2 There are 4 areas covered by Tree Preservation Orders in the near vicinity of the proposal. These are:
7.3 Since 1952 the M4 has been already developed to bisect the Richings Park protected area. Part of the study involves research into protection measures and the mitigation against potential tree damage. Little information is provided at present however any measures should be agreed with SBDC.
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Highways England's Comment
7.3.1 The TPO locations identified for TPO 04-1962, TP 14-2000 (T5) and TPO 07-1952 (also Slough Borough Council TP 13/1979) are consistent with those shown on Sheet 3 and Sheet 4, Drawing 9.1 (Application Document Reference 6-2) of the Environmental Statement, and taken into account, where appropriate, in relevant assessments, including Chapter 8 of the Environmental Statement (Application Document Reference 6-1). Please note that the trees covered by TPO 08-1952 have not been considered as they are at least 160m distance from the Scheme at the nearest point and as such they will not be affected. Two TPOs referenced TPO 07-1952 (W2 and W3) and TPO 14-2000 (T5) lie outside the Order limits but adjacent to them and have been considered in paragraph 8.11.9 of the Environmental Statement (Application Document Reference 6-1). It is unlikely that these two TPOs will be affected by the Scheme. With reference to paragraph 8.8.14 it is recognised that the Scheme is likely to result in a direct impact on some protected trees covered by TPO 04-1962 and which fall within the Order limits.
7.3.2 There is a requirement in the Outline CEMP, Appendix 4.2A of the ES (Application Document Reference 6.3), that the Contractor must protect and retain the trees covered by TPO which lie outside the Order limits but which are adjacent to it as well as trees covered by TPO within the Order limits where it is practical to do so throughout the construction phase, in accordance with BS5387. The contractor is required to develop the Outline CEMP into the final CEMP, which is to be approved by the relevant authorities prior to the start of works. This process is secured under Requirement 8, Schedule 2 of the Draft DCO (Application Document Reference 3-1). Consequently, South Bucks District Council will have an opportunity to approve proposals for the protection of trees covered by TPO.
Bats
7.4 The ES has identified the South Bucks area as being of local importance to bat numbers. It does however provide a strategic green corridor for bats as a flying route. Careful consideration is therefore needed to prevent detrimental impact to local species. It is important to mitigate impacts during construction and in design of the scheme around lighting.
Highways England's Comment
7.4.1 With regard to bats, sensitive locations will be detailed in the CEMP via chainage and piling activities will be timed to avoid the active period for bats (i.e. between October and April) where possible. Works within 50m of potential bat roosts will be undertaken subject to the control of a detailed method statement, in order to protect the roost from significant levels of noise, vibration, dust and light. If effects on these
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features cannot be avoided then a detailed working method statement will be produced and consideration given to the need for an EPS licence from Natural England. Appropriate mitigation will be required as part of the licencing procedure to ensure that there is no negative effect on the conservation status of bat populations. This could include enhancement of culverts for roosting and commuting and replacement of tree roosts in the form of bat boxes on trees.
7.4.2 Construction lighting will be regulated in terms of timing and lighting types within the Construction Environmental Management Plan (“CEMP”) lighting will be directional and used only as required for safe construction of the Scheme. In the operation phase, no new lighting is proposed and the luminaries of existing lighting will be replaced with LED lighting to reduce light spill from the sections which are currently lit, as described in paragraph 4.2.4(c) of the ES (Application Document Reference 6.1). The worst case is that there will be no change on the impact of lighting on bats, and possibly a slight benefit due to the reduction of light spill.
7.4.3 Highways England notes that in their written representation, Natural England who were specifically asked/interested in the issue of bats, state that they have no outstanding issues or concerns regarding the Scheme.
Other Wildlife
7.5 The Linear connectivity of sites as a strategic green corridor is important in South Bucks and needs to be maintained. Green Bridges are required to ensure movement of pollinators and associated habitats between both sides of the Motorway.
Highways England's Comment
7.5.1 The Phase 1 habitat surveys undertaken along the M4 indicated that the habitats within the Order limits are not suitable for supporting protected species of invertebrates. As explained in paragraph 9.4.32 of the ES (Application Document Reference 6.1), the habitats within the Order limits are common and widespread, and do not contain plant species considered of importance to notable invertebrate species, such as devils-bit scabious (Succisa pratensis), which is the food plant of marsh fritillary. The highway verges are generally man-made and managed. No protected invertebrates were identified during the desk study. Consequently, the habitats within the Order limits are considered to be unlikely to support a large, notable or diverse assemblage of terrestrial invertebrates and these habitats were therefore considered to be of local value to the invertebrate assemblage.
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7.5.2 No specific mitigation for invertebrates has been identified, although the general mitigation proposals to minimise habitat removal and replanting will benefit invertebrates. As stated in Table 9.5 of the ES (Application Document Reference 6.1), the residual impact of the mitigated Scheme on invertebrates is neutral, given the low value of the existing habitat for invertebrates and the small, discrete areas of habitat removal, much of which will be replanted.
7.5.3 The Scheme will not result in new fragmentation of habitats, as the Scheme comprises the conversion of the hard shoulders to running lanes, which will leave the width of the motorway largely unchanged, except where additional width is required for the Emergency Refuge areas or to accommodate slip roads. This is described in paragraphs 4.2.1 to 4.2.3 of the ES (Application Document Reference 6.1).
7.5.4 In summary, Highways England considers that the demand from Buckinghamshire County Council and South Bucks District Council for green bridges to promote the movement of pollinators is disproportionate given the absence of new fragmentation, the low value of the verges for invertebrates and the neutral effect of the Scheme on invertebrates.
Ecologically significant areas
7.6 Junctions 4 to 5: The main area of environmental interest concerns Richings Park, the South-East corner of which is transected by the M4. Further details are provided in Section 8: Cultural History and Historic Parks below. The water feature to the north of the M4 is a Biological Notification Site (BNS 07 J01), equivalent to Potential Wildlife Site in other areas. Immediately adjacent Old Wood is Ancient Woodland on both sides of the carriageway whilst the secondary and plantation woodland is identified as Deciduous Woodland in Natural England’s Priority Habitat Inventory (figure 9).
7.7 Junctions 7-to 8: Trumper’s Field (97 E03), owned by SBDC, has been selected as a Local Wildlife Site as a good example of unimproved damp neutral grassland. The site is immediately adjacent to the motorway on the south side. A total of 109 different plants have been recorded including Yellow Rattle
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(Rhianthus minor), Pyramidal Orchid (Anacamptis pyramidalis) and Small Flowered Crane’s-bill (Geranium pusillum). The field is cut annually for hay after the flowering season (figure 10).
7.8 BCC would be concerned if there are any negative impacts either directly or indirectly on the sensitive biodiversity sites or habitats, including the cutting back of trees where this reduces the effectiveness of the corridor or includes ancient woodland.
Highways England's Comment
7.8.1 The Scheme will avoid the boundaries of Richings Park, the BNS and Old Wood. Appropriate mitigation (currently in the Outline CEMP) will be detailed within the CEMP at the appropriate chainage for the protection of retained habitat and to avoid indirect impacts on adjacent habitats, including compliance with the Environment Agency’s Pollution Prevention Guidelines for Works in or Near Water, dust management, and BS 5837:2012 ‘Trees in relation to design, demolition and construction – Recommendations’. If required bespoke method statements will be produced for particularly sensitive sites.
7.8.2 The Scheme will remove a small amount of scrub boundary habitat to the north of Trumper’s Field LWS. For the area to be retained appropriate mitigation (currently in the Outline CEMP) will be detailed within the CEMP at the appropriate chainage for the protection of retained habitat not to be affected including compliance with the Environment Agency’s Pollution Prevention Guidelines for Works in or Near Water, dust management and BS 5837:2012 ‘Trees in relation to design, demolition and construction – Recommendations’. If required bespoke method statements will be produced for particularly sensitive sites. Small amounts of replacement scrub will buffer the LWS to the north and additional grassland habitat will be provided elsewhere within the Scheme footprint.
7.8.3 The Scheme will avoid the boundaries of all ancient woodland and appropriate mitigation (currently in the Outline CEMP) will be detailed within the CEMP at the appropriate chainage for the protection of retained habitat not to be affected including compliance with the Environment Agency’s Pollution Prevention Guidelines for Works in or Near
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Water, dust management and BS 5837:2012 ‘Trees in relation to design, demolition and construction – Recommendations’. If required bespoke method statements will be produced for particularly sensitive sites.
8. CULTURAL HISTORY AND HISTORIC PARKS (LISTED BUILDINGS)
Local area Characteristics – urban qualities
8.1 There are potential issues concerning built heritage with the construction process taking place in the near vicinity of 3 conservation areas: those of Burnham, Dorney and Huntercombe.
8.2 Burnham was designated a conservation area in 1977 for its links to Norman architecture. In total there are 39 individual list entries of buildings which are listed as being of special architectural or historic interest in the area (figure 11). Potential increase in noise, vibration and traffic are of main concern.
Highways England's Comment
8.2.1 Burnham Conservation Area is located north of junction 7 Huntercombe Spur on the M4, with the most southerly point lying about 2km from the M4. The Conservation Area lies about 1km to the north of the Zone of Visual Influence (“ZVI”) for the Scheme which
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extends northwards along Huntercombe Spur to the roundabout on the Bath Road, as shown on Drawing 7.1 Sheet 10 of the ES (Application Document Reference 6.1). The Conservation Area is not shown on this drawing, as it lies beyond the 250m study area for the Scheme. There is no inter-visibility between the Conservation Area and the Scheme, so the Scheme will not impact on views from the Conservation Area or its setting. Similarly, the Conservation Area lies outside the study areas for the air quality (defined in paragraphs 6.2.30 to 6.2.35 of the ES) and the noise and vibration studies (defined in paragraphs 12.2.33 to 12.2.38), indicating that the Scheme will not result in changes in air quality, noise levels or vibration in the Conservation Area. Therefore, no adverse impacts to this heritage asset are anticipated as a result of the Scheme.
8.3 Dorney was designated a conservation area in 1996 for special architecture and historic interest (figure 12). The impact on noise, vibration, air quality and traffic in the area are the main threats to this location.
Highways England's Comment
8.3.1 Dorney Conservation Area lies to the south of Junction 7 Huntercombe Spur on the M4 at a minimum distance of about 700m to the northern boundary of the Conservation Area and at least 300m outside the ZVI, as illustrated on Drawing 7.1 Sheet 10 in the ES (Application Document Reference 6.2). The Dorney Conservation Area is not shown on the drawing as it lies outside the 250m study area for heritage assets. As there is no inter- visibility between the Scheme and the Conservation Area, no direct or indirect impacts on landscape and views from the Conservation Area or the setting of the Conservation Area are expected.
8.3.2 Dorney Conservation Area lies outside the study area for the noise assessment. A comparison of the Do Something (the Scheme) and Do Nothing for the year of opening (2022), illustrated on Drawing 12.4 Sheet 10 of the ES (Application Document Reference 6.2), shows reductions in noise levels of 1 to 2 dB(A) in the countryside and 0 to 1 dB(A) along Lake End Road towards the village, resulting from the proposals to re-surface all lanes of the motorway with low noise surfacing. Given the distance between the Scheme
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and Dorney Conservation Area, the village may experience no change or possibly a modest reduction of noise of less than 1 dB(A).
8.3.3 Dorney Conservation Area lies outside the study area for the air quality assessment. Construction dust is generally considered to be an issue within 200m of construction sites, so the Dorney Conservation Area is sufficiently distant not to be significantly affected. Drawing 6.10 Sheet 10 of the ES (Application Document Reference 6.2) shows that the
NO2 air quality objectives would be met for most of the receptors modelled in the vicinity of the M4 and Junction 7. As the impacts on air quality decrease with distance from the source, it is considered that the Scheme will not significantly affect air quality in Dorney Conservation Area.
8.3.4 No adverse impacts are anticipated to Dorney Conservation Area as a result of the Scheme.
8.4 Huntercombe was designated a conservation area for special architecture and historic interest (figure 13). It is most at risk due to the site bordering Huntercombe Way to the East. Therefore issues of noise, vibration, traffic and air quality need to be considered.
Highways England's Comment
8.4.1 Huntercombe Conservation Area lies to the north of the M4 and to the east of Lake End Road. The Conservation Area encompasses part of Huntercombe Manor and Registered Park and Garden, discussed in paragraph 8.5 below, as well as Burnham Abbey, a Grade 1 listed building, discussed in paragraph 8.6.
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8.4.2 Most of the Huntercombe Conservation Area lies outside the Scheme ZVI. Paragraph 7.8.23 of the ES (Application Document Reference 6.1) states that a portion of the Huntercombe Conservation Area (No. 812 on Drawing 7.1 Sheet 10) is located with the Scheme’s ZVI. This portion is restricted to the eastern periphery of the conservation area and includes part of Huntercombe Manor and Registered Park and Garden, with views principally towards Huntercombe Spur to the east.
8.4.3 During construction, site activities along Huntercombe Spur may impact on the setting of the eastern part of the Conservation Area but such impacts are expected to be slight adverse and only temporary. Construction dust may also be issues for parts of the Conservation Area within about 200m of construction areas. Construction noise may result in slight to moderate increases in noise levels depending on the construction phase and time of day as discussed in Appendix 12.3 of the ES (Application Document Reference 6.3). These impacts will largely be mitigated through the implementation of site layout and general site management measures, dust management and noise control measures described in paragraphs 5.6.1 and 5.6.2, Sections 6.2 and 6.3, and Sections 12.2 and 12.3 of the Outline CEMP in Appendix 4.2A of the ES (Application Document Reference 6.3). The residual impact on the setting of the Conservation Area is evaluated to be temporary slight adverse as shown in Table 7.3 of the ES (Application Document Reference 6.1). The effects of construction dust are assessed as not significant in Table 6.23 of the ES (Application Document Reference 6.1). The effects of construction noise is slight adverse as shown in Table 12.21 of the ES (Application Document Reference 6.1).
8.4.4 During the operations phase, paragraph 7.8.23 of the ES (Application Document Reference 6.1) states that the impact of the Scheme on the setting of Huntercombe Conservation Area is predicted to be slight adverse. In the year of opening, the proposed noise mitigation of low noise surfacing across all lanes will result in decreases in noise levels from 3dB(A) near the M4 falling to no change further away, as shown on Drawing 12.4 Sheet 10 (Application Document Reference 6.2). Drawing 6.10 Sheet 10 of the ES (Application Document Reference 6.2) shows that the NO2 air quality objectives would be met for most of the receptors modelled in the vicinity of the M4 and Junction 7. As the impacts on air quality decrease with distance from the source, it is considered that the Scheme will not significantly affect air quality in the Huntercombe Conservation Area.
8.5 Huntercombe Manor (Grade 1 listed building) is also a registered Park and Garden.
Highways England's Comment
8.5.1 Huntercombe Manor and Registered Park and Garden partly lies within the Huntercombe Conservation Area, but the Registered Park and Garden extends to the Huntercombe Spur.
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8.5.2 Huntercombe Manor is a hospital located off Huntercombe Lane South. The Manor lies outside the ZVI of the Scheme. Given the lack of inter-visibility with the Scheme, there will be no effects on the setting of the Manor resulting from the construction of the Scheme. Construction noise levels emanating from works on the main line were calculated for Huntercombe Manor Hospital (CNR-32) and presented in Appendix 12.3 to the ES (Application Document Reference 6.3). The results presented in Tables A12.3.12 and A 12.3.13 indicate that during the daytime, the change in noise level may range from 0 to 2 dB(A) indicating no change to minor impacts, while evening works may lead to change in noise levels from 0 to 3 dB(A) indicating up to moderate impact for the site clearance works and no change to minor impacts for other construction activities. As the Manor house is more than 200m from the nearest construction site, dust is unlikely to be a problem. These impacts will largely be mitigated through the implementation of site layout and general site management measures, dust management and noise control measures described in paragraphs 5.6.1 and 5.6.2, Sections 6.2 and 6.3, and Sections 12.2 and 12.3 of the Outline CEMP in Appendix 4.2A of the ES (Application Document Reference 6.3). The effects of construction dust are assessed as not significant in Table 6.23 of the ES. The effects of construction noise is slight adverse as shown in Table 12.21 of the ES.
8.5.3 During operation phase, given the lack of inter-visibility between Huntercombe Manor and the Scheme, there will be no change in the setting of the Manor. In the year of opening, the proposed noise mitigation of low noise surfacing across all lanes will result in a negligible decrease in noise levels of 0-1 dB(A), as shown on Drawing 12.4 Sheet 10 (Application Document Reference 6.2). Drawing 6.10 Sheet 10 of the ES (Application
Document Reference 6.2) shows that the NO2 air quality objectives would be met for most of the receptors modelled in the vicinity of the M4 and Junction 7. As the impacts on air quality decrease with distance from the source, it is considered that the Scheme will not significantly affect air quality around Huntercombe Manor.
8.5.4 As described in paragraph 7.8.23 of the ES and shown on Drawing 7.1 Sheet 10 (Application Document Reference 6.2) a portion of the Huntercombe Manor Registered Park and Garden is located with the ZVI of the Scheme. The portion of the asset located within the ZVI consists of a large arable field bordered by Huntercombe Spur to Junction 7 on the M4. The impacts of the construction and operation of the Scheme on the Huntercombe Registered Park and Garden are similar to those described above for the Huntercombe Conservation Area. During construction, site activities along Huntercombe Spur may impact on the setting of the Huntercombe Registered Park and Garden. Construction dust may also periodically affect the amenity of the Registered Park and Garden within about 200m of construction areas. Construction noise may also result in minor to moderate impacts, as described for Huntercombe Manor above. These impacts
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will largely be mitigated through the implementation of site layout and general site management measures, dust management and noise control measures described in paragraphs 5.6.1 and 5.6.2, Sections 6.2 and 6.3, and Sections 12.2 and 12.3 of the Outline CEMP in Appendix 4.2A of the ES (Application Document Reference 6.3). The residual impact on the setting of Huntercombe Registered Park and Garden is evaluated to be temporary slight adverse as shown in Table 7.3 of the ES. The effects of construction dust are assessed as not significant in Table 6.23 of the ES. The effects of construction noise is slight adverse as shown in Table 12.21 of the ES.
8.5.5 During the operational phase, the impact of the Scheme on the setting of Huntercombe Registered Park and Garden is evaluated to be slight adverse due to the views of the Scheme. In the year of opening, the ambient noise levels may increase or decrease by 1dB(A), a negligible impact, due to the combined effects of traffic on the Huntercombe Spur and the proposed noise mitigation of low noise surfacing across all lanes on the M4, as shown on Drawing 12.4 Sheet 10 (Application Document Reference 6.2). Drawing
6.10 Sheet 10 of the ES (Application Document Reference 6.2) shows that the NO2 air quality objectives would be met for most of the receptors modelled in the vicinity of the M4 and Junction 7. As the impacts on air quality decrease with distance from the source, it is considered that the Scheme will not significantly affect air quality in the Huntercombe Manor Registered Park and Garden.
