John Raymond For Winslade Parish Meeting 25th July, 2018 Ms Lucy Page, Case Officer, Basingstoke and Deane Borough Council. Dear Lucy, Ref: 17/03487/FUL - Construction of new Motorway Service Area - Land Adjacent to Junction 6 M3 I write on behalf of Winslade Parish Meeting which includes the residents of Hackwood and Home Farm south of the Tunworth Road (Dickens Lane). We objected to this application last November 2018 and we do so again having studied the new support documents from Moto’s consultants and the many new objections submitted to you. Our reasons for objecting last November still stand. The new documents submitted by Moto raise more questions than they answer. They have been presented in a haphazard fashion and appear to make little attempt to answer clearly and coherently the very many major concerns and objections expressed by so many during the consultation period late last year, from both consultees and the more than 150 local residents who took the trouble to submit formal objections. There was only one letter of support. We have studied the new documentation posted on your website by Moto this year and have the following comments: 1. JUNCTION J6 AND QUEUES ON M3 SLIP ROADS. The new technical note from Moto’s consultant PFA shows a new traffic study as requested by Highways England following the last round of consultation. The study concludes that, with their suggested modifications to the J6 roundabout, queues on the slip roads will be the same or significantly better in 2021 and 2029 than they are today. Can this theoretical model be believed? Its modelling basis is unclear. Will the MSA entrance be moved to the middle of the roundabout as requested last year by Highways England? How will traffic arriving from Black Dam be controlled. It currently joins the roundabout as virtually free flow? With the new MSA built, this free flow will be interrupted by northbound traffic wishing to reach the MSA. Will there be new traffic lights at this north east corner of the roundabout? None of this is explained. The PFA report says queues on the slip roads will remain, even with their suggested improvements to the J6 roundabout. Queues will just be no worse than today which is all they have to prove under planning regulations. However, the purpose of this MSA is to serve the M3 motorist. At peak times seeing the queues motorists will drive on to Fleet or Winchester. So, at these times, the MSA cannot serve the need for which it is being built. SAFETY A major concern today is safety at J6. There are daily queues out on the M3 at peak times. Some years ago a lady was killed when her car was hit by a lorry. If by redesigning the J6 roundabout extra capacity can be created, this possible capacity should be used to reduce queues and improve safety, not used up in this needless manner. NEW RETAIL PARK It is not clear from the PFA study if the considerable traffic that will be generated by the planned new retail park at the Leisure Centre to the west of Basingstoke is included in their model. Basingstoke is expanding, many new houses are being built, if extra capacity on this vital link to the M3 can be achieved then the capacity should be kept in reserve to meet the future needs of Basingstoke, not the possible needs of the M3 motorist. 2. BATS: The new June 2018 biodiversity report from Greengage on behalf on Moto – ‘Dormouse and Reptile Mitigation Strategy’ shows there are dormice, slow-worms and protected plants such as hound’s tongue on the site. They explain the mitigation precautions to be taken. These species must be protected. This study mentions the building of a new access road along the south edge of the M3 towards the A339. It does not consider the disruption and damage to habitat that will be caused by laying the new foul water sewer from the MSA to meet the main sewer on the A339. The study mentions in passing the Bat Survey carried out by Corylus on behalf of Moto in 2016. It is attached at the end of the October 2017 Greengage ‘Ecology Mitigation Report’. This bat survey has far reaching implications as it found nine species of bat around the MSA Site, some rare. In its conclusions the survey lists ‘Sensitive lighting strategy suggestions’ which include: - using a minimum amount of light, i.e. that needed only for safety; - elimination of any bare bulbs and any upward pointing light; - limiting the times that lights are on to provide some dark periods; and - avoiding using reflective surfaces under lights. It is difficult to see how an MSA could operate meeting just these requirements, and there are other requirements mentioned in this report. The study ends by recommending the design of ‘a detailed sensitive lighting strategy’ to include these recommendations. This strategy has not been seen. A further study was recently conducted within neighbouring Hackwood Park and ancient Spring Wood by a respected ecologist on behalf of the owners of the Park. The report ends by saying “I suspect you also have brown long eared, some other myotis species (possibly some rare ones like Bechsteins)” The Corylus survey shows the presence over the MSA Site of long-eared bats and the Myotis species without specifically mentioning Bechsteins, but neither in large numbers. Bat experts inform us that a study such as that conducted by Corylus would be unlikely to spot these quieter more timid species above the open ground of the Red Line MSA Site. They live up in the surrounding tree canopy and woodland. To test for their presence in numbers a new different study in required. We are also told these rare species will be particularly affected by the light spill from the new MSA. We ask that this application is refused until a more detailed bat study of the surrounding ancient woodland has been conducted. Such breeding populations, particularly of Bechsteins, are strongly protected by law. URBAN DESIGN: John Dawson from the B&D Planning commenting on the ‘Urban Design’ of the MSA in his document dated 2 February 2018 and posted on B&D’s web-site on 16 July 2018 states in Paragraph 1.2: “Some of the more detailed aspects of the layout are welcomed including: b) The outdoor seating area near the entrance of the amenity building and the outdoor picnic area and open space to its immediate west provide a welcome opportunity for visitors to spend time outdoors if they wish thereby enhancing the enjoyment and amenity of the facility. c) The hotel has some outdoor space to its rear which visitors can use and there is a dog walking area to the north west of the hotel.” A LOCAL DESTINATION Surely to avoid disturbance of the neighbouring wildlife and bat habitat this is exactly what is not required. On late warm evenings, locals will be encouraged to leave urban dwelling of an evening to enjoy this location with their dogs bringing noise and disturbance as it becomes a local destination. Mr Dawson’s report goes on to say concerning the design of the buildings: “2. The appearance of the buildings: 2.2 A number of aspects of the form and elevational appearance of the amenity building are welcomed: b) The large, glazed frontages lend the building a light appearance. The facetted glazed façade ensures visual interest to the key public frontage of the building from several directions. The large expanse of glazing has a welcoming quality showing visitors the activity inside the building; it provides broad, open views outside for those using the building. The linear L-shaped plan maximises visual interest on approach and also offers extensive daylight and views out from its interior. As stated in the Corylus bat survey the ‘glazed surfaces’ welcomed by Mr Dawson from an urban design standpoint are exactly the surfaces they say should be avoided in this rural bat habitat. It is clear Moto has paid little attention to these recommendations when preparing their urban design. The glazed surfaces will reflect external lighting and confuse wildlife. Also, the glazed surfaces Mr Dawson welcomes that allow daylight in during the day will allow internal lighting to escape at night time damaging the bat habit. 3. LIGHT POLLUTION: The June 2018 Greengage report states “The band of proposed woodland will prevent light spill into existing adjacent habitats”. This band of woodland Moto proposes to plant around the edge of the MSA site. The trees planted will take some ten years to grow to a size where they make any difference, by when the bats’ habitat may have been destroyed. The Oaken Planation and New Park beyond consists mostly of deciduous trees and so in the winter they are fully susceptible to light pollution from any bordering property. Even when trees are in full leaf Oaken Planation is quite open and so the MSA Site can be seen from well within the Grade 1 New Park woodland. The new May 2018 Lighting Impact Assessment by Hydrock points out that at night the MSA site and Oaken Plantation are dark quoting the light level at E2. Moto’s planning consultant, Collins & Coward this week wrote to B&DBC (letter dated 18 th July) concerning lighting. They refer to a submission by a Mr Mark Susans, a local resident who says he believes the light levels around the Site are closer to the E1 level, which is very dark. He states opinions of the Basingstoke Astronomical Society who use this area for their studies due to its darkness.