A428 Black Cat to Caxton Gibbet Road Improvement scheme

Representations received regarding A428 Black Cat to Caxton Gibbet Road Improvement scheme

The list below includes all those who registered to put their case on A428 Black Cat to Caxton Gibbet Road Improvement scheme and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Colin Star-Butterlin
"my property is directly affected by the proposed routes"
Members of the Public/Businesses
response has attachments
Environment Agency
"Our Full Relevant Representations will be sent via email. Overview and issues of concern We reserve our right to add to or amend the matters set out in this Relevant Representation. We will keep the matters set out under review and update the Examining Authority on progress with the resolution of these issues at the appropriate point as the pre-examination stage or examination itself progresses. There are still a number of important outstanding issues that have been submitted as part of the draft DCO and accompanying information that require further attention or resolution. These are: 1. Flood Risk To ensure the scheme does not increase flood risk to or from the proposed route and to ensure we maintain operational access for river maintenance. 2. Navigation To protect this navigation route for river users. 3. Pollution Prevention To ensure satisfactory pollution control measures are in place and ensure maintenance or improvement of water quality standards within local water bodies. 4. Groundwater Protection and Contamination Further groundwater assessment is required. Assessment methodology requires adjustment. We have concerns over proposed continued dewatering. 5. Biodiversity Further updated ecological assessments are required. Consideration should be given to timings of works within watercourses to avoid sensitive times for biodiversity. These matters are discussed in full in the attached appendix."
Members of the Public/Businesses
Jack Pike
"The A428 will be on an intrusive embankment from visual an noise intrusion to [Redacted] and Chawston Lane."
Members of the Public/Businesses
John Wood
"The proposed route is near my house and I would like to see what potential disruption there will be. I approve of the road though"
Members of the Public/Businesses
Richard Watson
"As my home borders the existing A428, we are one of the closest houses to the new development. I am concerned that noise from the new road is properly managed by sufficient banking, cuts and screening for some distance either side of Croxton."
Members of the Public/Businesses
Simon Curtis
"It is my request that the position of the Black Cat interchange be relocated 250 Metres to the East from the planned location. The road should deviate from it's current line 570 Metres North of the Black Cat travelling due South in a straight line rejoining the current carriageway at a point 1638 Metres South of the current roundabout. The vast majority of the new interchange can be constructed with minimum disruption to the flow of traffic on the current A1/A428 roads By doing this one dangerous section of road being the Old Great North Road Wagon/Coach bridge which has been in that position since the 1660's will be removed plus several other road deviations. It will not be necessary to build the new separate access road to Kelpie Marina. Furthermore it moves the interchange further away from the Villages of Roxton and Chawston and will allow for much easier sound attenuating landscaping to be undertaken. Kind Regards Simon Curtis"
Parish Councils
Yelling Parish Council
"I was disappointed that the proposed EWR is given no mention in the application for the A428 when it is proposed to run alongside it. As a Parish Council we are keen that our tiny village is not disturbed with construction or diverted traffic during the work undertaken for the A428. It was a concern to learn that projected traffic volume through our village from West to East is only estimated at -20%. Pre Covid we had around 800 vehicles per hour at rush hour through the village so 20% reduction isn't at all impressive. Also an increase in traffic at the Toseland Crossroads from north to south is extremely worrying when this already carries a high accident rate as there are no STOP signs."
Members of the Public/Businesses
Jonathan Baker
"I fully support the proposed scheme, especially Black Cat Roundabout.. I was surprised with the A1 Black Cat junction the nearby Tempsford bends were not straightened out due to the close proximity of the 3 level junction. The situation on the A1;will be dangerous with motorists suddenly have to slow down to negotiate the the bend on the northbound carriageway. Generally the scheme has been designed well and will cut congestion."
Parish Councils
Toseland Parish Council
"Toseland is a very small hamlet, which, however, has deep historical roots, dating back not only to a Saxon/Danish barley farm mentioned in the Domesday Book as belonging to Countess Judith, but to the mesolithic era, according to archaeolgical finds in the village, which are logged on the Cambridgeshire Archaeology website. It is a quiet, tranquil rural community with no street lights and no light pollution produced within the village. Toseland Parish Council represents the interests and concerns of the residents and landowners within the Parish of Toseland, which have been exascerbated by the recent announcement of the favoured routes for the proposed East-West rail link as running alongside the proposed route of the renovated A428 (to be redesignated as the A421). The principal concerns relate to: 1. Loss of viable Grade 2 farmland, and of access to elements of this; 2. Permanent disruption of local ecology; 3. Destruction of potential archaeological features; 4. Increased CO2 pollution in the area; 5. Increased noise pollution in the area; 6. Increased light pollution in the area; 7. Potential problems with access to/use of local footpaths and bridleways if the Est-West rail route goes ahead in the same area. Our substantiated representation would centre on these concerns, paying critical attention to the assertions of the developers and other relevant documents."