Descriptions of Listed Buildings in close proximity to M4 and within Huntercombe Conservation Area
8.6 SU 98 SW BURNHAM LAKE END ROAD
7/275 Burnham Abbey (formerly listed as Burnham Abbey 23.9.55 Convent including attached barn) Grade I
Founded in 1266; restored 1915 and now used as a convent. Flint and chalk rubble with C16 brick restorations and additions; handmade tile roofs. Chapter House, Sacristy, and parts of Frater and Infirmary remain. East range of the cloister with 6 small 2-light casements, one larger 2-light casement and one extended window formerly loft entrance, all with leaded lights. Chapter House with C13 moulded 2-centred arched doorway and the room itself with 3 lancets in its recently extended east end. Sacristy with C16 windows and fireplace. Original south wall of Frater with C16 doorway and fireplace. Infirmary with C13 lancet windows, blocked doorway and C16 windows. VCH III, pp 168- 169; RCHM I, pp 72-75.
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Highways England's Comment
8.6.1 Burnham Abbey is located within the Huntercombe Conservation Area, to the north of the M4 and accessed off Lane End Road. It is shown as site No. 823 on Drawing 7.1 Sheet 10 (Application Document Reference 6.2).
8.6.2 The Abbey is located outside of the Scheme’s ZVI. Given the lack of inter-visibility between the Abbey and the Scheme, no significant effects are predicted on the setting of the Abbey during construction and operation.
8.6.3 The Abbey is located more than 200m from construction works on the M4 main line and the Huntercombe Spur, but lies about 110m from the Order limits on Lake End Road. Construction activities on Lake End Road may periodically result in construction dust deposition. Construction noise may also result in minor to moderate impacts, similar to those described above for Huntercombe Manor Hospital, depending on the construction phase and the time of day. These impacts will largely be mitigated through the implementation of site layout and general site management measures, dust management and noise control measures described in paragraphs 5.6.1 and 5.6.2, Sections 6.2 and 6.3, and Sections 12.2 and 12.3 of the Outline CEMP in Appendix 4.2A of the ES (Application Document Reference 6.3). The effects of construction dust are assessed as not significant in Table 6.23 of the ES. The effects of construction noise is slight adverse as shown in Table 12.21 of the ES.
8.6.4 In the year of opening, the noise modelling predicts a negligible decrease in ambient noise levels by 1dB(A), as shown on Drawing 12.4 Sheet 10 (Application Document Reference 6.2). Drawing 6.10 Sheet 10 of the ES (Application Document Reference 6.2) shows that
the NO2 air quality objectives would be met for most of the receptors modelled in the vicinity of the M4 and Junction 7. As the impacts on air quality decrease with distance from the source, it is considered that the Scheme will not significantly affect air quality in the vicinity of Burnham Abbey.
8.7 SU 98 SW BURNHAM HUNTERCOMBE LANE SOUTH
7/268 Huntercombe Manor Grade I
23.9.55 - I C14, altered and added to in late C17, 1717, and again in 1887. Plain tile roofs, plaster render and colour washed brick. Rainwater heads dated 1717. C19 additions and alterations. Entrance porch across north side of building. Door within ex situ doorcase with Corinthian columns and broken pediment. Main east front C17 plaster rendered two and a half storeys. Parapet and 3 gables, the centre one--shaped. 2 light attic windows. Centre has large 2 storey canted bay with modillion cornice, sides have 3 window range. Cross windows generally but glazing bar sashes to 1st floor of bay and 2
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1st floor windows. 2 similar gables to SOUTH end with large ground floor 3 sided C19 bay and sash windows above. Attached to left is lower range generally plaster rendered but painted brick at left end: recessed gable with projecting ground floor bay window marks C14 hall. To left a projecting 2-gable section with 3-sided C19 bays, one 2 storey, the other a porch with oriel over. To left a recessed section with modern infill in ground floor. To left again a C19 painted brick 2 gabled, 2 storey and attic range. One plain, one shaped gable, various windows, and a 2 storey 3-sided bay on left end gable. Interior: C14 2-bay hall with cambered tie beam and curved braces, late C17 doors and reset early C17 panelling; early C17 panelled buttery; panelled dining room with enriched plaster ceiling and carved overmantel; a south-east room with octagonal ceiling with Verrio panel; an upstairs room in centre of east front with chimney piece with carved garlands and an oval ceiling painting by Verrio; staircase of circa 1675 rising round an open square well and with twisted balusters and, in the ceiling, a round painting by Verrio. Owned by Evelyn family 1650-1705, visited in 1679 by the diarist, John, who describes the house and garden in his DIARY. VH III, p 169; CL, CV, pp 1310 etc; RCHM I, p 78.
Highways England's Comment
8.7.1 Please refer to Highways England’s response to paragraph 8.5 above for Huntercombe Manor Registered Park and Garden.
8.8 SU 98 SW BURNHAM HUNTERCOMBE LANE SOUTH
7/266 Huntercombe Farmhouse Grade II
North section, partly C16 and partly C17. West elevation re-fronted in C18. East elevation timber- framed with red brick nogging; handmade tile roof with old chimney ending in twin stacks, diamond shaped on plan. Modern casement windows with leaded lights. Ground floor with large fireplace, pair of glazed doors with small casement on each side. First floor with one one-light and one 2-light casement. Central section: C19 restored and portion added C20. Timber- framed brick nogging. First floor over-sails on brackets. Ground floor with one one-light casement and one 3-light casement. First floor with one 4-light casement. South section: modern wing brick cement rendered marked as stone masonry timber slats fixed horizontally to first floor; flat roof. West elevation with red brick old tile roof and central brick buttress supporting re- faced wall. Four flush sashes with glazing bars. Modillion cornice. Ground floor with 2 sashes set flush and with glazing bars. One modern casement. Timber door case with Roman Doric fluted pilasters and pediment. Central section, colour washed brick machine tile roof. Two sashes set flush under over- hanging eaves and with glazing bars. Ground floor with glazed entrance, one 3-light casement with cambered relieving arch and glazing bars. To the right again, a modern extension with first floor balcony.
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Highways England's Comment
8.8.1 Huntercombe Farmhouse is located off Huntercombe Lane South. The Farmhouse lies outside of the ZVI for the Scheme. Given the lack of inter-visibility between the Farmhouse and the Scheme, no significant effects on the setting of the farmhouse are predicted during construction and operation.
8.8.2 The farmhouse is more than 200m from construction sites, so construction dust is unlikely to be significant, but construction noise may result in minor to moderate impacts, depending on the construction phase and the time of day, as described for Huntercombe Manor above. Construction-related impacts will largely be mitigated through the implementation of site layout and general site management measures, dust management and noise control measures described in paragraphs 5.6.1 and 5.6.2, Sections 6.2 and 6.3, and Sections 12.2 and 12.3 of the Outline CEMP in Appendix 4.2A of the ES (Application Document Reference 6.3). The effects of construction dust are assessed as not significant in Table 6.23 of the ES (Application Document Reference 6.1). The effects of construction noise is slight adverse as shown in Table 12.21 of the ES (Application Document Reference 6.1).
8.8.3 In the year of opening, the noise modelling predicts a negligible decrease in ambient noise levels by 1dB(A), as shown on Drawing 12.4 Sheet 10 (Application Document Reference 6.2). Drawing 6.10 Sheet 10 of the ES (Application Document Reference 6.2) shows that
the NO2 air quality objectives would be met for most of the receptors modelled in the vicinity of the M4 and Junction 7. As the impacts on air quality decrease with distance from the source, it is considered that the Scheme will not significantly affect air quality in the vicinity of the farmhouse.
Other Heritage Issues
8.9 Junction 4 to 5: Richings Park has been identified as an Archaeological Notification Area. It is an early 18th century landscape park and is the only surviving example of Stephen Switzer’s work in the country. Many of the features of the park remain including the canal/water feature, the southernmost tip of which has been cut by the motorway. Other features are believed to remain including radiating woodland belts. The boundary of the park includes significant veteran trees and the area includes a number of earlier features evidence of which has been found archaeological investigations (figure 14).
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Highways England's Comment
8.9.1 The Scheme does not require any land outside the existing highway boundary in the vicinity of Richings Park, as shown on Drawing 4.1 Sheets 51 and 52. Paragraph 7.12.6 of the ES has identified that currently unknown archaeological remains may be affected by the construction of the Scheme. No direct physical impacts to any known heritage assets as a result of the Scheme have been identified. Any impacts will be dependent on the actual extent of the excavations required and the value of the as yet unknown heritage asset. If works are likely to disturb previously un-excavated ground, they will be subject to an archaeological watching brief, as described in paragraphs 7.2.2(a) in the Outline CEMP (Application Document Reference 6-3) and secured under Schedule 2, Requirement 8 of the Draft DCO (Application Document Reference 3-1).
8.10 Junction 7 to 8: This section includes a number of Archaeological Notification Areas adjacent to the motorway (figure 15).
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Highways England's Comment
8.10.1 The Scheme features to be built in the Dorney and Huntercombe Archaeological Notification Areas are shown in Drawing 4.1 Sheets 35 to 38. Notable works include the widening of Thames Bray Bridge and off-line construction of Monkey Island Lane overbridge, Lake End Road overbridge and Huntercombe Spur. Paragraph 7.8.16 of the ES states that currently unknown archaeological remains may be affected by construction works as a result of the Scheme. Any impacts will be dependent on the actual extent of the excavations required and the value of the as yet undiscovered remains. If such works are likely to disturb previously un-excavated ground, they will be subject to an archaeological watching brief, as described in paragraphs 7.2.2(a) in the Outline CEMP (Application Document Reference 6.3) and secured under Schedule 2, Requirement 8 of the Draft DCO (Application Document Reference 3.1).
8.11 BCC would expect that there would be further consultation with the archaeological service if any of the works outside the existing corridor affect the Archaeological Notification Sites. Further investigation might be required.
Highways England's Comment
8.11.1 The archaeological watching briefs identified within Chapter 7 of the ES (being an appropriate form of mitigation) will be undertaken in accordance with a Written Scheme of Investigation (WSI). The WSI will be produced in accordance with the requirements of the archaeological service and the published standards and guidance of the Chartered Institute for Archaeologists. The need for a WSI is secured by Schedule 2, Requirement 16 of the Draft DCO (Application Document Reference 3.1).
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9. COLNE VALLEY PARK
Background to and location of the Park
9.1 The Colne Valley Regional Park, which was established in 1965, is the first taste of countryside to the west of London. The Park runs from Rickmansworth in the north to Staines in the south, from Slough in the west to Uxbridge and Heathrow in the east.
9.2 The 6 objectives of the Park are:
1. To maintain and enhance the landscape, historic environment and waterscape of the Park in terms of their scenic and conservation value and their overall amenity.
2. To safeguard the countryside of the Park from inappropriate development. Where development is permissible it will encourage the highest possible standards of design.
3. To conserve and enhance biodiversity within the Park through the protection and management of its species, habitats and geological features.
4. To provide opportunities for countryside recreation and ensure that facilities are accessible to all.
5. To achieve a vibrant and sustainable rural economy, including farming and forestry, underpinning the value of the countryside.
6. To encourage community participation including volunteering and environmental education. To promote the health and social well-being benefits that access to high quality green space brings.
9.3 The concept of the Park is led by the Colne Valley Park Community Interest Company (CIC). South Bucks District Council is a member of the CIC alongside London Borough of Hillingdon and Slough Borough Council (through which the Smart Motorway scheme also passes). In total 65 organisations including local authorities, charities, community groups, landowners and businesses are members of the CIC.
Summary of proposal within the Park
9.4 Closure for 1 year of the Old Slade Lane Bridge in South Bucks/Slough that carries the Colne Valley Trail.
Highways England's Comment
9.4.1 The removal of the bridge during its reconstruction will sever the access route across the motorway. A traffic management plan will be prepared in detail during the development
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phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works.
9.5 In addition it appears that the connecting path (Bridleway IV31) to Old Slade Lane from Thorney Park will also be severed during construction.
Highways England's Comment
9.5.1 The removal of the bridge during its reconstruction will sever the access route across the motorway. A traffic management plan will be prepared in detail during the development phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works.
Impact expected
9.6 The scheme will negatively impact on the Colne Valley Park objective 4 (countryside recreation). The Old Slade Bridge is the only crossing point within the Colne Valley Park to the west of the M25; previous paths were severed when the M4 was originally constructed. Highways England’s diversion is 5km along busy A-roads with limited pavements - which is completely impractical (see figure 1, pp 9). The route of the Colne Valley Trail will effectively be stopped up.
Highways England's Comment
9.6.1 The removal of the bridge during its reconstruction will sever the access route across the motorway. A traffic management plan will be prepared in detail during the development phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works.
9.7 The closure of the connecting path will mean that the link from Thorney Park and Thorney Mill Road along bridleway IV31 will be unusable during construction.
Highways England's Comment
9.7.1 The removal of the bridge during its reconstruction will sever the access route across the motorway. A traffic management plan will be prepared in detail during the development phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works.
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Summary
9.8 Access along bridleway IV31 should be retained either through reducing the construction site or temporarily diverting the bridleway around the construction site.
Highways England's Comment
9.8.1 The removal of the bridge during its reconstruction will sever the access route across the motorway. A traffic management plan will be prepared in detail during the development phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works.
9.9 If this scheme goes ahead there would need to be mitigation through provision of alternate access for the Colne Valley Trail or, if this is not possible, compensation for the impacts on the Colne Valley Trail. This could include enhancements to circular routes to the north and south of the blockage and elsewhere in the Colne Valley Park in land under Highways England control (such as the M4 underpass beside the River Colne)
Highways England's Comment
9.9.1 The removal of the existing Old Slade Bridge during its reconstruction will remove the access route across the motorway. A traffic management plan will be prepared in detail during the development phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works. Highways England refers the Examining Authority to paragraphs 13.6 and 13.7 of the CEMP for approach for developing and agreeing diversion routes.
10. WATER: RIVER THAMES AND FLOOD RISK
Introduction
10.1 Most of the proposed development will take place within either Flood Zone 2 or 3 within the South Bucks District (see figure 16). As both Dorney and Iver are situated in the River Thames Catchment it is considered that local surface water flood risk areas will be affected by the proposed improvement scheme. It will be essential that detailed drainage design and any associated local flood risk impacts are fully assessed using up to date surface water flood maps and an assessment of areas at risk with hard standing. The design needs to be approved by Buckinghamshire County Council as Lead Local Flood Authority (LLFA) and should ensure that there are no adverse impacts on or off site.
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Highways England's Comment
10.1.1 Where works (for example carriageway widening) are to take place within Flood Zone 3, any loss of floodplain storage will be compensated for on a volumetric equivalent, and where feasible level for level, basis. The compensatory storage will be created prior to any losses and as a result of this proposed approach, which is set out in the Flood Risk Assessment (Application Document Reference 5.3), for example in paragraph 5.1.22 which discusses works within the floodplain at Thames Bray, there will be no impact on fluvial flood risk within the South Bucks District.
10.1.2 With regard to surface water, the current flood risk from this source has been assessed using information from Highways Agency Drainage Data Management System (“HADDMS”) flood events register and the Environment Agency’s updated flood maps for surface water. Sections of the Scheme which have experienced the highest number of historical flood incidents (which lie within South Bucks District between junctions 8 to 9) are also those areas where surface water flood risk on adjoining land is deemed moderate to high on Environment Agency flood maps (see Annexes A and B of the Flood Risk Assessment) (Application Document Reference 5.3). The effect of the Scheme on surface water flood risk between junctions 8/9 and 7 and junction 5-4b is appraised in paragraphs 5.1.18 and 5.1.53 respectively of the Flood Risk Assessment (Application Document Reference 5.3), which concludes that there will be no increase in surface water flooding risk to third parties and no adverse impacts either on or off site. This is because where there is an increase in impermeable surface cover due to the construction of the Scheme, mitigation will be included to manage surface water runoff from the new impermeable area such that discharge rates at outfalls will not exceed existing discharge rates. This principle is established in the Flood Risk Assessment, and a detailed drainage design will be completed during the detailed design phase of the Scheme, with information submitted to the Lead Local Flood Authority for approval
10.2 The rivers and streams in the area have been classified as ‘Moderate’ under the Water Framework Directive (WFD) and require improvement in order to reach the minimum standard that the WFD requires.
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Highways England's Comment
10.2.1 Table 15.5 of the Environmental Statement (Application Document Reference 6.1) sets out the Scheme response to delivering the requirements of Water Framework Directive, with regard to preventing further deterioration and reducing the pollution of aquatic ecosystems. As noted in this table the proposed drainage design will either maintain existing or improve runoff quality from the Scheme and measures will be implemented during construction and operation to prevent or mitigate impacts on hydro-morphology (for example, through appropriate design of culvert extensions), biological and physical- chemical quality of the water environment. These measures are documented in the Outline CEMP Appendix 4.2A to the ES (Application Document Reference 6.3) and include a commitment for all bankside and instream works to be undertaken in accordance with specific method statements that accord with current best practice pollution control guidance from the Environment Agency, contained in British Standards and key Regulations.
10.2.2 The effectiveness of these pollution prevention and mitigation measures is assessed in a Water Framework Directive Compliance Assessment (Application Document Reference 7.6), which concludes that the Scheme would be compliant with the objectives of the Water Framework Directive.
Design of drainage
10.3 BCC are concerned by the current documentation suggesting drainage systems to be in the form of conventional, oversized pipes and gullies. There is a real opportunity to provide enhancements to the water courses and biodiversity through the effective use of SUDS, contributing towards WFD targets. BCC would accept that this may not be possible within the corridor of the M4 itself but would be willing to identify suitable opportunities on adjacent land. The canal in Richings Park requires particular consideration given the importance it has for a range of issues.
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Highways England's Comment
10.3.1 Drainage proposals are centred on making best use of existing drainage systems and outfalls (with repairs/upgrades undertaken where necessary) as documented in the Drainage Strategy Report (Application Document Reference 7-5) and minimising land take in an effort to reduce effects on adjoining landowners and the environment. Incorporating SuDS within the Order limits is therefore not feasible. The potential for incorporated SuDS on adjacent land in the ownership of Buckinghamshire County Council is a topic of current discussion between Highways England and Buckinghamshire County Council, which is on-going with a view to finalising a Statement of Common Ground.
10.4 Works to the Thames Bray Bridge involve the development over a National Trail as identified by Policy L4. Relevant precautions need to be put in place to ensure that this route is not negatively impacted by the scheme.
