Clive Jones WRITTEN REPRESENTATION HIGHWAYS ENGLAND'S RESPONSE ADDITIONAL COMMENTS FROM CLIVE JONES 1. INTRODUCTION 1.0 Position Statement on behalf of Clive Jones On Behalf Of Wokingham Liberal Democrats. In response to Examining Authority Question at Agenda Item 7 f ii of the Agenda for the Compulsory Acquisition Hearing 1.1 First of all, I would like to thank you all for the courtesies that you extended to the interested parties and those who spoke at the public meetings and thank the staff and advisors of Highways England for the professional and courteous way that they dealt with our questions. 1.2 The following summarises the comments that I made to the open Meeting in Reading on the 16th November and comments made at the issue specific hearings at the Radison Blu hotel in Hayes on 17th and 18th November. 1.3 Some comments also relate to the accompanied site visits on 10th November when we visited 10 different sites between junctions 10 and 11. 1.4 In summary, we do not agree that Highways England noise mitigation, air quality or road safety plans as they currently are, go far enough for the stretch of motorway between junctions 10 and 11. 1.5 The small measures proposed by Highways England will only help a few hundred residents in Emmbrook, Winnersh, Sindlesham, Lower Earley and Shinfield. 1.6 This is very disappointing because there are over 10,000 houses in the Lower Earley area alone and possibly nearly 30,000 people living here. When you add the residents of Winnersh, Emmbrook, Shinfield, Sindlesham and Three Mile Cross this number will move towards 12,000 houses and 35,000 residents. These residents get little or nothing from the proposals by Highways England. Highways England Comment 1.6.1 The points raised in this summary are addressed by Highways England in response to the detailed comments below, which also take account of the additional comments provided by Mr Jones in his email of 4th December 2015 (contained in Appendix B). My detailed comments are set out below: 2. ACCOMPANIED SITE VISITS 2.0 I was pleased that Highways England added some sites to the visit that I suggested you looked at in my earlier representation. Deadline V 1 2.1 During the accompanied site visits on the 10th November we visited 10 different sites. As we drove between the sites I was able to point out to you where earth bunding and acoustic fencing could go. Highways England Comment 2.1.1 One of the design principles for the Scheme is to minimise land-take, in order to reduce the adverse effects of the Scheme on landowners and adjoining land users. This results in a preference for mitigation measures which can be accommodated within existing highway land, such as noise barriers, as opposed to measures that require land, whether through compulsory purchase or third party agreements, such as earth contouring for noise bunds. 2.2 Highways England have asserted that there will also be some noise from local feeder roads such as Lower Earley Way and Rushey Way and that this contributes to the noise and air quality levels. However on the site visits that we undertook we could distinctly hear the sound of motorway noise. Highways England Comment 2.2.1 Highways England considers that noise from roads other than the M4 will contribute to the prevailing noise climate at some locations to a greater or lesser extent, depending on distance from the motorway, the closeness of other busy roads and shielding effects. This does not mean that Highways England does not accept that the M4 motorway contributes as a noise source at many of these locations. 3. NOISE EARTH BUNDING AND ACOUSTIC FENCING LOWER EARLEY 3.0 2.1.1.1 For Earth bunding there is generally land south of Lower Earley Way where the bunds can go. There is also enough space for Lorries delivering the earth to turn around without clogging up Lower Earley Way. The bunds will be able to start at Eden Way in Winnersh and continue alongside the M4 until a few hundred metres before Beeston Way. At the end of the bund and Acoustic fence could be erected by the side of the M4 up to the roundabouts at Beeston Way. 3.1 2.1.1.2 From here acoustic fencing can continue alongside the north side of the M4 continuing to the Black Boy roundabout. Highways England Comment 3.1.1 This proposal would result in 3.6km of new earth bunds to the eastbound (northern) side of the M4 between Beeston Way in Lower Earley and Eden Way in Winnersh. Highways England considers that such a feature is not viable for the reasons set out below. 