Members of the Public/Businesses
James Tebboth
"Opportunity to Deliver the A428 Improvement and East West Rail Cost-Effectively I would like Highways England to consider how the delivery of this road scheme can be integrated with the delivery of the new railway line between St Neots and Cambridge. This could take several forms: * Where the routes of the two schemes run close to parallel * Where one route cross the other route * Where works (eg, earth works, culvert construction, rearrangement of utilities, footpath diversion, access routes) are in close vicinity Then there may be opportunities to integrate or at least coordinate the works. This will have several benefits: * More cost-effective - saving the taxpayer money overall when considering the schemes jointly - only one set of earth movements, one set of utility adjustment, etc. * Less disruption - having one combined set of works will be less disruptive than two sets of works over two separate periods * Less wasted work / rework - for instance if not integrated, it may be that a bridge needs building over the new road at a later to date, or some re-routing/adjustment is required, then this would caused rework which could be avoided if the two projects were considered together up front. I recognise that the road scheme is currently more advanced in planning than the new railway. At the very least, passive provision for the railway to be built afterwards should be made when building the road - eg, where a bridge is required, or the alignment of one needs to take the other into account. But for the reasons stated above, I think that the benefits of more closely integrating the delivery of the two schemes together will be significant. It may even make sense for the final choice of the route of the railway to take into account the benefit of being delivered alongside the road improvement. I urge Highways England and East West rail to collaborate closely so that as much benefit as possible can be realised by delivering the schemes together."
Members of the Public/Businesses
Steve Eldridge
"We approve of the scheme generally as it should finally reduce the congestion at the Black Cat. However, we do have concerns about noise from the A421 as it rises when it passes near Roxton. We were assured at the consultation that this section could use a low noise surface and have suitable bunding but we do not remember there being any woodland proposed at that section. That would be beneficial both for noise and visual reasons. We also spoke about the lack of noise reduction on the stretch of the current A421 passing Roxton at ground level where no noise reduction was provided when it was built a few years ago. We were told that there would be a chance to rectify this as part of the new scheme since it is precisely where the re-working of the A421 would start. Roxton residents feel they were let down by the lack of noise reduction measures when the bypass was built and hope that this can be rectified with the planned works."
Members of the Public/Businesses
Ann Kennedy
"I consider that the plans submitted by Highways England make inadequate provision for horse riders and carriage drivers, amongst the most vulnerable of road users. Cyclists appear to be being given priority over equestrian users. In particular, the arrangements between Roxton and Wyboston are, in my view, unacceptable as they make no provision for horses and make what is already a dangerous crossing even more so, compounding an error made when the A421 was built. I am told that the justification is that there is no need - but there are many local horses - who admittedly do not use the bridge much because it is dangerous - but would do so if it were safe. Just because people do not swim across a fast flowing river because it is dangerous does not mean that there is no need for a bridge over that river!"
Members of the Public/Businesses
Barton & District Bridleways Group
"I am the Chairperson for Barton & District Bridleways Group, which currently has 148 members. The group is concerned that in The Black Cat to Caxton Gibbet consultation there appears to be a lack of safe equestrian access included. The project has also not taken into consideration opportunities for improving and enhancing the fragmented Rights of Way network. This is quite frankly unacceptable and should be addressed in the Development Consent Order."
Members of the Public/Businesses
Lynda Warth
"The failure of the scheme to provide for safe equestrian access despite consultation with the British Horse Society since project inception. In particular, the removal of a safe equestrian crossing at Caxton Gibbet without any consultation or advice to the BHS. Inaccurate claims (no bridleway links) as to why equestrian access has been omitted. Missed opportunities to improve access for all non motorised users within this transport scheme. Use of out of date maps and information during the consultation period preventing proper consultation opportunities. This is a brief outline of my representation which I will be happy to expand on and provide more detail."