Highways England's Comment
10.4.1 As indicated in the response in 10.1.1, where works are to take place within Flood Zone 3, for example at Thames Bray, any loss of floodplain storage will be compensated for on a volumetric equivalent, and where feasible on a level for level basis. Implementation of this compensation strategy will ensure that there would be no impact on fluvial flood risk within the South Bucks District. As also stated in 10.1.1 there will be no increase in surface water flooding risk to third parties and no adverse impacts either on or off site. A detailed drainage design will be completed during the detailed design phase of the Scheme and this information submitted to the LLFA for approval. The National Trail would therefore not be negatively impacted by the Scheme in terms of surface water drainage or fluvial flood risk.
10.5 Formal consents may be required from BCC under Land Drainage Act 1991 for certain works affecting non Main River or ordinary watercourses. Similarly, consents may be required from the Environment Agency for works affecting Main River under Water Resources Act 1991.
Highways England's Comment
10.5.1 Highways England is aware of the requirement to secure Consent from Buckinghamshire County Council for any works (temporary or permanent) with the potential to obstruct flow in any ordinary watercourse and for Flood Defence Consent from the Environment Agency for any works (temporary or permanent) within 8m of the top of bank of any Main River.
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10.5.2 Consent applications would be lodged during the detailed design stage of the Scheme as the applications need to be informed by a level of detail of information that is not available at this juncture. This approach is typical, with the Environment Agency generally advising that Flood Defence Consents do not need to be tied into a DCO Application..
10.6 A maintenance plan is required to set out how and when the drainage system will be kept following construction. This needs to include details of responsibility and consider each drainage aspect. Proposals for the detailed drainage design will need to be discussed with Buckinghamshire County Council Strategic Flood Management at the appropriate stage.
Highways England's Comment
10.6.1 A maintenance plan already exists as documented in paragraph 1.3.17 of the Drainage Strategy Report (Application Document Reference 7.5) so regular maintenance of the drainage systems will be undertaken based on Asset Maintenance and Operational requirements (“AMOR”) and the Technology Maintenance Management Manual (“TMMM”) by the Asset Support Contract (“ASC”) service provider.
10.6.2 The proposed drainage design will be completed during the detailed design phase of the Scheme and information will be submitted to the LLFA for approval.
11. MINERALS AND WASTE ISSUES
11.1 The Scheme will take up a substantial area of land, and its reconstruction will give rise to Construction, demolition and Excavation wastes, as well as consume aggregates. These aspects have been quantified, especially as the scheme represents a significant infrastructure development within Buckinghamshire.
11.2 The current landfill capacity statements will need to be updated based on BCC’s Waste Capacity Study 2015 which is to be published later this year.
Highways England's Comment
11.2.1 After completion of the detailed design the quantities and types materials arising from the works can be finalised. The ground investigation works that are planned for early 2016 will further inform the type and nature of this material.
11.3 The Site waste management plan can then be finalised at this time and prior to commencing the construction phase. The designers and contractor will endeavour to reuse as much material on site as is possible. Compound areas will be used as storage and recycling/ reprocessing areas. This will minimise the amount of material to be disposed off-site and reduce the import of imported aggregates,
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with a view to minimise the impact of the Scheme on the local minerals and waste plan.. The contractor has a specialist team that specialises in the recycling and reuse of material, along with a full time on- site material testing team and lab facility. Early engagement will be held with Buckinghamshire County Council to share best practice and knowledge in order to maximise the re-use of material. The ES needs to identify and publish the total aggregate requirement, detailed with the types of material, when they will be required, and for what phase of the scheme. This is essential information for BCC to include in its Local Aggregate Assessments which it publishes each year and that will be taken on board in the production of its new Replacement Minerals and Waste Local Plan. If the scheme takes place it will be likely to make a temporary increase in demand for aggregates during the period of its construction, and some of that demand may fall on sites in Buckinghamshire.
Highways England's Comment
11.3.1 The total aggregate requirements along with material type will be finalised following completion of the detailed design and construction programme. The likelihood of sourcing aggregates from quarries within Buckinghamshire will then be determined and will be discussed with Buckinghamshire County Council.
11.4 The likelihood of sourcing aggregates from quarries within Buckinghamshire needs to be discussed and indicated within the ES.
Highways England's Comment
11.4.1 As stated above, the likelihood of sourcing aggregates from quarries within Buckinghamshire will be discussed with BCC following completion of the design and the production of the materials management plan. The materials management plan will be developed with early engagement being held with Buckinghamshire County Council.
11.5 Rates of recycling on site of all waste streams should at least be equivalent to similar constriction projects, e.g. Cross Rail. The more material that can be reused within the scheme the less waste will need management off site, including disposal.
Highways England's Comment
11.5.1 Early engagement will be held with Buckinghamshire County Council to share best practice and knowledge in order to maximise the re-use of material. Rates of recycling on site of all waste streams should at least be equivalent to similar constriction projects, e.g. Crossrail. It is recognised that the more material that can be reused within the Scheme means that less waste will need management off-site, including disposal.
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11.6 It will be important for the Outline Construction Environmental Management Plan to identify when the waste reuse locations will be identified. The Site Records also refer to ‘contingency arrangements’, however BCC believe these arrangements should be agreed in advance.
Highways England's Comment
11.6.1 Waste re-use locations will be identified in the CEMP following completion of the detailed design and detailed construction planning prior to commencement of the construction works. Contingency arrangements will be determined with discussions with Buckinghamshire County Council after consideration of the risks associated with the availability of each site.
11.7 The Outline Materials Management Plan reads as tentative, and states intentions, rather than detailed requirements.
- 1.1.4 Refers to soil management, including reuse on other sites of soils with elevated levels of contaminants. This would need to be carried out with care given this may lead to leakage of contaminants into watercourses or ingestion by animals or humans.
- 1.1.5 Refers to passing on recyclable materials to be passed on to other waste facilities so as to find other suitable sites. Reusable materials may or may not be wastes, and in either case should not be sent for disposal to landfill. There is Environment Agency advice about when reusable materials are wastes or not.
Highways England's Comment
11.7.1 A soil management strategy will be included within the materials management plan, which will address the concerns associated with leakage of contaminants into watercourses or ingestion by animals or humans..
11.7.2 The designers and contractor will endeavour to reuse as much material on site as is possible. Compound areas will be used as storage and recycling/ reprocessing areas. This will minimise the amount of material to be disposed off-site and reduce the import of aggregates. The contractor has a specialist team that specialises in the recycling and reuse of material, along with a full time on-site material testing team and lab facility. Early engagement will be held with Buckinghamshire County Council to share best practice and knowledge in order to maximise the re-use of material.
11.8 Ground investigation results should have already provided HE with considerable information about the volume of wastes arising, and their characteristics, i.e. Inert/Non-Hazardous/Hazardous, and which materials are potentially reusable directly within the scheme.
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Highways England's Comment
11.8.1 Ground Investigations (GI) have not been carried out for the scheme to date. Ground investigations are planned to take place in early 2016 and the data produced will inform the construction planning with respect to the likely quantities of inert, non-hazardous and other materials.
11.8.2 After completion of the finalised design and detailed construction planning, the quantities and types materials arising from the works can be finalised, based on the GI results.
11.9 Further information is needed on what are the areas of land that will be used for material testing, selection, handling and processing. Page 4 of the Materials Management Plan says they will be ‘outlined’. This is crucial so as to reduce the volumes of wastes that need disposal off site to landfill. Laboratories for testing for contamination will be needed, as well as aggregates recycling machinery.
Highways England's Comment
11.9.1 Compound locations for processing storage and recycling areas will be finalised following completion of the detailed design and construction planning. These locations will be incorporated within the materials management plan. The designer and contractor will endeavour to reuse as much material on site as is feasibly possible in order to minimise the amount of material to be disposed off-site and reduce the need for imported aggregates. The contractor has a specialist team that evaluates the potential for recycling and reuse of material.
11.10 There is no reference to targets for recycling and diversion from landfill. How are higher rates of recycling and diversion from landfill to be achieved? For example, in paragraph 1.1.6 ‘Material resources and waste targets have not yet been set and initial quantifications of the material resources use and waste arisings forecast from the Scheme have been provided using preliminary design information, key performance indications (‘’KPIs”) from similar schemes and professional judgement’.
Highways England's Comment
11.10.1 Recycling targets will be established and included within the materials management plan following the completion of the detailed design and construction planning and prior to commencement of the construction works.
11.11 The better that HE and its contractors are at distinguishing what material needs to be landfilled, and what can be reused, either within the scheme or elsewhere, then this will lead to less wastes needing to be disposed of to landfill. BCC is keen to promote reduction in wastes at source, consistent with the Waste Hierarchy in the National Waste Management Plan for England and the National Planning
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Policy for Waste. This is implemented in policy CS8 in the Buckinghamshire Minerals and Waste Core Strategy.
Highways England's Comment
11.11.1 The designers and contractor have considerable experience in identifying opportunities for re-use of materials and they will endeavour to reuse as much material on site as is possible. The benefits of material recycling and reuse have been known for many years. These include reduced truck movements, materials costs, need to seek landfill sites, and reduced demand on natural resources. As stated previously, the contractor has an in-house specialist team to assist in maximising the recycling and reuse of material along with a full time on-site material testing team and compliance laboratory facility. Early engagement will be held with Buckinghamshire County Council to share best practice and knowledge in order to maximise the re-use of material.
12. PUBLIC RIGHTS OF WAY
Introduction
12.1 There are 2 Public Rights of way that will be affected by the scheme which are both long distance national/regional rights of way. These are the Thames path and Colne Valley trail (see figure 17). Additionally the walkway over the River Thames as part of the M4 Bridge will be impacted.
Details of Routes affected
12.2 The Thames Path is a National Trail through the Dorney area of the district and passes directly underneath the M4 Thames Bray Bridge. Construction has the potential to impact upon wildlife, the users of the path and of the river around the construction site. At present no mitigation plans have been put in place. BCC request that the width of the path at this point should be maintained and improved upon post development whilst also ensuring that closures are kept short and convenient diversions offered.
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Highways England's Comment
12.2.1 Section 13.7 of the CEMP (document 6-3 Appendix 4.2A of the Environmental Statement) details the general measures that will be undertaken in respect of Public Transport, pedestrian, equestrian or cycle routes. Paragraph 7.5.35 of the Engineering and Design Report (Application Document Reference 7-3) details the public rights of way that could be affected by the works including the Thames Path. As stated therein, the tow-path under the bridge on the east side will be isolated from the works and kept open during construction. However, short-term closures will be needed on the Thames Path and the river navigation route during the beam lifts for safety reasons. Any damage to the Thames Path will be made good to a similar standard as existed before the works - the outline CEMP requires any public rights of way that are impacted upon to be reinstated and returned to their pre-construction condition.
12.3 The M4 Bridge over the River Thames hosts a cycleway/footpath along both the north and south side. However it is currently intimidating to use due to there being little protection from the oncoming traffic. With the plan for this bridge involving the widening to the north, Sustrans and BCC wish to see the cycle route retained and an improved walkway to be 2.5m wide. BCC also wish to see the cycleway improved by 2.5m on the south side of the bridge. The proposal states that the Thames Path below will not be closed for a lengthy period of time meaning that use of the southern walkway for Cycles and Pedestrians will be available throughout the development.
Highways England's Comment
12.3.1 The cycleway / footpath on the north side of the bridge will be closed temporarily during construction to allow asymmetric widening to the north side. The widened north side will incorporate a 2.5m wide shared path. The cycleway / footpath on the south side of the bridge will be kept open during construction and will not be widened. This is explained in paragraph 4.6.14(a) and (b) of the ES (Application Document Reference 6.1).
12.3.2 As stated in paragraph in 12.2.1 above, the path under the bridge on the east side will be isolated from the works and kept open during construction. However, short-term closures will be needed on the Thames Path and the river navigation route during the beam lifts for the new bridge for safety reasons.
12.4 Old Slade Lane forms part of the Colne Valley Trail, a prominent series of walkways through the Colne Valley Park. The bridge is therefore primarily used for walkers, cyclists and horse riders with a gate present to stop vehicles crossing. At present the County is seeking formal designation of this route to a bridleway. Due to the nature of the users of the bridge, the proposed diversion routes are impractical, requiring a 6km detour. For this reason the preservation of access during bridge construction has been requested.
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Highways England's Comment
12.4.1 The removal of the bridge during its reconstruction will sever the trail across the motorway. A traffic management plan will be prepared in detail during the development phase of the contract, after consultation with all the stakeholders. This will then detail the diversion routes for the closed public rights of way during the construction phase of the works.
13. CONSTRUCTION IMPACT (PROPERTIES, LAND ACQUISITION, HGV MOVEMENTS & BRIDGE REPLACEMENT)
13.1 SBDC are concerned over the potential Highway impacts of bridge and lane closures on the adjacent A4 and other local roads for which there is not much data.
Highways England's Comment
13.1.1 The finalised Construction Traffic Management Plan (CTMP) for the scheme will incorporate all issues associated with the management of vehicular and non- vehicular traffic impacted by the works. The traffic management plan will be prepared prior to commencing the construction of the works. The CTMP will include assessment of the impact to the local network. and during its drafting, consultation with all stakeholders will be undertaken.
13.2 Figure 18 shows the pieces of Council owned land along with other private sites that will need to be acquired for the construction process. It is not yet known how long these parcels of land will be needed for. The use of the access track to Dorney Village Hall is of concern and access to the Hall and its associated car park needs to be guaranteed. Trees and vegetation will also need to be removed including areas of trees covered by TPOs. Part of the mitigation does include replanting of any vegetation lost though.
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Highways England's Comment
13.2.1 The durations that these parcels of land will be needed will be confirmed once the contractor has developed the detailed construction programme. An outline construction programme (Appendix 4.1 of the ES) (Application Document Reference 6-3) is included in the Application. The majority of the parcels of land are required to facilitate the bridge construction works adjacent to them and the outline construction periods gives an indication of the proposed construction periods for these bridges.
13.2.2 Temporary use of the access track to Dorney Village Hall (land parcel 19-56) is required in order to construct a new retaining wall to the motorway to accommodate a new sign gantry. The works will mostly be carried out from the motorway with the access track remaining open. Certain operations will require the track to be narrowed or closed for short periods for health and safety reasons. The finalised traffic management plan for the scheme will incorporate all issues associated with the management of vehicular and non- vehicular traffic impacted by the works. The traffic management plan will be prepared prior to commencing the construction of the works. During its drafting consultation with all stakeholders will be undertaken and where practicable all issues will be addressed.
13.2.3 There is a requirement in the Outline CEMP, Appendix 4.2A of the ES (Application Document Reference 6.3), that the Contractor must protect and retain the trees covered by TPO which lie outside the Order limits but which are adjacent to it as well as trees covered by TPO within the Order limits where it is practical to do so throughout the construction phase, in accordance with BS5387. The contractor is required to develop the Outline CEMP into the final CEMP, which is to be approved by the relevant authorities prior to the start of works. This process is secured under Requirement 8, Schedule 2 of the Draft DCO (Application Document Reference 3-1).
13.3 There are 4 main issues that need to be considered during the construction phase:
- The impact of bridge closures on the local area
- The impact of the construction sites
- The impact of the scheme on the local communities
- The adverse effects of the scheme on the local area
Highways England's Comment
13.3.1 Highways England can confirm that these matters have been considered as part of the environmental impact assessment for the Scheme as reported in the E.S. and that
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mitigation measures to address any impacts arising to those matters stated above have been provided via the mitigation proposals for the Scheme.
13.4 There is a potential for the works to increase congestion on the A4 to the detriment of local residents and businesses over a 2 year period. Marsh Lane and Lake End Road are the main access roads for Dorney Village together with the local businesses and Eton Dorney Lake. It is important that access is maintained at all times and sufficient advance signage is displayed to guide drivers.
Highways England's Comment
13.4.1 The construction will be planned to ensure that access to Dorney Village is maintained. Any diversion routes to maintain access will be clearly defined within the construction traffic management plan and this will be developed within the detailed construction planning stage in consultation with BCC. Sufficient signage will be displayed at all times to guide and inform drivers. The impact to the local network will be assessed and will form part of the consideration process for identifying the diversion routes.
13.5 The Colne Valley Community Interest Company has expressed concern over the disruption likely to be caused by the closure of the Old Slade Lane Bridge. This is a major north-south recreational route over the M4 for which there are no safe alternatives if this bridge is not replaced.
Highways England's Comment
13.5.1 The Old Slade Lane overbridge carries an accommodation track over the M4 to provide access for farm use, local pedestrians and cyclists as part of the Colne Valley Trail. Surveys of NMUs using the bridge were carried out on the 3rd and 6th of June 2015. A total of 102 people used the crossing over the two days of survey, of which 94 were pedestrians and 8 were cyclists. The nearest alternative crossing is at Sutton Lane overbridge, just over 1 mile to the west of Old Slade Lane. As stated in paragraph 13.7.21 of the ES (Application Document Reference 6.1), using this alternative would involve a lengthy diversion but there is no basis for suggesting that this does not provide a safe alternative to Old Slade Lane.
13.6 Detailed plans of the anticipated noise and vibration linked to the construction process have still not been disclosed. SBDC is concerned about potential noise and lighting impacts along with any potential unsocial working hours from work sites.
Highways England's Comment
13.6.1 Paragraphs 12.4.32 to 12.4.87 of the ES (Application Document Reference 6-1) and Appendix 12.3 of the ES (Application Document Reference 6-3) address construction noise and vibration effects.
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13.6.2 The assessment is based on an indicative likely construction schedule and plant roster, and identifies reasonable worst-case noise and vibration effects along the Scheme corridor. For the South Bucks District Council area, the assessment concludes that construction noise and vibration effects are predicted to be generally slight adverse for daytime, evening and night-time works as set out in paragraphs 12.4.48, 12.4.51, 12.4.54 of the ES (Application Document Reference 6-1). Where more significant effects are identified for particular activities, it is noted that these activities are dynamic in nature, as the works moved along the Scheme, and that these higher noise levels would prevail for only a short period of time, resulting in a slight adverse effect overall.
13.6.3 Once the contractor has developed the detailed construction programme, based on the outline construction programme (Appendix 4.1 of the ES) (Application Document Reference 6-3) and associated plant schedule, the noise and vibration effects will be revisited in detail. This will include an assessment of necessary night-time working and the associated noise and vibration effects.
13.6.4 The contractor will employ best practicable means to minimise noise and vibration levels during the works. The contractor is required to liaise with South Bucks Environmental Health Officers, affected residents and commercial operations, to ensure that noise and vibration during construction are effectively managed. The contractor will seek to enter into Section 61 Agreements (under the Control of Pollution Act) with South Bucks District Council.