3.1.2 The effectiveness of acoustic barriers such as noise fences and earth bunds is greatest immediately behind the barrier and decreases with distance from the barrier. Any bund between Lower Earley and Winnersh along the eastbound carriageway would lie at distances of several hundred metres from residential Deadline V 2 properties. Apart from the very eastern and western ends of the bund, where housing is nearby, such a bund would not noticeably benefit residential areas. In comparison, the enhanced noise mitigation proposed by Highways England in this location (new noise barrier to Lower Earley/new and replacement barriers to Winnersh, on the Scheme boundary) will provide significant noise reductions to properties close to the Scheme, with lower noise reductions to properties further away. 3.1.3 The topography is not suitable for constructing an earth bund as much of the M4, especially east of the River Loddon, is on embankment. It would be necessary to construct a “false cutting” to raise the land sufficiently to create a bund. This would require considerably more aggregate than a bund where the motorway is at grade or in cutting. This would clearly increase the construction costs and associated haulage movements. Therefore, the enhanced noise mitigation proposed by Highways England will provide new and replacement noise fences rather than bunds. 3.1.4 Further, the construction of an earth bund along the eastbound carriageway would require extensive removal of mature tree cover, which currently provides valuable screening. 3.1.5 The mitigation proposed for the Scheme, to provide low noise surfacing across all lanes, will mitigate noise at source, benefiting wide areas to the north and south of the M4. Two short sections of new noise barrier are also proposed on the eastbound and westbound carriageway at Mill Lane Underbridge, specifically to provide additional mitigation for properties close to the motorway at this location. 3.1.6 As reported in Chapter 12 of the ES (Application Document Reference 6-1, APP- 152), the magnitude of impact for the Scheme on ambient noise is minor beneficial in the short term and negligible 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. This includes the Lower Earley area as shown on sheets 3 to 5 of drawings 12.4 and 12.5 (Application Document Reference 6.2 figures 12.4 and 12.5, APP-266 and APP-270). 3.1.7 However, it is noted in paragraph 12.4.112 of the ES (Application Document Reference 6-1, APP-152) that there is potential to improve further the noise climate within the Scheme corridor. A qualitative appraisal of an enhanced noise mitigation study to achieve this is provided in Appendix 12.5 of the ES (Application Document Reference 6-3, APP-351). This enhanced noise mitigation study comprises the possible provision of additional noise barriers and the possible replacement of some existing noise barriers with higher noise barriers. 3.1.8 The results of the enhanced noise mitigation study are provided with the Deadline V submission. The confirmed barrier provision in the Lower Earley area is detailed within Appendix E of the Enhanced Noise Mitigation Study Report (Ref 514451-MUH-00-ZZ-RP-EN-400158). Sheet 4 is relevant to the Lower Earley area. A new 2.5 metre high noise barrier is proposed to provide noise mitigation to Lower Earley. 3.2 2.1.1.3 Along the bunding we would like to see extensive planting of tree and bushes to help improve the air quality. This would greatly improve the visual impact from both sides of the bunds. Deadline V 3 Highways England Comment 3.2.1 Highways England recognises that extensive planting of trees and shrubs could potentially offer some benefit to air quality, as set out in Forestry Commission research http://www.forestry.gov.uk/fr/urgc-7edhqh. However, it should be noted that the effects of vegetation on nitrogen dioxide, the principal pollutant gas emitted by vehicles, are less well established. As nitrogen dioxide is generally the pollutant with higher concentrations along highways routes, vegetation may have less utility, compared to urban centres where particulate concentrations may be higher. For example the highest predicted annual average concentration of PM10 with the Scheme was 26.3 µg/m3 against an annual average air quality objective value of 40 µg/m3. Consequently, no such mitigation is required for the Scheme. 3.2.2 Additionally, the existing M4 along this section is mostly on an embankment going through an area with a limited number of residential properties which have a potential view to the Scheme. Where the motorway is close to residential properties, the existing embankments are vegetated and this vegetation would for the most part be retained as part of the Scheme.