Members of the Public/Businesses
Brian Challis
"I wish to register an interest in this upgrade, as I use the route frequently to travel from my home to Stanbridge, Beds. to visit my daughter. Alternative routes are much longer and less convenient."
Members of the Public/Businesses
Charlotte Freeman
"I am interested in horse riders of Eltisley protecting our bridle paths and ensuring there are safe access routes around the new roads and layouts for safe equestrian activities."
Members of the Public/Businesses
Sarah Wynn
"As a rider I have kept horses in the village of toseland that neighbours this route. I am disappointed to see that the latest application does not take full advantage of the opportunities to provide safe off road access for horses as well as other users. I would be keen to see greater consideration given to how this scheme can be used to promote active travel of all types. There a a number of bridlepaths that cross the route and opportunities to provide greater connectivity that have been missed."
Members of the Public/Businesses
Catherine Florence Armstrong on behalf of West Cambridgeshire Bridleways Group
"We believe strongly in access for all and this project appears to have missed the opportunity for improving and enhancing safe off-road shared routes with equestrians. It is critical that such rights of access and rights of ways are a connected network of safe off-road use, especially now there is such a significant increase in traffic on our county's roads. There are increasing motor incidents with both cyclists and horse riders on the roads and it is imperative that this project includes safe access for equestrians on connected networks of rights of way. We have 39 active riders in our group and we are just one of many bridleway groups in this area, so there really is a definite need for equestrians to be considered along with cyclists and pedestrians."
Members of the Public/Businesses
CPRE Cambridgeshire and Peterborough
"PRE Cambridgeshire and Peterborough (CPRE) agrees with various local authorities who expressed concerns about the lack of provision of technical information and the applicants disregard the to responses sent during the pre-application stage. There was a one way consultation. CPRE received no response to our letter dated 22/04/2017. CPRE’s comments were not included in the “A428 Black Cat to Caxton Gibbet Improvements Report on Public Consultation”, February 2019. Likewise CPRE received no response (apart from acknowledgement of receipt) to our letter of 26/07/2019. There appears to be a lack of transparency by the applicant. The applicant appears to consider this application to be a ‘fait-accompli’. CPRE Cambridgeshire and Peterborough is concerned that the consultation only provided road based solutions to the A428 corridor. CPRE’s report, The End of the Road? (https://www.cpre.org.uk/resources/the-end-of-the-road-challenging-the-road-building-consensus/) reveals that road-building is failing to provide the congestion relief and economic boost promised, while devastating the environment. CPRE is also concerned that the A428 scheme needs to be integrated into other RIS2 studies in particular the A1 study, with it’s potential impact on the Black Cat junction, road modelling/alignment and resulting traffic flow changes. There is a failure to outline in detail how the A428 proposals form part of a joined up approach to a multi-modal transport solution. Consideration should be given to integration opportunities with other transport projects, ongoing and planned, in the A428 corridor or nearby. These include the proposed East-West Rail, Greater Cambridge Partnership Busway Programme and Cambourne to Cambridge Better Transport project and other ‘last mile’ proposals. There is a lack of adequate traffic modelling and demonstration of best value and a potential non-compliance with National Planning Policy statements on biodiversity effects of new developments. How does this scheme fit in with the UK Government’s agenda of “Zero Carbon” and target of net zero greenhouse gas emissions by 2050? In short, this scheme as proposed will increase greenhouse gas emissions, making national reduction targets harder to achieve, while simultaneously increasing the risk of ill health to current and future generations arising from increased polluting emissions such as PM2.5 particulates and oxides of nitrogen. For the reasons outlined above CPRE Cambridgeshire and Peterborough opposes the proposals and wishes to be registered as an interested party in the DCO process."
Members of the Public/Businesses
Geoffrey Digby
"This new road layout is important for the improvement of the local area and will reduce the fumes from the traffic delays."