14. ECONOMIC AND SOCIAL IMPACT
Impact on Businesses
14.1 The scheme is expected to have impacts on the local economy both positive and negative, along with associated community impacts.
Highways England's Comment
14.1.1 The impacts on the local economy have been detailed in the Socio-Economic Report (Application Document Reference 7.1) and Chapter 14 of the ES (Application Document Reference 6.1). Impacts have been identified for both the construction and operational phases of the Scheme. Table 14.15 of the ES (Application Document Reference 6.1) states that during construction, positive impacts arising from the Scheme relate to the creation of temporary employment, whilst temporary negative impacts relate to issues such as amenity, travel delays, temporary land-take and temporary severance. Appropriate mitigation measures have been identified and accordingly none of the negative impacts are considered to be significant. Table 14.15 of the ES (Application
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Document Reference 6.1) states that permanent impacts arising from Scheme operation are primarily positive, relating to improvements to journey times and reliability. Slight adverse impacts arising from Scheme operation may relate to small areas of permanent land-take affecting local residents and businesses, for which appropriate compensation arrangements will be made.
14.1.2 Overall, the Scheme will provide net benefits to the community. The Scheme has been appraised over a range of economic, environmental and social impacts, the results of which are summarised and presented in an Appraisal Summary Table that forms Appendix 2 to the Socio-Economic Report. As explained in paragraphs 7.1.2 and 7.1.3 of the Socio-Economic Report, key benefits to the transport economic efficiency of business users and the creation of local construction-related employment have been identified.
14.2 The proposed scheme will impact on a number of businesses and schools along the proposed route, predominantly during the construction phase. Those in question include:
- The Horse Grazing Pasture off Oak Stubbs Lane
- The Animal Sanctuary UK, Lake End Road
- The Spanish Bit Riding School, Elm Farm Boveney Road
- Amerden Caravan Park
- Burnham Abbey, Lake End Road
- Oxford Diocese, with respect to land owned off Marsh Lane
- Glebe Close animal rescue site for Primates and Horses
- A1 Grab Hire, Lake End Road
- Abbey House, Huntercombe Lane
- Goodman Colnbrook (Jersey) Ltd, Old Slade Lane
- Cemex UK Operations Ltd, Lake End Road / Huntercombe Spur
- Dorney School
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Highways England's Comment
14.2.1 The impact of the Scheme on businesses and community facilities has been considered as part of the assessment undertaken as set out in the Socio-Economic Report (Application Document Reference 7.1) and Chapter 14 of the ES (Application Document Reference 6.1). Comments relating to each of the assets listed above are given below:
Asset Comments
The Horse Grazing Pasture There is a field used for horse grazing bounded by Oak Stubbs Lane, Marsh off Oak Stubbs Lane Lane and the M4 to the north. Sheet 19 of the Land Plans (Application Document Reference 2-2) identifies Plot 19-59 as a strip of temporary land-take to the eastern edge of the field boundary. Table 2 in the Statement of Reasons (Application Document Reference 4-1) states that the purpose of the temporary acquisition of Plot 19-59 is for access and working space for the online reconstruction of Marsh Lane and the Marsh Lane overbridge. The Scheme may therefore have a temporary effect on the use of this site for horse grazing during the construction period (twelve months) due to construction noise.
The Animal Sanctuary The presence of an animal sanctuary at this location was considered in UK, Lake End Road paragraph 4.5.16 of the baseline assessment in the Socio-Economic Report (Application Document Reference 7.2). The status of the animal sanctuary had not been finalised at the time of submitting the Development Consent Order (an appeal decision was awaited).
Sheet 20 of the Land Plans (Application Document Reference 2-2) identifies Plots 20-02a and 20-05 as strips of permanent land-take adjacent to the western side of Lake End Road. Table 2 in the Statement of Reasons (Application Document Reference 4-1) states that the purpose of the acquisition of these plots is for land required for the realignment of Lake End Road overbridge. The Book of Reference (Application Document Reference 4-3) identifies the Animal Sanctuary as an occupier of Plot 20-02a, which comprises some 750sqm of land. Sheet 20 of the Land Plans (Application Document Reference 2-2) identifies Plot 20-02, 20-03 and 20-03a as areas of temporary land-take adjacent to the areas of permanent land-take previously identified. Table 2 in the Statement of Reasons (Application Document Reference 4-1) states that the plots relate to temporary land required for access and working space to construct the realigned Lake End Road and new Lake End Road overbridge. Again, the Book of Reference (Application Document Reference 4-3) identifies the Animal Sanctuary as an occupier of Plot 20-02, an area of 4,362sqm.
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Asset Comments
The principal impact of the Scheme on the Animal Sanctuary therefore relates to the temporary use of land currently occupied by the business. Paragraph 13.7.17 of the ES (Application Document Reference 6-1) states that Lake End Road overbridge is proposed to be constructed within a twelve month period. After completion of the construction works, land required for temporary purposes will be returned to its original use.
The Spanish Bit Riding The Spanish Bit Riding School and Livery is located to the south of the M4, School, Elm Farm, outside of the 0.5km local study area. Boveney Road The Spanish Bit Riding School and Livery is located at Boveney Road to the south of the M4. The business is located outside of the 0.5km local study area used for private assets within the ES (Application Document Reference 6-1). The business will not be affected by temporary or permanent land-take as a result of the Scheme and is sufficiently distant from the Scheme not to be affected adversely as a result of changes in amenity during construction.
Users of the Riding School and Livery accessing the facility from the north may currently use either Lake End Road or Marsh Lane. The plans for the reconstruction of both the Lake End Road and Marsh Lane overbridges have been developed in order to minimise disruption to local residents and businesses and to ensure that one or other overbridge remains open at all times; the construction sequence is specified in paragraph 7.5.38 of the Engineering and Design Report (Application Document Reference 7-3)
Amerden Caravan Park Amerden Caravan Park is a local employment and visitor site. The impacts of the Scheme are identified in paragraph 6.6.7 of the Socio-Economic Report (Application Document Reference 7-2) which states that visitors to the Caravan Park may experience a reduction in amenity whilst construction works are in the immediate vicinity of the site and that ongoing discussions are taking place with the owners of the Caravan Park to identify ways to minimise the impact of Scheme construction on the day to day operation of the business, for example phasing construction work to avoid peak holiday periods.
Burnham Abbey, Lake Burnham Abbey, an Anglican contemplative religious community located on End Road Lake End Road, is identified and described in paragraph 4.5.15 of the ES (Application Document Reference 6-1). Burnham Abbey is located more than 200m from construction works on the M4 and Huntercombe Spur, but about 100m from the Order limits on Lake End Road. As described earlier in this
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Asset Comments
document (paragraph 8.6.3), construction impacts at the Abbey may principally relate to noise (assessed as slight adverse in Table 12.21 of the ES (Application Document Reference 6-1)) although this would be temporary in nature (for example the construction period of Lake End Road overbridge is twelve months in duration). Oxford Diocese, with Paragraph 6.6.9 of the Socio-Economic Report (Application Document respect to land owned off Reference 7-2) identifies that temporary land-take is required in relation to the Marsh Lane reconstruction of Marsh Lane overbridge that may affect private residential and commercial assets, including agricultural land and part of a garden.
Paragraph 14.5.16 of the ES (Application Document Reference 6-1) notes that, for local businesses and residents, construction of the Scheme may lead to some temporary reductions in amenity as a result of potential changes to air quality from construction dust, vehicle emissions and traffic management, increased noise disturbance and some loss of visual amenity. However, residual effects are not considered to be significant (refer to Chapter 6 of the ES (Application Document Reference 6-1) ‘Air Quality’, Chapter 8 of the ES (Application Document Reference 6-1) ‘Landscape’ and Chapter 12 of the ES (Application Document Reference 6-1) ‘Noise and Vibration’ for further detail). Measures to mitigate adverse effects have been identified in the relevant chapters as appropriate and are referred to in the Outline CEMP (Appendix 4.2A of the ES) (Application Document Reference 6-3).
Glebe Close animal rescue The proximity of the Glebe Close properties to the Lake End Road bridge site for Primates and replacement works is recognised by the provisions identified in 14.4.8 of the ES Horses (Application Document Reference 6-1).
As above paragraph 14.5.16 of the ES (Application Document Reference 6-1) notes that, for local businesses and residents, construction of the Scheme may lead to some temporary reductions in amenity as a result of potential changes to air quality from construction dust, vehicle emissions and traffic management, increased noise disturbance and some loss of visual amenity. However, residual effects are not considered to be significant (refer to Chapter 6 of the ES (Application Document Reference 6-1) ‘Air Quality’, Chapter 8 of the ES (Application Document Reference 6-1) ‘Landscape’ and Chapter 12 of the ES (Application Document Reference 6-1) ‘Noise and Vibration’ for further detail). Measures to mitigate adverse effects have been identified in the relevant chapters as appropriate and are referred to in the Outline CEMP (Appendix
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Asset Comments
4.2A of the ES) (Application Document Reference 6-3).
A1 Grab Hire, Lake End A1 Grab Hire is identified as an occupier of Plots 20-02 and 20-02a in the Book Road of Reference (Application Document Reference 4-3). Plot 20-02 is affected by temporary land-take in relation to the Lake End Road overbridge reconstruction. As stated earlier in this table, paragraph 13.7.17 of the ES (Application Document Reference 6-1) notes that Lake End Road overbridge is proposed to be constructed within a twelve month period and that after completion of the construction works, land required for temporary purposes will be returned to its original use. Plot 20-02a is required permanently as part of the realignment of Lake End Road overbridge.
Abbey House, Residential properties in the vicinity of the M4 are described in Section 4.5 of Huntercombe Lane the ES (Application Document Reference 6.1).
Paragraph 14.13.1 of this document confirms that there is no requirement for compulsory acquisition at this location. The property is located in the vicinity of proposed works to Lake End Road and Huntercombe Spur and as such may experience amenity impacts during the construction period. Paragraph 6.6.31 of the Socio-Economic Report (Application Document Reference 7-2) identifies that the significance of the residual effects of the Scheme in this area are considered to be slight adverse.
Goodman Colnbrook Old Slade Lane provides access across the M4 to a sewage treatment works, (Jersey) Ltd, Old Slade forms part of the Colne Valley Trail and acts as farm access. It is Lane acknowledged in paragraph 6.9.5 of the Socio-Economic Report (Application Document Reference 7-2) that the consequences of rebuilding Old Slade Lane on-line will include effects on road users, pedestrians, cyclists and equestrians travelling to and from destinations on either side. The lack of suitable alternative routes for pedestrians has resulted in a moderate to large adverse residual effect being attributed during construction of the Scheme.
Cemex UK Operations Paragraph 4.7.15 of the Socio-Economic Report (Application Document Ltd, Lake End Road / Reference 7-2) identifies the proposal for the extraction of sand and gravel by Huntercombe Spur Cemex in the vicinity of the Riding Court Road overbridge. Planning permission for this development has been obtained from the Royal Borough of Windsor and Maidenhead since the submission of the DCO application for the Scheme. Cemex anticipates that the quarry will commence extraction
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Asset Comments
operations in April 2016.
Table 6 of the Engineering and Design Report (Application Document Reference 7-3) identifies that offline construction of the Riding Court Road overbridge has been selected in part to minimise effects on the proposal to extract aggregates from the land around Riding Court Farm and the need to manage volumes of extraction operations traffic accordingly. Paragraph 7.7.43 of the Engineering and Design Report (Application Document Reference 7-3) notes that construction works for this bridge are anticipated to take sixteen months to complete.
Highways England does not expect Cemex to experience disruption to proposed extraction activities as a result of the Scheme. When construction works are taking place for the Scheme, access for construction traffic will be from the motorway and associated compounds and not from the local road network.
Dorney School Ways in which Dorney School may be affected by the Scheme relate principally to the construction period. Asymmetric widening of the Thames Bray underbridge was selected to minimise impacts on Dorney School arising from land-take (Table 6 of the Engineering and Design Report (Application Document Reference 7-3)). Access to Dorney School has been identified in paragraph 14.8.6 of the ES (Application Document Reference 6-1) as a potential area of impact in connection with works to Marsh Lane and Lake End Road overbridges. In relation to vehicular access, the construction sequence specified in paragraph 7.5.38 of the Engineering and Design Report (Application Document Reference 7-3) ensures that one or other of Marsh Lane or Lake End Road remains open at any one time. In relation to pedestrian access, consideration has been afforded to the provision of additional mitigation to minimise impacts, with measures (for example the provision of a shuttle-bus if deemed necessary following consultation with parents and staff at the school) to be secured under the Construction Traffic Management Plan (Annex E of Appendix 4.2A of the ES (Application Document Reference 6-3).
Part of the playing field at Dorney School (Trumpers Field) is affected by temporary land-take as a result of the Scheme, as assessed in paragraph 6.6.10 of the Socio-Economic Report (Application Document Reference 7-2). The extent of the land-take is considered such that the day to day activities of the school will not be significantly affected. After completion of the construction
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Asset Comments
works, land required for temporary purposes will be returned to its original use.
Eton College Eton College is described in various paragraphs of the ES, including as an employer (paragraph 4.7.3), educational facility (paragraph 4.7.11) and as a tourism attraction (paragraph 4.7.12) (Application Document Reference 6.1).
Employees and visitors to Eton College may currently use either Lake End Road or Marsh Lane to access the site and associated facilities (for example Dorney Rowing Lake). As noted previously in this table, the plans for the reconstruction of both the Lake End Road and Marsh Lane overbridges have been developed in order to minimise disruption to local residents and businesses and to ensure that one or other overbridge remains open at all times, with the construction sequence specified in paragraph 7.5.38 of the Engineering and Design Report (Application Document Reference 7-3).
14.3 Additionally the following Parish Councils have responded:
- Dorney
- Iver
- Burnham
Highways England's Comment
14.3.1 Highways England notes the relevant representation made by Dorney Parish Council (Relevant Representation 46). The representation, dated 16th June 2015, relates principally to noise disturbance as a result of the Scheme and the need to ensure effective mitigation measures. The findings of the noise and vibration assessment, presented in Chapter 12 of the ES (Application Document Reference 6.1), are that, overall, the majority of receptors experience a negligible or minor decrease in traffic noise levels in the short-term (paragraph 12.4.92). The assessment of the long-term change in traffic noise levels shows that, again, the majority of residential properties experience a negligible decrease in traffic noise levels (paragraph 12.4.94 of the ES) (Application Document Reference 6.1). This is a consequence of the assumption of a low-noise surfacing (a Thin Surface Course System) across all lanes along the complete Scheme length (paragraph 12.2.49 of the ES (Application Document Reference 6.1) and Chapter 7 of the Engineering and Design Report (Application Document Reference 7.3)). The village of Dorney is located
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between junction 8/9 and 7; the noise assessment for this section of the Scheme states that, overall the magnitude of impact is minor beneficial in the short term and negligible in the long term, with the significance of effect of the operation of the Scheme in this location assessed as slight beneficial in the short term and neutral in the long term (paragraph 12.8.15 of the ES (Application Document Reference 6.1)).
14.3.2 Highways England held an exhibition in Iver on 6 December 2014 as part of the formal consultation. A further meeting was held with Iver Parish Council on 10 March 2105. Highways England provided an update on progress and outlined the DCO process and timing. Key topics raised by the council were construction compounds, construction traffic routes and Old Slade Lane bridge.
14.3.3 Highways England sent a consultation invitation to Burnham Parish Council in March 2014 and subsequently sent applications for s47, s42 and s56 notices as part of the formal consultation process.
14.4 Farm businesses along the M4 within the district include the Dorney Court Estate, the Dorney Court Kitchen Garden and the land North West of junction 4b. HE has not identified any farm in South Bucks to become economically unviable due to the scheme.
Highways England's Comment
14.4.1 Highways England confirms that farm businesses identified within South Bucks County Borough Council’s area include the Dorney Court Estate, the Dorney Court Kitchen Garden (referred to in paragraph 4.5.8 of the Socio-Economic Report (Application Document Reference 7.2)) and arable farming to the immediate northwest of junction 4b (paragraph 4.8.6 of the Socio-Economic Report (Application Document Reference 7.2)). Paragraph 14.2.10 of the ES (Application Document Reference 6.1) notes that the evaluation of the sensitivity of agricultural receptors has made use of professional judgement stemming from an assessment of the quality and quantity of agricultural land affected. The assessment has not identified any significant impacts on agricultural businesses within the South Bucks County Borough Council area as a result of the Scheme.
14.5 Possible services impacted by the scheme include The Hedgerley to Ascot gas pipeline which bisects the M4 within South Bucks. HE is already aware of this however.
Highways England's Comment
14.5.1 The presence of the Hedgerley to Ascot gas pipeline (National Grid Gas) is noted as crossing the M4 and running east-west within the link between junction 8/9 and junction 7 is noted in paragraph 4.5.7 of the Socio-Economic Report (Application Document
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Reference 7.2). Ongoing liaison is taking place with National Gas to identify potential impacts and identify further appropriate mitigation as necessary.
14.6 To date there is one large scale planning permission on the former Wyeth Pharmaceuticals site along Huntercombe Lane South. This proposal could be postponed by the developer during the M4 construction period. The site is identified as one of the most important employment sites in the district. There are no other existing or proposed land-use planning applications within the main communities surrounding the M4 in the South Bucks District. The land identified as being required within the main communities is also designated as Green Belt.
Highways England's Comment
14.6.1 Chapter 16 of the ES (Application Document Reference 6.1) presents the findings of the cumulative impact assessment of the environmental effects of the Scheme. Paragraph 16.3.6 of the ES states that the traffic model for the Scheme has taken into account other transportation schemes as well as future predicted traffic growth as a result of filters outlined in WebTAG (Unit M4: Forecasting and Uncertainty). The long list of developments and growth scenarios considered for inclusion in the traffic forecasting is provided in Appendix 16.2 of the ES (Application Document reference 6.1), which includes the Wyeth Pharmaceuticals site at Huntercombe Lane South. The site has planning permission for 59 dwellings and associated office development. Only those developments within 1km of the Scheme have been included within the traffic modelled cumulative assessment and the Wyeth Pharmaceuticals site has been scoped out accordingly as it is outside this area.
14.7 The improved M4 provides the motorway with the ability to service higher numbers of vehicles that would otherwise utilise surrounding roads. It would also aid to physically ease transport access and journey times to local businesses. This would maintain the M4 corridor as a continued attractive location for business development in the future with its links to London, Heathrow Airport and the West.
Highways England's Comment
14.7.1 Chapter 14 of the ES (Application Document Reference 6.1) summarises the benefits to arise from the operation of the Scheme. Paragraph 14.4.18 notes that the operation of the Scheme is anticipated to relieve congestion and smooth the flow of traffic along the M4, thereby improving the road network relied upon by local residents and businesses. Improvements in the transport economic efficiency of business users as a result of the Scheme are highlighted in paragraph 14.4.19 of the ES, with a total of 56.7 million vehicle hours anticipated to be saved by business users in the Design Year (2037).
