HIGHWAYS AGENCY – M4 JUNCTIONS 3 TO 12 SMART MOTORWAY APPENDIX 29: SECTION 42 CONSULTATIONS – RESPONSES FROM LOCAL AUTHORITIES AND PRESCRIBED CONSULTEES 5.2 CONSULTATION REPORT APPENDICES MARCH 2015 HIGHWAYS AGENCY – M4 JUNCTIONS 3 TO 12 SMART MOTORWAY PAGE INTENTIONALLY BLANK 5.2 CONSULTATION REPORT APPENDICES MARCH 2015 HIGHWAYS AGENCY – M4 JUNCTIONS 3 TO 12 SMART MOTORWAY APPENDIX 29 VOLUME 5.2 SECTION 42 CONSULTATIONS – RESPONSES FROM PRESCRIBED CONSULTEES Section 42 Consultees: Responses to consultation Prescribed Consultees/Local Authorities/Land Interests Date Representor Consultee/ Representation Highways Agency Response Proposed Received No. Organisation Change Additional information request 11/12/2014 043 Iver Parish Council Request for PEI Report, NTS and the relevant plans The requested information was provided to Iver Parish Council on 10 December 2014. No 26/11/2014 057 Scottish and Southern Please provide as much information as possible The Agency identified SSE plant as part of the Scheme's research, and continues to No Energy Power engage with SSE teams as part of its stakeholder engagement processes. Distribution Limited The Agency engaged with SSE to obtain information on the company's apparatus. Commencing in February 2014 it made requests to SSE for C3 estimates of costs to deal with SSE apparatus affected by the Scheme. The engagement by SSE in response to the C3 requests was welcome and helpful and the information provided has been very useful in the Scheme's development. Any of SSE's assets affected by the Scheme will be covered by protective provisions for the benefit of Electricity undertakers, which have been provided in the DCO. Air Quality Increased Air Pollution 16/12/2014 255 Wokingham Borough Section 6 of Preliminary Environmental Information Report states that consultation was EHOs and air quality officers were contacted by the Alliance on behalf of the Agency to No Council carried out with EHOs however this was not the case. Section 6.6.2 identifies monitoring establish general baseline air quality data. locations within our borough but does not include 10 monitoring locations at sensitive All Wokingham Borough Council sites that are located in representative locations have receptors along the M4 which should have been considered. The air quality assessment been used in the assessment. The data presented in section 6.6 of the ES only displays indicates that there are a number of receptors within WBC area where concentrations of those measurement locations that exceed the objective value. All measurement locations NO2 will increase as a result of the scheme which is located within an existing AQMA. No considered in the assessment are presented in Appendix 6.4 to the ES. further consideration has been made of this worsening of air quality. This will have a direct There are 391 individually modelled receptors within WBCs area. Five medium (2.1 - 2.6 impact on our LAQM duties and the requirement to DEFRA in improving air quality in this µg/m3) increases in annual mean NO2 concentrations are predicted at sensitive receptors area. The proposed location of the compounds are extremely close to residential areas that exceed the objective value within WBCs area. The remaining 386 receptors are not and therefore the receptors are likely to be affected by dust, plant/vehicle emissions and predicted to exceed the objective value. Changes in NO2 concentrations at these remaining noise. The mitigation measures proposed are insufficient. receptors are predicted to range from a decrease of 0.7 µg/m3 to an increase of up to 2.1 µg/m3. The results of the air quality assessment are reported fully in the ES which accompanies the application for development consent. It is not anticipated that the LAQM duties of WBC will be affected by the Scheme. Construction activities could adversely affect air quality in some areas through dust generation and plant emissions. However, proposals to control these potential impacts are set out in the Outline Construction Environmental Management Plan ("CEMP"), which is provided with the Application. 16/12/2014 006 West Berkshire District The Preliminary Environmental Information Report details the location of the construction An Outline CEMP is provided with the Application, which includes measures to control dust, No Council compounds. There is the likelihood that existing sensitive receptors will be affected by noise vehicle and plant emissions. The Agency will review whether an application under COPA and air quality from the compounds due to their very close proximity. It is recommended 1974 is necessary or appropriate in the circumstances. that application under Prior Consent of the Control of Pollution Act 1974 is made to West Berkshire Council to protect the residents from noise and also prepare a construction management plan to include air pollution (including dust and vehicle and plant emissions). M4 JUNCTIONS 3 TO 