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14.7.2 Paragraph 14.4.21 of the ES states that the Scheme may positively influence decision- making for businesses looking to locate to areas within the sub-region, as it makes a significant and strategic improvement to local infrastructure.
Social impact on residents
14.8 Settlements that will be affected along the M4 corridor in South Bucks District are:
- Dorney
- Dorney Reach
- Burnham
- Richings Park
Highways England's Comment
14.8.1 The assessment methodology set out in paragraph 14.2.7 of the ES makes reference to a study area of 0.5km from the Order limits for an assessment of impacts at the local level, in order to identify facilities that may be directly affected by the Scheme (although it should be noted that where an asset deemed of particular importance has been identified outside this defined study area, this has been included on the basis of professional judgment). The settlements of Dorney and Dorney Reach therefore fall within the 0.5km study area within the link between junction 8/9 and 7 and have been considered in depth. Paragraph 4.5.13 of the Socio-Economic Report (Application Document Reference 7.2) notes that the village of Dorney Reach is located on the eastern bank of the River Thames, with properties along Meadows Way and Oak Stubbs Lane being in closest proximity to the M4. The village of Dorney is located to the south of the Jubilee River. Richings Park is identified as an area of greenspace (including the Richings Park Golf and Country Club) in the vicinity of junction 4b in paragraph 4.8.1 of the Socio-Economic Report (Application Document Reference 7.2). The settlement of Burnham is located to the north of Bath Road and as such is over 0.5km distant from the Order limits. The social impacts on residents of Burnham have therefore not been considered in detail.
14.9 The majority of disruption to residents is likely to take place during the construction phase. This will be in the form of:
- Additional noise and vibration pollution along with decreased air quality. There will also be negative impacts linked to night-time working such as additional lighting.
- Both Dorney and Iver will be impacted by bridge closures, requiring large diversions as a result. This will have a significant effect on school children in Dorney, due to associated
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diversions, and walkers using Old Slade Lane in Iver who will be required to use a substantial 4.1mile long diversion.
Highways England's Comment
14.9.1 Whilst it is acknowledged that there is likely to be some temporary disruption to local residents during the construction phase of the Scheme, through the use of appropriate mitigation measures and a Construction Environmental Management Plan (CEMP), the level of disruption will be minimised as far as possible. Paragraph 1.4.1 of the Outline CEMP in Appendix 4.2A of the ES (Application Document Reference 6.1) notes that the purpose of the CEMP is to set out a series of proposed measures and standards of work that will be applied by Highways England and its contractor throughout the construction period to provide effective planning, management and control during construction of the Scheme with the aim of controlling potential impacts upon people, businesses and the natural and historic environment; and to provide the mechanisms to engage with the local community and their representatives throughout the construction period.
14.9.2 Measures to deal with noise and vibration disturbance throughout the construction works are detailed in Section 12 of the Outline CEMP (Appendix 4.2A of the ES (Application Document Reference 6.1)), which includes the introduction of management and monitoring processes to ensure that the effects of noise and vibration are controlled and that best practice measures are planned and employed during the construction period. Section 6 of the Outline CEMP (Appendix 4.2A of the ES (Application Document Reference 6.1)) identifies measures to be adopted for the management of emissions to the atmosphere during the construction of the Scheme and the control of dust nuisance. Finally, Section 5 of the Outline CEMP (Appendix 4.2A of the ES (Application Document Reference 6.1)) addresses general site management practices that should be employed throughout the works including giving consideration to surrounding receptors in the general operation of the Site. Issues such as night-time working are considered in Section 5.4 of the Outline CEMP (Appendix 4.2A of the ES (Application Document Reference 6.1)) and lighting in paragraphs 5.6.7 and 5.6.8.
14.9.3 Other impacts highlighted within the Local Impact Report relate to bridge closures affecting the settlements of Dorney (from works to both Lake End Road and Marsh Lane) and Iver (from works to Old Slade Lane).
14.9.4 Paragraphs 13.7.16 and 13.7.17 of the ES (Application Document Reference 6.1) describe how Marsh Lane and Lake End Road currently connect Bath Road to the north of the M4 with the villages of Dorney, Eton Wick and Eton to the south of the M4. Both routes provide access to Dorney Lake and Dorney School. Marsh Lane overbridge is proposed to be constructed on-line, with Lake End Road overbridge being constructed off-line to
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maintain a suitable diversion route for users during construction works to Marsh Lane overbridge (anticipated to take 12 months). Paragraph 13.7.18 of the ES (Application Document Reference 6.1) assesses the diversion route as severe, based on journey distance and time criteria. Paragraph 14.8.6 of the ES (Application Document Reference 6.1) notes that, following both public consultation and ongoing consultation with Dorney School, consideration has been given to providing additional mitigation to minimise the impact on pedestrians making use of the Marsh Lane overbridge (including school- children during peak times of day) and further consultation with parents and staff will be necessary (other options could include the provision of a shuttle-bus to transport children from the north of the school catchment area during the bridge works).
14.9.5 Highways England acknowledges that the closure of Old Slade Lane overbridge for on- line replacement will involve the temporary severance of rights of way during construction works, with an associated need to identify alternative routes for non- motorised users. The severance incurred as a result of the diversion route described in paragraph 13.7.21 of the ES (Application Document Reference 6.1) is assessed as severe, with significantly lengthened journey times likely; however, as paragraph 13.7.29 notes, these effects are for a limited duration of around 12 months, whilst the new bridges are under construction.
14.9.6 The approach that will be taken to dealing with effects relating to route closures and diversions is set out in the Outline Construction Environment Management Plan (CEMP) (Appendix 4.2A of the ES) (Application Document Reference 6.3). Paragraph 5.6.1 of the Outline CEMP states that prior to development being undertaken, the contractor will provide method statements to local authorities; paragraph 5.6.2 states that the method statements should include measures for the maintenance of public rights of way for pedestrians, including reasonable adjustments to maintain or achieve inclusive access. Paragraph 13.6.3 of the Outline CEMP (Appendix 4.2A of the ES) (Application Document Reference 6.3) notes that agreement on diversion routes will be required prior to works commencing; and finally paragraph 13.7.2 states in relation to pedestrian and cycle routes in particular, that diversion works will require to be confirmed in consultation with the relevant local authority.
14.9.7 In order to ensure that users of routes will not be put at a disadvantage by the use of diversions, paragraph 4.1.1 of the outline CEMP (Appendix 4.2A of the ES (Application Document Reference 6.1)) notes that a community engagement strategy will be produced by Highways England. The strategy will include procedures to not only maintain effective community engagement throughout the construction period, but to inform affected communities in advance of relevant construction works, including the programming thereof. Paragraph 4.2.1 of the CEMP (Appendix 4.2A of the ES
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(Application Document Reference 6.1)) states that methods identified to communicate matters during construction works include on-line communication, a Scheme newsletter and notification to local residents, businesses and key stakeholders as appropriate, of planned construction works a minimum of two weeks in advance.
14.10 Post construction the main impact on residents will be noise from an increase in motorway traffic. This is especially of concern in Dorney where businesses, schools and homes are located in the near vicinity to the motorway.
Highways England's Comment
14.10.1 Please refer to Highways England’s response to paragraph 14.3 earlier.
Residents of the Burnham and Huntercombe Conservation Area
14.11 The residents of the Burnham and Huntercombe Conservation Area have written to SBDC regarding a number of concerns with the proposal.
14.12 Buildings and land east and north east of Lake End Road bridge are part of the conservation area and therefore as little disturbance as possible should be ensured.
Highways England's Comment
14.12.1 Highways England’s response to paragraphs 14.11 and 14.12 are covered below with the response to paragraph 14.13.
14.13 Although the owners of Abbey House received notification from the Planning Inspectorate that a possible 2 acres of land in the garden would be subject to a compulsory acquisition order, no further communication has been received. For this reason a group has formed to object to any potential land acquisition or disturbance in the vicinity of the bridge. The group have outlined the following issues:
- The land is Green Belt and within a Conservation Area surrounded by listed buildings and is of historical and archaeological significance as part of the original Burnham Abbey Compound
- The land of interest is being used for the keeping of ponies that are for the use of disabled children. The ‘hard standing’ referred to is an Olympic sized horse Manege. It is considered other surrounding sites are more appropriate including farmland and a commercial industrial yard.
- Any storage of vehicles, night time working, lighting, etc in this area would be a great disturbance to all residents of nearby properties, as would parking, caravan sites and porta cabins. The properties in question are: Tithe Barn, Chauntry Cottage, Abbey House, Four
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Elms, The Chauntry, Little Chauntry, Chauntry Barn, Burnham Abbey, The Lodge, and Huntercombe Farmhouse.
Highways England's Comment
14.13.1 Highways England confirms that the owners of Abbey House were contacted in April 2014 regarding a request for land ownership information as part of the land referencing process. The information provided was used to inform and develop the design of the Scheme, resulting in the identification of no requirement for compulsory acquisition powers over this piece of land (Ref. 19201). As such, the owners of the land have been consulted under section 47 (as part of the community consultation), but not under section 42 or section 56.
14.13.2 The only relevant plots in this vicinity are the following (shown on sheet 20 of the Land Plans (Application Document Reference 2.2), none of which impact on the land ownership of Abbey House.
1. Land within the existing highway: 20-14 (permanent powers)
2. Land to the west of the Lake End Road: 20-12 (temporary powers) and 20- 12a, 20-13 (permanent powers)
3. Land to the south of Huntercombe Lane South: 20-17, 20-20 (temporary powers) and 20-15 (permanent powers)
14.13.3 Plots 20-12a, 20-13, 20-14 and 20-15 are identified in the Statement of Reasons as “Land required for the realignment of Lake End Road”.
14.13.4 Plots 20-12, 20-17 and 20-20 are identified in the Statement of Reasons as “Temporary land required for access and working space to construct realigned Lake End Road and new Lake End Road overbridge”
14.13.5 Paragraph 14.4.7 of the ES (Application Document Reference 6.1) states that the right to compensation and methods and procedures for assessing appropriate levels of such will be secured by the Order pursuant to the National Compensation Code. Continued consultation will be undertaken with landowners, occupiers and agents where necessary to manage and reduce impacts on day to day activities as far as possible.
14.13.6 The impact of the Scheme on the Huntercombe Conservation Area is discussed in Section 8.4 above
14.13.7 The Scheme lies in Green Belt land within the South Bucks District Council area. Table 7 of the Planning Statement (Application Document Reference 7.1) states that the
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proposals for the Scheme within the Borough are confined largely to works within the existing carriageway of the M4. The exception to this is the demolition and reconstruction of Marsh Lane, Lake End Road, Huntercombe Spur and Old Slade Lane overbridges. The footprint and physical extent of the motorway therefore remains largely unchanged and for this reason is not considered to adversely affect the character or amenities of the Green Belt.
14.13.8 Paragraph 5.2.149 of the Planning Statement (Application Document Reference 7.1) states that the additional permanent land requirement beyond the boundary of the existing highway represents a demonstrably small increase in the use of greenfield land. Paragraph 5.2.158 of the Planning Statement (Application Document Reference 7.1) notes that the route of the M4 along this section already lies within Green Belt and the Scheme is confined largely to the existing physical boundaries of the motorway. Paragraph 5.2.162 of the Planning Statement (Application Document Reference 7.1) states that for those elements of the Scheme that lie outside the highway boundary within designated Green Belt land (for example rebuilding of overbridges), it is considered that such uses may not be development inappropriate in the Green Belt, as the National Planning Policy Framework (NPPF) paragraph 90 provides that ‘local transport infrastructure which can demonstrate a requirement for a Green Belt location’ can be an acceptable use. An analysis of the impact of the Scheme on the Green Belt was provided in the Planning Statement submitted with the Application and further detail was provided in response to the ExA’s questions on this issue at Deadline II.
14.13.9 A temporary construction compound is proposed to be located within the looped slip road at junction 7. Paragraph 14.4.16 of the ES (Application Document Reference 6.1) notes that construction compounds may have a number of uses, including for the storage of plant and materials, batching, housing local link offices or staff accommodation and for the temporary storage of spoil and waste. The bulk of traffic movements to and from compounds is likely to take place during the day. However, some HGV movements will be necessary during the night to support specific night time activities that require full or significant occupation of the existing M4 carriageway, such as bridge works, girder erection for gantries, carriageway re-surfacing and white lining.
14.13.10 Paragraph 14.9.32 of the ES notes that the site at junction 7 is currently disused and as a result the use of the site as a construction compound is not considered to have a long-term effect on future use of the land; paragraph 14.9.33 of the ES states that the use of the site as a construction compound constitutes a temporary slight adverse effect on local residents within close proximity to the compound, notably residential properties along Westpoint and Lake End Road.
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14.13.11 Paragraph 8.2.10 of the Engineering and Design Report (Application Document Reference 7.3) states that the CEMP will be in place prior to the construction works commencing, which will ensure that appropriate management processes are in place during Scheme construction.
14.14 The questions raised by the residents can be found in Appendix X
Highways England's Comment
14.14.1 The questions raised by the Burnham and Huntercombe Conservation Area group are listed and addressed in the table below.
Question Highways England’s Response Where will the access points to The parcel of land that has prompted the convening of the Burnham and the site be? Huntercombe Conservation Area group is required on a temporary basis as part of the rebuilding off-line of Lake End Road overbridge to the west of the existing bridge. Construction details will be determined at the detail design stage of the Scheme and the development.
What alterations will be made to The Scheme has no building or alteration works planned to this site and the site and what buildings or no construction works will be on it. constructions will be on it?
How long will the site be in use Paragraph 13.7.17 of the ES (Application Document Reference 6.1) for? states that Lake End Road overbridge is proposed to be constructed within a twelve month period.
What will be the hours and days Patagraph 4.8.1 of the final Construction Environmental Management of operation, and what is the Plan (CRMP) states “Core working hours will be from 08:00 to 19:00 approximate start date? on weekdays (excluding bank holidays) and from 07:00 to 16:00 on Saturdays. The Contractor will adhere to the core working hours for each site as far as is reasonably practicable.” The CEMP further states at paragraph 4.8.6 “Certain other specific construction activities will require extended working hours for reasons of engineering or environmental practicability. These activities include, but are not limited to surveys, e.g. for wildlife or engineering purposes which may need to be carried out outside of core working hours although given the nature of these works it is considered unlikely that they would affect surrounding receptors materially”
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Question Highways England’s Response What are the anticipated noise and Paragraphs 12.4.32 to 12.4.87 of the ES (Application Document vibration levels? Reference 6-1) and Appendix 12.3 of the ES (Application Document Reference 6-3) address construction noise and vibration effects. Drawing 12.1 (Application Document Reference 6-2) shows the representative construction noise receptors employed in the assessment. Sheet 10 is relevant to this area, with receptors CROB-9 and CNR-32 lying within Huntercombe Conservation Area.
The assessment of construction noise levels is based on a comparison of the predicted noise levels for the various construction activities and the prevailing noise levels at the receptors.
For the mainline works (i.e. works on the carriageways and hard shoulders), the noise impacts to receptor CROB-9 are assessed as follows (see Tables A12.3.1 and A12.3.2 in Appendix 12.3 of the ES for the definition of impacts):
Daytime: Negligible Impact
Evening: Negligible Impact
Night-time: Minor Impact
The significance of these noise impacts is assessed as Slight Adverse.
For the mainline works (i.e. works on the carriageways and hard shoulders), the noise impacts to receptor CNR-32 are assessed as follows:
Daytime: Negligible Impact
Evening: Negligible Impact
Night-time: Negligible Impact
The significance of these noise impacts is assessed as Slight Adverse.
The bridge works at Lake End Road will comprise removal of the existing bridge structure over the motorway, demolition of the existing bridge approaches and abutments, construction of the new bridge approaches and abutments and installation of the new bridge structure
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Question Highways England’s Response over the motorway. By necessity, bridge removal and bridge installation will have to be carried out at night, so that the motorway can be closed for safety reasons.
With respect to the demolition of the existing bridge and the construction of the new bridge at Lake End Road, noise impacts to receptor CROB-9 are assessed as follows:
Daytime: Negligible Impact
Evening: Negligible Impact
Night-time: Minor Impact
The significance of these noise impacts is assessed as Slight Adverse.
The corresponding noise impacts at receptor CNR-32 are Negligible for daytime, evening and night-time. The significance of these noise impacts is assessed as Slight Adverse.
With respect to ground borne vibration resulting from works on the mainline (i.e. works on the carriageways and hard shoulders), the majority of the plant to be employed are not sources of significant ground borne vibration. However, sheet piling will be carried out at some locations and vibratory rollers will be employed for ground compaction. Stand-off distances to maintain vibration impacts at negligible / minor levels are provided in Tables 12.13 and 12.14 in Chapter 12 of the ES. Receptors CROB-9 and CNR-32 are outside these stand-off distances and the significance of this effect is assessed as Slight Adverse for both annoyance and cosmetic building damage.
With respect to ground borne vibration resulting from works on Lake End Road Bridge, the intention is that rotary bored piling will be used. This results in significantly lower vibration levels than impact piling. As reported in paragraphs 12.4.77 to 12.4.79 of Chapter 12 of the ES, vibration impacts at a distance of 30 metres from the piling works will be negligible, resulting in a Slight Adverse effect. Receptors CROB-9 and CNR-32 are at greater distances than 30 metres from the piling works. Hence, the vibration effects will be Slight Adverse.
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Question Highways England’s Response With regard to operational effects, between junctions 8/9 and 7, the noise assessment for this section of the Scheme states that overall the magnitude of impact is minor beneficial in the short term and negligible in the long term, with the significance of effect of the operation of the Scheme (i.e. excluding construction) in this location assessed as slight beneficial in the short term and neutral in the long term (paragraph 12.8.15 of the ES (Application Document Reference 6-1)). This is mainly a consequence of the provision of low-noise surfacing (a Thin Surface Course System) across all lanes along the complete Scheme length (paragraph 12.2.49 of the ES (Application Document Reference 6-1) and Chapter 7 of the Engineering and Design Report (Application Document Reference 7-3)).
Will there be an archaeological Paragraph 7.8.16 of the ES (Application Document Reference 6.1) states survey of the site before use? that there is potential for the Scheme to cause direct physical impacts to currently unknown archaeological remains and that if any works are likely to disturb previously un-excavated ground, archaeological watching briefs will be undertaken during topsoil stripping and excavations.
The outline CEMP (Appendix 4.2A of the ES (Application Document Reference 6.1)) sets out in further detail general management measures for cultural heritage assets.
Will the site be screened, and if The Outline CEMP (Appendix 4.2A of the ES (Application Document so, how? Reference 6.1) notes that the final CEMP will be required to include specific measures to reduce the impacts of the construction works at particular locations. In particular, measures will be included to minimise visual intrusion.
Will the site be lit at night and Section 5 of the Outline CEMP (Appendix 4.2A of the ES (Application have security? Document Reference 6.1)) addresses general site management practices that should be employed throughout the works including giving consideration to surrounding receptors in the general operation of the Site, including lighting.
What measures will be taken to Section 5 of the Outline CEMP (Appendix 4.2A of the ES (Application keep the surrounding roads clear Document Reference 6.1)) addresses general site management practices that should be employed throughout the works including giving
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Question Highways England’s Response of mud consideration to surrounding receptors in the general operation of the Site, including cleaning of construction vehicles. Paragraph 13.3.4 of the CEMP specifically addresses the issue of mud.
After completion of the M4 work After completion of the construction works, land required for temporary will the site be decommissioned purposes will be returned to its original use. and reinstated as green belt
Will the land be sold on After completion of the construction works, land required for temporary completion of the work, and if so, purposes will be returned to its original use and owner. what will be the sale process and future usage or will it be offered back to the current owners at the forced sale price?
Is Lake End Road bridge to be The Engineering and Design Report (Application Document Reference demolished and rebuilt only, or is 7.3) outlines the proposed construction works for the Lake End and a second bridge to be built? Marsh Lane overbridges. It is proposed to reconstruct Lake End Road overbridge off-line, and the Marsh Lane overbridge on-line. The construction sequence as described in paragraph 7.5.38 of the Engineering and Design Report (Application Document Reference 7.3) is as follows:
the new Lake End Road overbridge will be constructed to the west of the existing bridge;
the old Lake End Road overbridge will be demolished;
traffic will then be diverted from Marsh Lane to the new Lake End Road overbridge whilst the Marsh Lane Road overbridge is demolished and reconstructed.
The properties, trees and Plot 20-02 is required on a temporary basis and will be returned to its landscape near the bridge will be current state at the end of the construction period. Paragraph 14.4.7 of blighted. the ES (Application Document Reference 6.1) states that the right to compensation and methods and procedures for assessing appropriate
levels of such will be secured by the Order pursuant to the National Compensation Code. Continued consultation will be undertaken with landowners, occupiers and agents where necessary to manage and reduce
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Question Highways England’s Response impacts on day to day activities as far as possible.
With regard to the proposed Paragraph 8.3.1 of the Engineering and Design Report (Application widening, which seems to be a Document Reference 7.3) notes that the overall works programme is fait accompli, speedy completion planned over a five year period. However, this will be divided into two is requested, as the suggested ten sections. Work is planned to start in late 2016. Until early 2019, year works will blight our lives receptors near junction 8/9 to 3 will not experience disturbance and similarly there will be no disturbance for receptors near junction 12 to 8/9 from late 2018 onwards as those works are complete (paragraph 8.3.7 of the Engineering and design report (Application Document Reference 7.3)).
The overall construction programme for the whole Scheme Paragraph 13.7.17 of the ES (Application Document Reference 6.1) states that Lake End Road overbridge is proposed to be constructed within a twelve month period.
The only benefit will be “quiet” It is correct that mitigation is proposed for the Scheme in the form of low tarmac, as the requested noise noise surfacing across all lanes, along the complete extent of the barriers are not now proposed. Scheme. However a number of new noise barriers will also be provided From experience of the M40, J2 as part of the Scheme proposals to mitigate noise impacts. The heights the quiet tarmac deteriorates with and extents of these barriers are defined in Table A12.2.1 of Appendix time, and more so with road 12.2 of the ES (Application Document Reference 6-3). No additional repairs. Are we expected to pay noise barriers are proposed to the E/B carriageway of the Scheme for noise barriers ourselves to between Lake End Road and Junction 7. benefit the neighbourhood, and The noise and vibration assessment, as reported in Chapter 12 of the ES, especially Burnham Abbey? is for the Scheme with the above mitigation in place. The vast majority of the Scheme corridor will experience negligible or minor reductions in noise levels with the Scheme in operation (see paragraph 12.4.110 of the ES).
These noise reductions are shown in Drawing 12.4 for the short term, and in Drawing 12.5 for the long term (Application Document Reference 6-2). Sheet 10 is relevant to Huntercombe Conservation Area. The negligible / minor noise reductions across the Conservation Area in the short term are evident. Where there are negligible noise increases to some parts of the Conservation Area in the long term, these are due to changes in traffic flows on Lake End Road and Huntercombe Lane
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Question Highways England’s Response South. These changes would occur even if the Scheme did not go ahead, as can be seen from Sheet 10 of Drawing 12.3 of the ES (Application Document Reference 6-2), which shows the long term changes in noise levels without the Scheme.
Regarding the acoustic performance of low noise surfacing, all road surface types degrade over time, with consequent increases in tyre/road noise. Research has indicated that, when new, low noise surfaces provided on average between 4 and 6 dB(A) benefit over tested hot road asphalt (“HRA”) surfaces. In spite of the better acoustic durability of the HRA surfaces, low noise surfaces still outperformed the HRA surfaces by 1 to 3 dB(A) after 10 years. The -3.5 dB correction employed for a low noise surface in the noise assessment, as prescribed in Design Manual for Roads and Bridges (“DMRB”), is a reasonable average over the life of the surface for calculation and assessment purposes.
14.15 There is potential for vibration to affect the wall at Burnham Abbey. It is expected that the scheme will have an adverse effect on the Abbey which is a convent for nuns. Previous works on the motorway have proven the noise to be very intrusive at the Abbey, a place that runs ‘Quiet Days’. There is a potential for this to reduce visitor numbers and therefore income to the Abbey.
Highways England's Comment
14.15.1 The presence of Burnham Abbey as an Anglican retreat is noted in paragraph 4.5.15 of the Socio-Economic Report (Application Document Reference 7.2). Paragraph 7.8.21 of the ES (Application Document Reference 6.1) states that there is no inter-visibility between the Abbey and the construction works and that, given the distance to the works, the construction activities are not expected to affect the setting of the Abbey. Construction noise levels will vary during the construction phase according to the schedule of works, and will tend to be more noticeable during the evening than the daytime, due to the lower ambient noise levels. Estimates of construction noise for the Huntercombe Manor Hospital north of Burnham Abbey suggest that construction noise levels may be negligible to slight during the daytime and negligible to moderate during the evening – see the results for CNR-32 in Tables A12.3.12 and A12.3.13 in Appendix 12.3 to the ES (Application Document Reference 6.3) for the short period of time that construction takes place in this area.
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14.15.2 Construction works in relation to Lake End Road overbridge are anticipated to last no more than twelve months, thus any impact in relation to amenity (noise, disturbance) are temporary in nature.
Severance
14.16 Overall the scheme will not have a major impact on the South Bucks District in terms of severance. The issue is only prevalent during the construction phase with works on the bridges within South Bucks. This will cause major disruption within Dorney as well as the Colne Valley as Marsh Lane and Old Slade Lane bridges are closed. Although a solution of building Lake End Road bridge offline solves the issue in Dorney, the closure at Old Slade Lane requires a diversion of over 4 miles.
Highways England's Comment
14.16.1 The issue of severance in relation to construction works at Marsh Lane, Lake End Road and Old Slade Lane overbridges has been discussed in paragraphs 14.9.3 to 14.9.7 of this response and in row 12 of the table at paragraph 4.14.1.
Summary
14.17 This section has considered the different types of impact on communities and businesses within the study area of South Bucks.
14.18 The evidence suggests that the majority of disruption from the proposal will be experienced in the construction phase with the associated noise, lighting, vibration and traffic impacts. After the completion of the scheme there is the potential for the increase in motorway capacity reducing the burden on the local roads which will help local businesses and residents. It is expected that Highways England will return the acquired land back to how it was meaning that the long term impacts are likely to be based on noise, air quality and vibration.
Highways England's Comment
14.18.1 The conclusions set out in Chapter 17 of the ES (Application Document Reference 6.1) include that on Scheme opening (2022), the improvements to journey times and reliability are assessed as being of large benefit for local businesses, residents and visitors.
14.18.2 Paragraph 17.3.6 of the ES (Application Document Reference 6.1) states that the overall effect of the Scheme on air quality during both construction and operation is assessed as not significant.
14.18.3 Land acquired on a temporary basis will be returned to its former use.
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14.18.4 As stated in paragraph 14.10.1 of this response, the findings of the noise and vibration assessment (Chapter 12 of the ES (Application Document Reference 6.1) are that, overall, the majority of receptors experience a negligible or minor decrease in traffic noise levels in the short-term (paragraph 12.4.92). The assessment of the long-term change in traffic noise levels shows that, again, the majority of residential properties experience a negligible decrease in traffic noise levels (paragraph 12.4.94 of the ES (Application Document Reference 6.1)). This is a consequence of the assumption of a low-noise surfacing (a Thin Surface Course System) across all lanes along the complete Scheme length (paragraph 12.2.49 of the ES (Application Document Reference 6.1) and Chapter 7 of the Engineering and Design Report (Application Document Reference 7.3)). The village of Dorney is located between junction 8/9 and 7; the noise assessment for this section of the Scheme states that, overall the magnitude of impact is minor beneficial in the short term and negligible in the long term, with the significance of effect of the operation of the Scheme in this location assessed as slight beneficial in the short term and neutral in the long term (paragraph 12.8.15 of the ES (Application Document Reference 6.1)).
15. CUMULATIVE IMPACT FROM OTHER NATIONALLY SIGNIFICANT INFRASTRUCTURE PROJECTS
15.1 The M4 Smart Motorway proposal is not the only NSIP that is expected to impact on the South Bucks District. There are a number of projects that are planned for the Iver area and there is concern over how this will impact local traffic. A wider plan needs to be put in place for how these projects will be planned to reduce the impact on the region. Figure 19 shows the locations of these proposals.
15.1.1 The list of cumulative developments considered is presented in Table A16.2.1 of Appendix 16.2 of the Environmental Statement (ES) (Application Document Reference 6- 3). The list was compiled from details provided by local planning authorities and / or published local plans. The assessment was undertaken in accordance with DMRB, Volume 11, Section 2, Part 5 and included all reasonably foreseeable developments (see Chapter 16.1 of the ES). With reference to DMRB Volume 11, Section 2, Part 5 (HA 205/08) ‘reasonably foreseeable’ is interpreted to include other projects that are ‘committed’. These should include but will not necessarily be limited to (i) Trunk road and motorway projects which have been confirmed (i.e. gone through the statutory processes), and (ii) Development projects with valid planning permissions as granted by the Local Planning Authority, and for which formal EIA is a requirement or for which non-statutory environmental impact assessment has been undertaken. In addition, this assessment has also considered applications for consent which have been made, but which have not yet been granted.
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Crossrail
15.2 Expected to be completed by 2019 this project involves the updating of the Rail line to support the new electrified service.
Highways England's Comment
15.2.1 Construction of Crossrail is ongoing and the scheme has been included within the transport model to ensure its effects on traffic forecasts are taken into account as part of the cumulative assessment.
Heathrow Airport
15.3 It has been recommended that the North West Runway proposal would be most suitable to meet aviation needs in the South East. This is not yet confirmed however and there are still areas within South Bucks that have been proposed for various infrastructure works in connection with the new runway.
Highways England's Comment
15.3.1 The recommendations of the Airports Commission concerning a possible third runway at Heathrow are under consideration by the Government, and no application for consent to construct the proposals has been made. Heathrow is one of two locations where additional airport capacity was considered and as such, pending a decision by the Government, it cannot be regarded as committed. As such, the proposal is not considered to be reasonably foreseeable and so was not included within the cumulative impact assessment for the Scheme. Any application for the construction of the third runway, and any connection applications such as for the relocation of the Energy from Waste Plant, will be required to take the "committed" M4 improvement Scheme into account when assessing the impact of their proposals, rather than the reverse.
Western Rail Access to Heathrow
15.4 A new link to Heathrow is planned from Langley Station. This will involve a tunnel that passes under the M4 and is planned to be completed by 2021. This will coincide with the M4 proposal and will require a large volume of HGV movement within South Bucks.
Highways England's Comment
15.4.1 The Western Rail Link to Heathrow proposal was announced on 05/02/2014 following consideration of four options by Network Rail. At the time the assessment for the Scheme was undertaken, the proposal was at “early stages of development” following its inclusion in the Route Utilisation Strategies published in March 2010. As such, it was not at a
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sufficiently developed stage to be included in the cumulative assessment for the Scheme, and did not come within the guidelines set out in DMRB for those committed, reasonable foreseeable developments that should be included in the assessment. It is understood an application may be brought forward in due course. Any application for the construction of the Western Rail Link will be required to take the M4 improvement scheme into account when assessing the effect of their proposals, rather than the reverse.
Heathrow Express Sidings
15.5 The HS2 proposal (an additional provision published in July 2015 to the Hybrid Bill) requires the relocation of the current Heathrow Express Sidings from Old Oak Common. Langley is the preferred alternative and is required to be completed by 2019. It is anticipated that this development will require at least 500 daily HGV movements during construction and the preferred route for these vehicles has not yet been confirmed.
Highways England's Comment
15.5.1 Similarly, as the requirement to relocate the Heathrow Express depot is dependent on the HS2 Bill receiving Royal Assent and as such, without such approval, it cannot be regarded as committed. However, the sidings site is identified in the local development framework for the London Borough of Hammersmith and Fulham as a site for employment and potentially some element of residential use. Accordingly, it was included in the development sites assessed within the traffic model.
Other Projects near Iver
15.6 The Slough International Freight Exchange (SIFE) has been proposed on the land to the South of the stretch of M4 bordering Iver. Although it is not situated in the South Bucks District, its proximity has the potential to add to HGV traffic in the Iver area. With the site proposed to occupy the same area as the potential Heathrow Expansion, the development of this scheme is subject to the Airport expansion not going ahead.
Highways England's Comment
15.6.1 An application to construct S.I.F.E. was refused by Slough Borough Council on the 8th September 2011. Accordingly it was excluded from the developments used as part of the traffic forecasting process for the Scheme. The proposal is to be the subject of a planning inquiry that commenced in September 2015.
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16. CONCLUSIONS
16.1 This report has been produced by SBDC and BCC and considers the impact of the proposed M4 widening between junctions 3-12 scheme on the SBDC area.
16.2 This report has been prepared in accordance with advice and requirements as set out in the Planning Act 2008, the Localism Act 2011 and the National Policy Statement for National Networks.
16.3 Highways England intends to widen the M4 between junctions 3 to 12 by creating a Smart Motorway. The scheme is set to take place within the M4 boundary with the focus being on the conversion of the Hard Shoulder to a running lane. The main disruption within South Bucks will therefore be due to road closures during the construction phase and the potential for increased noise, air and vibration pollution once the scheme is running.
16.4 There are 4 bridges being replaced as part of the scheme in the South Bucks area:
- Thames Bray
- Marsh Lane
- Lake End Road
- Old Slade Lane
All will have a local impact on pedestrians, cyclists and motorists during construction as diversions are put in place. Some of the diversions will have an impact for up to a year which will cause inconvenience.
Highways England's Comment
16.5 Highways England acknowledges that replacement of these bridges will have some local impact on pedestrians, cyclists and motorists during construction. Responses to impacts raised in Section 13 of this Local Impact Report detail how these impacts will be addressed. Additionally a number of local roads would be affected during construction, namely Bath Road (A4), the A355, Richings Way, Old Slade Lane, Marsh lane, Lake End Road, Huntercombe Road South and the Huntercombe Bypass. Additional congestion may also be experienced particularly on the A4 and through Iver up to the M40 Junction 1 as displaced traffic finds alternative routes. The cumulative impacts of construction traffic will be particularly noticeable in the Iver area as other major infrastructure projects are constructed to a similar timetable.
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Highways England's Comment
16.6 The traffic management plan will be prepared prior to commencing the construction of the works. The CTMP will include assessment of the impact to the local network and the effect of other nearby infrastructure projects. This assessment will form part of the consideration process for identifying diversion routes. During the drafting, of the CTMP, consultation with all stakeholders will be undertaken SBDC is generally supportive of the scheme as it will improve strategic access to London and the M25 from the West and thus will relieve pressure on local roads. However SBDC have some concerns over the impact on the local road network that the new road may have, that as yet have not been resolved. These are identified in the full report and Statement of Common Ground. Updates on these issues will be provided throughout the examination stage.
Highways England's Comment
16.6.1 Highways England welcomes South Bucks District Council’s general support for the Scheme and acknowledges the Council has concerns over the impact on the local road network that the Scheme may have. Highways England will continue to consult with both South Bucks District Council and Buckinghamshire County Council on their respective Statements of Common Ground to resolve as many of these issues and concerns as possible
16.7 The Environmental Statement indicates minimal impact to the local roads once the scheme is constructed with the focus being on supporting predicted future travel demands. The use of low-noise surfacing is deemed to be the only required mitigation measure in the district with the impact on vibration and air quality being anticipated to be minimal by HE. The Council is still of the opinion that noise barriers may be required to protect nearby residents from traffic noise.
Highways England's Comment
16.7.1 The proposed mitigation for the Scheme comprises low noise surfacing across all lanes, along the complete extent of the Scheme, and a number of new noise barriers, the heights and extents of which are defined in Table A12.2.1 of Appendix 12.2 of the ES (Application Document Reference 6.3). Existing noise barriers will be retained or replaced like for like i if in poor condition. The heights and extents of existing noise barriers are defined in Table A12.1.1 of Appendix 12.1 of the ES (Application Document Reference 6.3).
16.7.2 The locations and extents of existing noise barriers and the new noise barriers are provided in Drawing 12.2 of the ES (Application Document Reference 6.2).
16.7.3 Following consultation with London Borough of Hillingdon and South Bucks District Council post DCO submission, a revised Drawing 12.2 and revised Tables A12.1.1 and
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A12.2.1 were provided in response to Question E4.7.18 of the Examining Authority’s first written questions. The revised drawing and tables incorporated revisions relating to the noise barriers to Hillingdon and to Dorney Reach, and the minor corrections as submitted in response to the Examining Authority’s Rule 6 Letter.
16.7.4 The noise and vibration assessment, as reported in Chapter 12 of the ES (Application Document Reference 6.1), is for the Scheme with the above mitigation in place. The magnitude of impact for the Scheme is minor beneficial in the short term and negligible in the long term. The significance of effect during the operation of the Scheme is assessed as slight beneficial in the short term and neutral in the long term, with the vast majority of the Scheme corridor experiencing negligible or minor reductions in noise levels with the Scheme in operation (see paragraph 12.4.110 of the ES) (Application Document Reference 6.1).