12 SMART MOTORWAY VOLUME 5.2 SECTION 42 CONSULTATIONS – RESPONSES FROM PRESCRIBED CONSULTEES, LOCAL AUTHORITIES AND THOSE WITH A LAND MARCH 2015 INTEREST APPENDIX 29 PAGE 1 HIGHWAYS AGENCY – M4 JUNCTIONS 3 TO 12 SMART MOTORWAY Date Representor Consultee/ Representation Highways Agency Response Proposed Received No. Organisation Change 19/12/2014 038 South Bucks District Infrastructure enhancement to support economic success and decrease congestion along The air quality assessment for the Scheme was undertaken as part of the Environmental No Council major arteries linking Heathrow and London to the rest of the UK is a key issue for the Impact Assessment. The impact of changes in air quality on Burnham Beeches Special South East. We therefore understand the need for an improved M4 corridor to meet the Area of Conservation ("SAC") and the Site of Special Scientific Interest ("SSSI") has been anticipated needs of the region over the next 40 years. The proposal put forward has the assessed, and reported in Chapters 6 and 9 of the ES, which accompanies the Application. potential to ease congestion in the South Bucks region as the motorway becomes more The SAC and the SSSI are located approximately 4.4km from the M4 and 2km from the efficient at servicing larger volumes of traffic. The concern over this expansion is the impact M40 near to the A355. The predicted increase in annual average daily traffic ("AADT") flow on local housing (for example along Old Slade Lane) and SSSIs. The nearby Burnham along the A355 closest to Burnham Beeches ranges between 12 and 49 vehicles per day. Beeches SAC and SSSI is of particular concern with it being vulnerable to changes in air An increase in vehicles of this size would not produce a significant change in air quality quality. Discussions should take place with Natural England to ascertain whether air quality effect on the SSSI/SAC. The Agency has consulted Natural England as part of the changes will have an adverse effect on these locations. Although the initial report indicates preparation of the ES. Properties on Old Slade Lane are predicted to experience an minimal impact on the local area in terms of noise and pollution, it would be prudent to imperceptible increase in annual mean NO2 concentrations, with a maximum predicted guarantee alleviation measures should this not be the case in practice. increase of 0.3 µg/m3 at the property closest to the M4. 19/12/2014 066 Slough Borough 5.0 It should be noted that the entire section of the M4 within the jurisdiction of Slough The numbered points below reflect those in the representation from SBC: No Council, Slough Borough Council (SBC) to a buffer area of around 50m from the highway falls within an Air 5.0 The AQMA is identified in the ES Air Quality Chapter, sections 6.9 and 6.10, and has Borough Council - Quality Management Area (AQMA1). been considered in the Environmental Impact Assessment ("EIA") for the Scheme, as Planning Department 6.0 SBC latest Air Quality Progress Report 20141 clearly illustrates there are breaches of reported in the ES. the NO2 EU limits along the boundary of the M4. There are several hundred Slough 6.0 The air quality assessment undertaken as part of the EIA, has modelled 303 individual Borough properties that fall within the M4 AQMA1. properties within this AQMA. Of these, 11 are predicted to be above the air quality objective 7.0 To date, we have received no air quality action plan or low emission strategy from the for annual mean NO2 with the Scheme in place, and are predicted to experience a small Highway Agency in relation to the M4 and would welcome assistance in tackling the poor (0.4-2 µg/m3) increase in annual mean NO2 concentrations. air quality that afflicts our residents from the M4 motorway traffic in a progressive way. 7.0 The assessment undertaken for air quality is focussed upon the effect of the Scheme 8.0 The Highway Agency has a duty to ensure the impact of the strategic road network upon local air quality. This includes the evaluation of changes in air quality at sensitive does not give rise to harm to public health. The European Union have initiated infraction receptors with particular reference to locations anticipated to be subject to poor air quality in proceedings against the UK Government for non-compliance with (NO2) EU Limits2. the opening year of the Scheme. Mitigation measures to improve air quality are 9.0 Outdoor Air quality is one of the most significant public health issues affecting the recommended to avoid potentially significant air quality effects on this basis rather than on modern world, and there is growing body of medical evidence that the prolonged exposure existing baseline air quality. Those mitigation measures are detailed in Chapter 6 of the ES, to NO2 pollution may have longer term impacts on health in particular lung function and and are secured by the Outline CEMP, which is submitted as part of the Application.