16.7.5 These noise reductions are shown in Drawing 12.4 for the short term, and in Drawing 12.5 for the long term (Application Document Reference 6.2). Sheets 10, 13 and 14 are relevant to the South Bucks District Council area. The reductions in noise levels with the Scheme in operation are evident.
16.7.6 It is noted in paragraph 12.4.112 of the ES (Application Document Reference 6.1) that there is potential to further improve the noise climate within the Scheme corridor through enhanced mitigation. A qualitative appraisal of an enhanced mitigation strategy to achieve this is provided in Appendix 12.5 of the ES (Application Document Reference 6.3). This enhanced mitigation strategy comprises the provision of additional noise barriers, as outlined in Table A12.5.1 of Appendix 12.5 of the ES (Application Document Reference 6.3) and the replacement of some existing noise barriers with higher noise barriers as outlined in Table A12.5.2 of Appendix 12.5 of the ES (Application Document Reference 6.3).
16.7.7 The possible replacement of existing barriers and the possible provision of new barriers to the eastbound and westbound carriageways between Junction 7 and Junction 8/9 in the South Bucks District Council area form part of this enhanced mitigation study.
16.7.8 The effects of implementing this enhanced mitigation strategy have not been assessed in Chapter 12 of the ES (Application Document Reference 6.1). Hence, the assessment provided in Chapter 12 of the ES (which concludes that the vast majority of the Scheme corridor will experience noise reductions with the Scheme in operation) is very much a worst case.
16.7.9 Work is ongoing to provide a quantitative assessment of the enhanced mitigation strategy outlined in Appendix 12.5 of the ES (Application Document Reference 6.3). This
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comprises an iterative process which is employed to estimate the numbers of receptors experiencing specific reductions in noise levels (for an additional noise barrier, as detailed in Table A12.5.1 of Appendix 12.5 of the ES (Application Document Reference 6.3), or replacement of an existing barrier, as detailed in Table A12.5.2 of Appendix 12.5 (Application Document Reference 6.3)), monetising the benefits of these reductions in noise levels (as employed in TAG appraisal) and comparing this monetisation value with the cost of the mitigation to provide a cost benefit analysis. Thus, the lengths and heights of new barriers (if specified), and the heights of replacement barriers (if specified), will be optimised. The results of that assessment, and the results of the assessment of the landscape and visual impact of any additional noise barriers proposed, will be provided to the Examination in due course.
16.8 The designs of the new bridges are anticipated to be standardised low maintenance constructions. SBDC understand this to be non-negotiable.
Highways England's Comment
16.8.1 The massing, cross section and elevation details of the proposed replacement bridges are as indicated in the Engineering and Design Report (“EDR”) (Application Document Reference 7-3). The detail design of bridges would be developed in consultation with the Local Authority, whist remaining inside the parameters of the approved plans.
At the time of writing detailed information was not available for the construction process as the contractor has only just been appointed. Further detail of the process is therefore still being awaited by SBDC and BCC.
Highways England's Comment
16.8.2 Further detail of the construction process will be available following the detail construction planning phase and the completion of the design.
16.9 There are potential issues concerning heritage sites that have been mentioned in this report. The development involves construction very close to listed buildings and conservation areas.
Highways England's Comment
16.9.1 Chapter 7 of the ES (Application Document Reference 6.1) has considered impacts to listed building buildings and conservation areas during the Scheme construction phase. No direct physical impacts to these assets have been identified during the construction phase. No increases in noise level above 3dB or deterioration in air quality are associated with these assets and no adverse impacts to their settings are anticipated in relation to noise or air quality. For those heritage assets located within the Scheme’s Zone of Visual
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Influence (“ZVI”), the significance of effect in relation to the construction phase is predicted to range from neutral to slight adverse. No mitigation measures are considered necessary as any visual intrusion is considered to be very limited.
16.10 There is a risk of damage to protected ecological areas, with some trees being protected by a TPO.
Highways England's Comment
16.10.1 There is a requirement in the Outline Construction Environmental Management Plan (Appendix 4.2A of the ES) (Application Document Reference 6.3) that the Contractor must protect the adjacent trees to be retained throughout the construction phase, in accordance with BS5387. In the event that protected trees at these locations are affected by the Scheme, mitigation measures will be discussed with the Local Planning Authority.
16.11 There will be disruption of national trails within the Colne Valley Park.
Highways England's Comment
16.12 Highways England acknowledges that there will be disruption of national trails within the Colne Valley Park during construction. Responses to points raised in Section 9 of this Local Impact Report detail how this disruption will be addressed.There is some concern over what happens to the land that has been subject to a compulsory acquisition order after use.
Highways England's Comment
16.12.1 Any land acquired on a temporary basis will be returned to its original owner in its original state at the end of the construction period. Paragraph 14.4.7 of the ES (Application Document Reference 6.1) states that the right to compensation and methods and procedures for assessing appropriate levels of such will be secured by the Order pursuant to the National Compensation Code. Continued consultation will be undertaken with landowners, occupiers and agents where necessary to manage and reduce impacts on day to day activities as far as possible.
16.12.2 Any land acquired permanently will fall under the ownership of the Scheme and will from then onwards be managed by Highways England accordingly.
16.13 It is anticipated that the scheme will have a beneficial impact on the local economy and commuting once completed.
Highways England's Comment
16.13.1 Overall, the Scheme will provide net benefits to the community. The Scheme has been appraised over a range of economic, environmental and social impacts, the results of
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which are summarised and presented in an Appraisal Summary Table that forms Appendix 2 to the Socio-Economic Report (Application Document Reference . 7-2).
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Appendix
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Karen Jones Our Ref: By email to Contact : Jane Griffin [email protected] Direct Dial : 01895 837315 E-Mail: [email protected] Switchboard: 01895 837200 Date:9th September 2014
Dear Karen
Scoping consultation for M4 Junctions 3-12: Smart Motorway
South Bucks District Council is directly affected by the proposal. The District borders the M4 in two locations – in the east of the District near Richings Park and to the west of the District in the Taplow, Burnham and Dorney areas.
Contrary to para 4.1.1 of the scoping report this District has never been consulted. Although we believe that Bucks County Council has been. Hence as no information has been provided by the District we are not confident that the evidence included in the scoping report includes evidence collected in a sufficient and robust manner.-
Our main concerns are with regard to noise and air quality impacts. .
The District already suffers significantly from noise. Richings Park currently records ambient noise levels of 62dB LA eq (recorded by Heathrow Airport Ltd). Widening the motorway to accommodate more traffic is likely to make this worse. It is likely that our other communities such as Dorney Reach and Lake End, which are similarly close to the motorway will be equally affected.
In terms of Air Quality the scoping report does mention the Air Quality Management Area for the District but in a small District which has the M25, M4 and M40 passing through, the air quality can only get worse. This is having an adverse effect on the biodiversity of the District and in particular on Burnham Beeches SAC (2km north of the M4) which is not mentioned in any of the documentation. There is substantial evidence that the beech trees within the SAC area are being adversely impacted by the deterioration in air quality. It is difficult to see how this could be mitigated.
In addition it is considered that the Scoping Report should mention other transport schemes such as Western Rail Access to Heathrow which will tunnel under the M4 at Richings Park and the potential for the HS2 Heathrow Spur if Heathrow expansion is approved.
Other sites that may be noteworthy but do not appear to have been included are the redevelopment of Taplow Mill which will provide 250 new homes (application recently submitted based on adopted SPD) and the Historic Park of Burnham Abbey adjacent to the spur road.
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Yours faithfully
Jane Griffin Principal Planning Officer – Planning Policy
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Response to the M4 Junctions 3 – 12 smart motorway proposal
The Council has a number of objections/concerns:-
The construction implications for the local area and how these will be mitigated as well as ensuring that aftercare measures are carried through. In particular, there is the potential for the works in the Dorney area to increase congestion on the A4 to the detriment of residents and businesses and to the free flow of traffic on this strategic route. The Thames and Jubilee Rivers and associated footpaths must receive minimal disruption.
The three pieces of land owned by the Council identified for temporary construction use. These form part of the River Thames tow path; part of the playing field at Dorney School and the access track to Dorney Village Hall. These land takes will greatly reduce accessibility in the area, especially to the car park at Dorney Village Hall. The land including roads and paths should be left in an appropriate state post use.
The final details of the construction methods and compound sites. Once a contractor is appointed, more detail on the works is needed.
The impact on the closure of Old Slade Lane, Iver. The Colne Valley Way is a major North-South recreational route with no safe alternatives. There will be a negative impact on the Colne Valley Regional Park. A solution is needed – a temporary bridge or an offline solution. It is of concern that neither measurements of existing uses nor the potential impact of this bridge closure have been carried out.
The areas of trees covered by TPOs to be removed. A clear indication of how many will be lost and how this will be mitigated is needed. This is along with mitigation and replanting for any other tree loss as a consequence of the development.
The use of local roads while bridge works take place. Local impacts should be assessed, avoid long term inconvenience and disturbance, and be discussed with the relevant Parishes.
The local scale impacts on residents. The low-noise surfacing is welcomed by the Council but we would like to meet with the Contractor at an early stage to discuss potential local scale impacts.
An unacceptable increase in HGVs on local roads. Cumulatively with other schemes (Western Rail Link to Heathrow, HS2 Heathrow Express Sidings, potential third runway at Heathrow) the proposals would involve high levels of HGV movements.
The potential for night works. A section 61 Control of Pollutions Act Application should be submitted prior to works if this is required.
The impact on Air Quality and Dust. The works are within South Buck’s AQMA so low emissions policies should be adopted to limit impacts.
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The associated change in NOx and Particulates. The developer is encouraged to seek innovative solutions to reduce the levels of pollutants.
The control of dust, mud and spoil. Management should be coordinated to ensure that there is no negative cumulative effect.
The impact on drainage. This needs to be discussed with our Lead Local Flood Authority, Buckinghamshire County Council.
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BCC response to the M4 Junctions 3 – 12 smart motorway proposal
Highways/construction/compounds
• Modelling reports, including validation report required.
• Works to Marsh Lane and Lake End Road bridges to be undertaken during the same period. Marsh Lane to not close until Lake End Road is completed - likely to be extensive traffic management.
• Define limits of responsibility for structures and services.
• How will localised bridge sites be accessed and construction routes implemented?
• Further develop mitigation packages e.g. the impact on severance in closing Old Slade Bridge over 12 months is considered to be severe however no mitigation has been put forward.
• Clarify 2018 construction period traffic displacement, particularly in relation to the A4 and A355. Impact on local network?
• Construction TMP to address issues pertaining to local highway network within Buckinghamshire, including haul road, vehicle routing, preferred diversion routes.
• Compound 9 concerns; routing agreement is required so that vehicles do not use Sutton Lane; instead access/egress compound via A4.
• To account/assess the impact of HS2, WRATH, other committed developments.
Ecology – fundamental need to mitigate impacts associated with drainage, biodiversity and landscape design, in particular to address:
• Linear connectivity of sites as a strategic green corridor for wildlife, in relation to the protection of bat flying routes, pollinators and associated habitats in landscaping and design. e.g. green bridges.
• Mitigate impacts during construction and in design of scheme around lighting –bats and invertebrates.
Public Rights of Way
• River Thames Bridge - Cycleway/footpath, Sustrans and BCC wish to see cycle route retained and width improved to 3m. Include on definitive map.
• Thames Path National Trail - width should be maintained and improved upon. Full closures should be kept short with convenient diversions.
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• Old Slade Lane - Bridge must be suitable for walkers/cyclists/horseriders with equestrian compliant parapets (at least bridleway status). Seeking formal designation to bridleway up to point maintained at public expense in Bucks to bridleway in Slough. Ensure access is maintained while new bridge is being built.
Floodwater management/drainage
• Sustainable drainage to be considered instead of conventional drainage - instead of soakaways use swales, SuDs, for fluvial and surface water runoff; the width/length of culverts to not restrict or decrease existing natural flow; discharge into existing water courses.
• Maintenance plan to set out how/when to maintain the full drainage system, following construction with details of responsibility.
• Use updated flood maps for surface water to assess areas at risk with hard standing.
Minerals and Waste
• Inaccurate appraisal of landfill capacity in Buckinghamshire. Note BCC is preparing a Waste Capacity Study for 2015.
• ES should identify total requirement for aggregate- break down into different types, timings, locations.
• ES could indicate whether aggregate quarries within Buckinghamshire are to supply aggregates.
• Confirm likely aggregate demand on Buckinghamshire
• Provide draft waste management plans for waste streams arising.
• Scheme should achieve a rate of reuse and recycling equivalent to Cross Rail making the greatest use of potential wastes.
Willingness to co-operate
• To maximise outcomes of this scheme - include measures around sharing information/collaborative working to achieve indirect benefits associated with the above objectives.
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Date: 23rd December 2014
Lynne Stinson Smart Motorways Programme The Cube 199 Wharfside Street Birmingham B1 1RN
M4 Junctions 3 to 12 Smart Motorway pre-application consultation
The Highway Agency is proposing to improve a 32 mile stretch of the M4 between junction 3 (Hayes) and junction 12 (Theale) by upgrading it to a smart motorway. Buckinghamshire County Council recognises the benefits the scheme will have when complete, with a reduction in congestion on the M4, smoothing of traffic and improvements in journey time reliability. Careful consideration however needs to be paid to the impact on the County road network during the construction period.
Environmental Impact Assessment:
The Environmental Impact Assessment is being carried out in two stages; a preliminary environmental report (which forms part of the consultation) and an environmental statement (yet to be made available).
The preliminary environmental report is very brief and more detail is required in order that the County Council can provide comprehensive comments. The County Council would wish to be consulted on the environmental statement, which is to contain the full results of the EIA and will accompany the Development Consent Order application.
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Road Bridges:
The following roads in Buckinghamshire County Council’s jurisdiction will be directly affected by the proposed smart motorway working:
• Marsh Lane
• Lake End Road
• Old Slade Lane (an old road bridge that is now gated and used as a public footpath)
Marsh Lane and Lake End Road bridges are Highway Agency owned structures. Buckinghamshire County Council would want to be consulted on the review process and may possibly need to be a signatory to the AIP. Please find below the contact details for the Team Leader of Highway Structures Management:
Len Smith
[email protected] (01296 382709)
Discussions need to be had at an early stage with Buckinghamshire County Council regarding the detailed design and construction proposals of the Marsh Lane and Lake End Road bridges. For example, should the new structures be built on the line of the existing, requiring a temporary structure to the side, or off line requiring a permanent realignment of the approach ramps. In addition there are likely to be issues relating to increasing the clearance under the bridges, as this will result in the road levels of Marsh Lane and Lake End Lane being raised making them more prominent in the landscape.
Buckinghamshire County Council is aware that the Highway Agency intends to set up workshops in the New Year to discuss this in more detail. Early engagement would be fully supported by Buckinghamshire County Council.
Rights of Way:
The bridge works are likely to affect two existing Rights of Ways in Buckinghamshire; Marsh Lane and Old Slade Lane (please refer to the attached plans). The County Council needs to be consulted on the impacts of the bridge works and any requirements for Temporary Traffic Regulation Orders if the footpaths/bridleways need to be closed.
Please find below the contact details for the Strategic Access Advisor:
Jonathan Clark
[email protected] (01296 387695)
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Flooding and Drainage:
The part of the M4 which runs through Buckinghamshire is very short. The documents which are part of the consultation are very brief and more detailed would be required to make comprehensive comments. From what is given we can make the following comments:
• The documents suggest that the central reserve drainage system will be replaced. The designs of the drainage to the central reservation will be in line with Highways Agency design standards. Details on this design required.
• The design of the verge will ensure that there is no flooding of the carriageway once the hard shoulder is upgraded to a running line. We would encourage the use of Sustainable Drainage especially for drainage from the hard shoulder and any drainage design should include a maintenance/management plan.
• The document claims that “there will be no increase in discharge from the highways drainage system to local watercourses.” Evidence of the designs, to show no increase, would be required. In addition to the fluvial flood maps the surface water must be considered and the most recent Surface water maps on the Environment Agency website should be used http://watermaps.environment- agency.gov.uk/wiyby/wiyby.aspx?lang= e&topic=ufmfsw&layer=0&x=487500&y= 181500&scale=10&location=Maidenhead%2c+Windsor+and+Maidenhead#x=487 500&y=181500&scale=10
• It would be important to see more details from the assessment of the “impacts of the proposed scheme on drains, flood plains and water courses”
Buckinghamshire County Council was consulted on the scoping for the EIA in August 2014 and provided the following comments in relation to flooding and drainage:
The documentation we would expect to be submitted for flood risk would be:
• Details of the existing site layout, drainage system and catchment areas, if appropriate.
• Ground investigations, (including groundwater and contamination), and infiltration tests, where appropriate.
• A detailed site layout at an identified scale (as agreed with the SAB) with a North point of the proposed drainage system with catchment areas.
• A plan for the management of construction to include; phasing and maintaining the system (including access arrangements, operational characteristics, and energy requirements for constructing and maintaining all proposed drainage systems) and the details of any offsite works required, together with any necessary consents period and any impacts, such as diversions and erosion control.
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• Suitable construction details and details of connections (including flow control devices) to watercourses, sewers, public surface water sewers, highway drains and drainage systems.
• Full design calculations and design parameters to demonstrate conformity with the design criteria for the site.
We are disappointed that the suggested drainage so far is very conventional, using oversized pipes and gullies. We would wish for sustainable drainage to be considered within the Smart Motorway proposal. This is a great opportunity to showcase some SuDS techniques for managing flood risk and providing benefits such as pollution management, increased water quality, amenity and habitat.
Buckinghamshire County Council hopes that these comments have been taken into account as part of the EIA. Please find below the contact details of the Lead Officer for the Flood Management Team:
Karen Fisher
[email protected] (01296 382951)
Ecology:
The specific areas that relate to Buckinghamshire are represented by Sheets 14, 18 and 19 (EIA Scoping Report Figure 1), relating to Junctions 7-8 and 4-5:
Landscaping
Opportunities should be sought to improve the linear connectivity of sites along the motorway as a potential corridor for wildlife. This may be achieved by sympathetic management of the roadside verges as well as the planting of native species of local provenance that represent the local species mix.
Where vegetation is removed, this should not have an impact upon protected species that may frequent them. If mature trees are to be removed these will require an assessment of their potential to support bat roosts. Where vegetation is to be cleared preliminary assessments and/or checks by and Ecological Clerk of Works (ECoW) should be undertaken to ensure that harm is not caused to breeding birds, reptiles and other protected species deemed potentially present by ecological survey.
Bridge works
Bats are known to roost in a number of locations within bridges. Such as:
• Widening joints
• Expansion joints
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• Gaps at the corners of buttresses
• Widening gaps (where the width of the bridge has been increased)
• Cracks and crevices that are approximately greater than 100mm deep e.g. between stonework/brickwork
• Drainage pipes and ducts
• Internal voids
All species of bat and their roosts are protected under The Conservation of Habitats and Species Regulations 2010 which make it an offence to undertake activities that may kill, injure or disturb an individual or damage or destroy a breeding site or resting place of that individual. Consequently, each bridge should be subject to a preliminary bat assessment. Opportunities to integrate biodiversity features into the design of new bridges may also be realised.
The works present a fantastic opportunity to improve ecological connectivity across the M4. Opportunities should be sought to include overbridges for the purposes of wildlife i.e. green bridges. Both the Natural Environment White Paper (2011) and the United Kingdom’s Biodiversity Strategy (Biodiversity 2020) recognise the findings of the Lawton Report and the need to create ‘more, bigger and better joined’ habitats. The inclusion of a green overbridge would conform to these national objectives. Appropriate locations may be within the Colne Valley Park in close proximity to the Colne Valley Biodiversity Opportunity Area (BOA). For more information about BOAs see:
http://www.buckinghamshirepartnership.co.uk/partnership/bmkbp/biodiversity opportunity ar eas.page
Lighting
The lighting scheme should be developed with potential impacts upon bats and invertebrates in mind. It may be possible to consider the placement of lights in relation to sensitive adjacent habitats e.g. woodlands and rivers, or the timing of their use and the lighting levels. Bats can be significantly impacted by light levels and the type of lighting. For more information refer to:
http://www.bats.org.uk/pages/bats_and_lighting.html
Flood control
It is noted that the central reserve drainage system will be replaced. Should this form part of a new sustainable drainage system biodiversity opportunities should be realised through appropriate SuDS design, noting that the SuDS triangle comprises of water quality, water quantity and amenity/biodiversity. Consequently, SuDS installations should be provided with features and planting for biodiversity.
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Please find below the contact details for Buckinghamshire County Council’s Ecology Advisor:
Ian Thornhill
[email protected] (01296 383138)
Construction:
When assessing the construction impact, as part of the Environmental Impact Assessment, it should be noted that there are other major construction schemes planned, within the same timescales, in this area of Buckinghamshire that will need to be taken into account:
• High Speed Rail 2
• Heathrow Western Access (rail tunnel from the mainline at Langley to T5)
• Crossrail
• Great Western mainline electrification
• Pinewood Development
There is local concern regarding the cumulative impact of construction traffic and the location of the compounds, which Buckinghamshire County Council would wish to see addressed as part of the Development Consent Order application.
The County Council would also wish to be consulted on the construction proposals and programme for delivery of the M4 Smart Motorway project. Information regarding the origins of bulk construction material and destinations for the bulk waste from the scheme should be provided. Buckinghamshire County Council would wish to comment on routes and times of operations, if it is the Highway Agency’s intention to use the County road network.
The demolition and construction of overbridges are due to take place at night/over the weekend. Buckinghamshire County Council would also wish to comment on the tactical diversion routes during motorway closures between junctions 8/9 and junction 7 and the strategic diversion for anything between junctions 4B (M25) and junction 8/9.
In addition concerns have been raised regarding possible displaced traffic during the construction period, particularly on the A355 through Farnham Royal/Farnham Common and the A4. Increases in congestion on the A4 will result in locals using less appropriate parallel routes in Taplow, Burnham, Farnham Royal, Iver and Wexham.
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Please find below the contact details for the County Council’s Intelligent Transport Systems Specialist:
Anthony Blackmore
[email protected] (01296 382678)
Yours sincerely
Christine Urry
Strategic Transport Development Management Officer
Planning, Advisory & Compliance Service
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FAO: Karen Jones (EIA and Land Rights Advisor) The Planning Inspectorate 3/18 Eagle Wing Temple Quay House 2 The Square Bristol BS1 6PN
Dear Ms Jones,
Re: Highways Agency application for an Order Granting Development Consent for the M4 Junction 3-12 (Smart Motorway) – Environmental Statement scoping consultation
Thank you for consulting Buckinghamshire County Council regarding this Environmental Statement scoping opinion. Please find below our observations addressing flood management, landscape, ecological and archaeological matters.
To properly assess any flood risk associated with this proposal, we would expect the following documentation to be submitted for our consideration:
• Details of the existing site layout, drainage system and catchment areas, where appropriate;
• Ground investigations, (including groundwater and contamination), and infiltration tests, where appropriate;
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• A detailed site layout at an identified scale (as agreed with the SuDS Approval Body) including a North point of the proposed drainage system and catchment areas;
• A plan for the management of construction to include phasing and maintenance of the system (including access arrangements, operational characteristics, and energy requirements for constructing and maintaining all proposed drainage systems) and the details of any offsite works required, together with any necessary consent period and any impacts, such as diversions and erosion control;
• Suitable construction details and details of connections (including flow control devices) to watercourses, sewers, public surface water sewers, highway drains and drainage systems; and
• Full design calculations and design parameters to demonstrate conformity with the design criteria for the site.
Considering the current documentation, we are disappointed that the suggested drainage to date is very conventional, using oversized pipes and gullies. We would wish for sustainable drainage to be considered within the Smart Motorway proposal. This is a great opportunity to showcase various SuDS techniques for managing flood risk and providing benefits such as pollution management, increased water quality, amenity and habitat.
The submitted information regarding landscape is limited, though it appears the core proposal would have a minimal impact on landscape (with most work taking place within the existing boundary of the motorway). It is suggested however that some land will be required to enable the construction or replacement of widened bridges. We would welcome further details on this matter.
When undertaking the Environmental Assessment for the Smart motorway proposal, the Highways Agency should be cognisant of baseline data from Buckinghamshire. From a landscape perspective that would include the Landscape Character Assessment for South Bucks District1 and the Historic Landscape Characterisation Project for Buckinghamshire2.
It is unclear at present whether the Environmental Assessment for this scheme will undertake a Landscape and Visual Impact Assessment. Although the literature states that environmental impact on landscape will be minimal we would encourage due consideration to be given to the potential visual impacts this proposal may impose. Particular attention should be paid to the visual intrusion which may be caused through the presence of new gantries and additional lighting. At the detailed design stage the County Council would encourage the Highways Agency to consider the character of the surrounding landscape. Cues should be taken from the landscape form and appearance when designing infrastructure.
We make a number of observations regarding ecological matters specific to the county. The relevant information is represented by Sheets 14, 18 and 19 (EIA Scoping Report Figure 1) of the submitted documentation and regards Junctions 7-8 and 4-5.
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In order to consider potential ecological issues pertaining to the proposed improvements to the M4 Junctions 3- 12: Smart Motorway specific to Buckinghamshire, We have reviewed what ecological concerns there are first within the footprint of the proposal and then within a 1km buffer. We have referred to designated sites (statutory and non-statutory) and protected species under The Conservation of Habitats and Species Regulations 2010. Also considered are habitats and species listed under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006 as being of principal importance for the purpose of conserving biodiversity. In order to inform species records we have accessed BMERC records as an initial indication of protected and notable species only.
The scope of Ecological Baseline information to be updated or made additional to the existing baseline (6.4.6) should provide a robust account of the ecology potentially impacted by the proposal, provided that they adhere to best practice guidance as outlined. However, invertebrate surveys should also be scoped in as they may be similarly impacted by increased traffic and lighting which will cause direct fatality as well as increased resistance to dispersal. To this end Natural England provides guidance in the form of documents NERR005 and RIN005: http://publications.naturalengland.org.uk/publication/36002 . The widening of the motorway is likely to lead to the loss of suitable habitat for invertebrates. The presence of water vole in four locations along the route may also warrant an increased valuation, though it is not clear from the Scoping Report where these locations are.
Opportunities should be sought to improve the linear connectivity of sites along the motorway as a potential corridor for wildlife. In any event, the lighting scheme should be developed with potential impacts upon bats and invertebrates in mind. It may be possible to consider the placement of lights in relation to sensitive adjacent habitats e.g. woodlands and rivers, or the timing of their use and the lighting levels. Bats can be significantly impacted by light levels and the type of lighting. Please refer to http://www.bats.org.uk/pages/bats and lighting.html for more information.
With regards to archaeological matters, we have consulted the Environmental Impact Assessment scoping report and welcome section 6.2 covering Cultural Heritage. Section 6.2.1 is particularly welcome, stating consultations will be undertaken with Local Authority development control archaeological officers at County level and English Heritage. We encourage the revision of section 6.2.3 to consult the Buckinghamshire Historic Environment Record. The potential mitigation measures stated are encouraging however 6.2.14 should be amended to read ‘Targeted archaeological excavations ...’
We would normally expect applications to be supported by the results of an assessment of the significance of the historic assets affected and the impact of such development on that significance. This work should include an archaeological desk based assessment and a walk over survey. Such work should provide further information on the presence of undesignated and designated heritage assets such as may be affected. It is likely on some of these sites that such an assessment would indicate the need for an archaeological geophysical survey to provide factual information regarding the presence or absence of buried archaeological remains. Such information should be sought from the developers as supporting information to an application in accordance with
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Paragraph 128 of the National Planning Policy Framework dealing with ‘information requirements’. It is likely that direct impacts of the scheme could be reduced or avoided through sensitive design; however this can only take place if facilitated by the assessments recommended above. We would therefore recommend that the historic environment is included within an Environmental Impact Assessment and covers the above issues. If it is decided that an Environmental Impact Assessment is not required then we would expect the above issues to be to be addressed prior to application.
Thank you for providing this opportunity to comment, we look forward to further opportunities to engage with you.
Yours sincerely,
Emma Green Senior Policy, Strategy and Development Officer Telephone: 01296 382090 Email: [email protected]
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OBJECTIONS TO ANY POSSIBLE LAND ACQUISITION IN THE BURNHAM AND HUNTERCOMBE CONSERVATION AREAS.
Firstly, it is important to stress that buildings and land to the east and north east on the north side of the proposed widened Lake End Road bridge belong to Burnham and Huntercombe Conservation areas, V51 and V52 (map?) designated 1977. Quote p1 (3) “It is an area of special architectural or historic interest whose character or appearance it is desirable to preserve or enhance” therefore it is desirable that as little as possible should be done to interfere with this area during the time the bridge is being built.
The owners of Abbey House received notification from the Planning Inspectorate that there was a possible interest in 2 acres of land in the garden of Abbey House, (Ref. 19201), being the subject of a compulsory acquisition order. However, no further official communication about this has been received. It is for this reason that a group has been formed to object to any potential land acquisition or disturbance in the surrounding area when the bridge is built and the Motorway widened.
The said group has the following objections:
1. The land is both green belt and within a conservation area surrounded by listed buildings and is of historical and archaeological significance as part of the original Burnham Abbey compound
2. The land that was of interest in the Abbey House garden is used for the keeping of ponies. These ponies are for the use of disabled children, and a Charity has been set up for these children. The area you described as “hard standing” is in fact an Olympic sized horse Manege. In the surrounding areas there are far more appropriate sites such as flat farmland with safe access, the Animal Sanctuary site which will shortly become vacant, and, adjacent to that, a commercial industrial ‘yard’ that processes skip materials. As such, this site is already suitable for heavy vehicles.
3. The said land is adjacent to the following properties: Tithe Barn (a listed building), Chauntry Cottage, and Abbey House and its listed Dovecote. Nearby are Four Elms, The Chauntry, Little Chauntry, Chauntry Barn, Burnham Abbey, The Lodge at Burnham Abbey, and Huntercombe Farmhouse. Any storage of vehicles, night time working, lighting, etc. in this area would be a great disturbance to all the residents of these properties, as would parking, caravan sites and portacabins.
4. Huntercombe Lane South is a fast, busy, narrow, winding country lane with access to residential properties and Burnham Abbey. Lake End Road is also a fast and busy road. The potential for serious accident is extremely high.
We have the following questions regarding the proposal:
1. Where will the access points to the site be? Access to the house named Four Elms is changing and there are no clear plans as to what is being done.
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2. What alterations will be made to the site and what buildings or constructions will be on it?
3. How long will the site be in use for?
4. What will be the hours and days of operation, and what is the approximate start date?
5. What are the anticipated noise and vibration levels?
6. Will there be an archaeological survey of the site before use?
7. Will the site be screened, and if so, how?
8. Will the site be lit at night and have security?
9. What measures will be taken to keep the surrounding roads clear of mud?
10. After completion of the M4 work will the site be decommissioned and reinstated as green belt?
11. Will the land be sold on completion of the work, and if so, what will be the sale process and future usage or will it be offered back to the current owners at the forced sale price?
12. Is Lake End Road bridge to be demolished and rebuilt only, or is a second bridge to be built?
13. The drains around Four Elms will be blocked by the new proposal as it may affect the water table....hence the said property.
14. The properties, trees and landscape near the bridge will be blighted.
15. With regard to the proposed widening, which seems to be a fait accompli, speedy completion is requested, as the suggested ten year works will blight our lives.
16. The only benefit will be “quiet” tarmac, as the requested noise barriers are not now proposed. From experience of the M40, J2 the quiet tarmac deteriorates with time, and more so with road repairs. Are we expected to pay for noise barriers ourselves to benefit the neighbourhood, and especially Burnham Abbey?
Burnham Abbey is a Grade 1 listed building with several grade 2 listed buildings around it, including the grade 2 listed Tudor wall on its northern boundary, with only a footpath separating it from the field to the north of it. If this is being considered for acquisition to house heavy machinery, which the Abbey simply do not know, as it is landowners who have been informed, the vibration could affect the wall. More generally, the whole scheme, but particularly the building of the bridge, is going to have an adverse effect on Burnham Abbey which is a convent of nuns. We have no illusions about the volume of noise whilst the work is going on, as three of the present nuns were already here when this section of the M4 and the Lake End Road bridge were built. The noise was deafening and very intrusive. This will not only affect the nuns but also different groups, from about 5 to 20
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people who come for quiet days once or twice a week. In addition, the nuns frequently have individuals for quiet days and also resident guests to be quiet or to be in retreat. The question is, “Will people want to visit during the building of the bridge?” This is an important aspect of the Abbey ministry and a key part of their Charitable Purposes (Reg. Charity 900512). The nuns also have a house called St Augustine’s which is let out at a market rent; again the amount of noise might force them to drop the rent. To sum up, the noise will affect the Abbey one way or another, including perhaps their income.
In conclusion, we all ask that all the above factors are taken into consideration when decisions are made.
The residents of the Burnham and Huntercombe Conservation area.
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FAO Head of Planning South Bucks District Council Capswood Oxford Road Denham UB9 4LH By email to [email protected] and by post
17 September 2015
Dear Head of Planning,
Cc Director of Public Health
Re: The Council’s Local Impact Report on the Application by Highways England for an Order Granting Development Consent for the proposed M4 Junctions 3 to 12 Smart Motorway3
On behalf of Friends of the Earth and Campaign for Better Transport, we wish to raise a number of matters that should be assessed as part of the Local Impact Report in relation to the above application (ref TR010019).
In summary we are of the view that a number of negative impacts arise with regard to:
• Air pollution (and the related health impacts)
• Congestion, increased transport, impact on transport reduction, and safety of other road users (local transport impact)
• Increased greenhouse gas emissions
• Noise (impact on amenity and health)
• The impact on existing and emerging local plans, and the impact of the acquisition of common land and allotments on local provision and access
• Impact on nationally designated and locally protected areas
• Socio-economic impacts
Firstly with regard to air pollution, you will be aware that the EU Directive limits are absolute and must be met irrespective of cost. Air pollution must not be worsened in three ways:
• a breach must not be caused
• air already failing legal limits cannot be worsened or compliance delayed
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• the non-deterioration principle: “maintain the levels of those pollutants below the limit values and shall endeavour to preserve the best ambient air quality, compatible with sustainable development”. See letter of clarification to Clean Air in London4
Given the recent Supreme Court ruling requiring new plans to be produced by the UK Government by the end of the year, so that EU legal limits are met in the shortest time possible5, in our view the local impact report must consider how this scheme will affect the ability of areas within your authority to meet limits as required. In relevant areas, in order to meet limits in the shortest time possible, air pollution should not be added to at all from a scheme. Within the context that the impact on local air quality must be considered, you may be aware that baseline dates for complying with EU limits have changed6.
Recent figures for premature deaths due to NO2 pollution now add to those for particulate pollution, meaning a greater impact on the health of citizens in your area.i7 We are of the view that the impacts on communities are such that representative local authorities must consider this issue fully in their Local Impact Report, and ensure that the Director of Public Health is also consulted.
Secondly, with regard to transport impacts, the local impact report must contain an assessment of whether the scheme will increase flows on roads in the surrounding area to the detriment of road safety and congestion, and whether this will then have an impact on schemes to enhance walking and cycling and public transport.
Thirdly, with regard to greenhouse gas emissions increases, given the local authority’s duty under Section 19(1A) of the Planning and Compulsory Purchase Act 2004 to ensure that: “Development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change”, the relevant policies should be referenced in the Local Impact Report. The National Planning Policy Framework links land-use planning to the Climate Change Act 2008, and therefore the impact of increased transport emissions should form part of the impact report.
Fourthly, we are of the view that increased noise and lighting may also adversely affect the health and amenity of those in proximity to the M4 and its connecting roads, given the number of junctions affected by the changes designed to increase traffic use. It is imperative that this is considered carefully in the Local Impact Report as an important local planning issue under paragraph 123 of the National Planning Policy Framework.
Fifthly, given that the local plan for the local authorities where this application is located has no direct link to the National Policy Statement on National Networks, it is vital that these plan policies are properly reflected and drawn into the examination through the Local Impact Report. We are concerned about the possible loss of land which is currently in allotment use and how this would be replaced; and the replacement of common land, and any other open public space. Any loss of publicly accessible land is of high public interest, and provision must be ensured through local plans and appropriate funding and commitments.
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Sixthly the local impact report should fully detail the impact on nationally and locally designated areas of protection. We are particularly concerned that the local impact report should outline the impact of the scheme on the character and appearance of the landscape, in particular the North Wessex Area of Outstanding Natural Beauty and the visual impact of associated infrastructure along the length of the proposed project. In addition, we would wish to see the local authority’s view on the extent to which the scheme would cause disruption or permanent harm to habitats and plants, invertebrate species, amphibians, reptiles, birds, bats, water voles, otters, and badgers.
Finally, we would wish to see a full analysis of the socio-economic impacts of the increased traffic (noise and congestion), on local businesses, access to essential services, and general amenity of areas on the linking roads that will be affected.
Yours sincerely,
Naomi Luhde-Thompson Friends of the Earth, Planning Advisor
Sian Berry Campaign for Better Transport, Roads and Sustainable Transport Campaigner
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