Members of the Public/Businesses
ADL Traffic and Highways Engineering Ltd on behalf of McDonald
"Our Representation will relate to the existing McDonald's restaurant at the Caxton Gibbet Park Service Area and the highway works as shown on General Arrangement Plan Regulations 5(2) (O) Sheet 14. The restaurant is currently visible from the A428 and A1198 as customers approach the roundabout. The new grade separated arrangements require customers on the A428 to make an earlier decision if they wish to visit the services. Appropriate signage for the services must be provided so that drivers are able to make a safe and timely decision to access the slip roads. No signage plans have been provided with the submissions to demonstrate that this has been adequately addressed. The existing Service Area is accessed via a right turn lane on the A1198 which is shown as proposed to be removed with the new highway arrangement. The lack of right turn lane facility presents a risk to highway safety and is contrary to DMRB CD123 junction design guidance. The design of the highway at the Services Access is therefore unacceptable. Our representations also relate to the existing McDonald's restaurant at Wyboston. The proposed link to the Black Cat junction is a less direct link to the A1 and appropriate signage will be necessary to direct customers to the A1. No signage plans have been submitted with the application to demonstrate this has been adequately addressed."
Members of the Public/Businesses
Wyboston & Roxton Bridleways Group
"Safe access must be available to all vulnerable road users, cyclists, pedestrians and horse riders. There is a significant number of horse riders in this area who are members of the group, more than 117 people with at least two horses each. In relation to the ‘improvements’ at Black Cat and the proposal to lead all HGV 1. The bridge over the A428, Roxton Road, should be designed to equestrian standards, with horses separated from the increased levels of HGVs. The bridge will need to be designed to equestrian standards, in particular that it will need appropriate height parapets alongside the bridleway. The current bridge is considered unsafe by riders due to its lack of parapets and the lack of separation from the traffic. In particular, it cannot be used by young/inexperienced horses or children, of which there are a number in Wyboston. There is an incorrect perceived lack of need to provide equestrian height parapets, as horse usage of the current bridge is not regarded as significant. There are many riders, who would use the bridge if they considered it safe for themselves and their horses. Due to the closure of other HGV routes into Wyboston from the A1 Northbound, all HGV traffic with be diverted along a new route of a single road, bridge and roundabout. This will significantly increase risk of accidents and death amongst all road users. However riders are particularly vulnerable road users and Rule 55 of the Highway Code states riders should avoid roundabouts wherever possible. Appropriate bridge parapets and an alternative roundabout route are vital to mitigate risk. 2. The ‘shared footway/cyclepaths’ shown in red on maps 1 and 2 of the Updated General Arrangement Plans in your consultation should be upgraded to bridleway status 3. The provision of a parallel public bridleway running the length of the new A428 should include an underpass of the A1 so that this new bridleway is accessible by horse riders from the Bedfordshire villages. 4. A bridleway link is made from Wyboston to the current underpass under the A1 and through to Alpha Drive, St Neots. This could either be by creating a route further north from the route on Map 2 (although it would appear that this may be difficult to achieve) or by getting Footpath 37/A9 upgraded from the end of Northfield Road, Wyboston, through to Alpha Drive. 5. The gantry to be built by Bridleway 6 to the west of Black Cat is designed in such a way as to not impede or endanger use of that bridleway (plan 16E) 6. Speed limits should be imposed on the country lanes that may be used by diverted traffic during construction."
Members of the Public/Businesses
Cambridgeshire Local Access Forum
"The Cambridgeshire Local Access Forum (CLAF) is a statutory consultee for all Local Authorities and Statutory undertakers. We are concerned at the lack of Non-Motorised Users (NMU) access included in the project and the missed opportunities for improving and enhancing the rights of way network. Equally disappointing is that despite everything that has been learnt about the need for active travel safe access, the importance to health and well being of access to the countryside etc., the excuse for not providing this type of amenity as part of the project is that the project was conceived before the pandemic therefore the need for better access was not included. We find this utterly unacceptable to create a transport network now which will be in use for years and years and not to incorporate the massive changes that Covid has made on our society."
Parish Councils
Hilton Parish Council
"Hilton Parish Council is registering as an interested party on the consultation on the A428 Black Cat to Caxton Gibbet Road Improvement scheme Planning Inspectorate Reference: TR010044 because it wishes to express its desire for Highways England to take steps to prevent any construction traffic from using the B1040 through the village to and from the site when a suitable alternative route is available along the A1307 and along the A1198 for access to and from sites to the north of the new routing. During the construction of the A14 southern by pass Highways England made promises they were unable to honour concerning construction traffic not coming through the village so we would like this to be written into the DCO from the outset."
Members of the Public/Businesses
Shelford and District Bridleways Group
"I represent the interests of all Bridleways users in my area: walkers, cyclists and horse-riders. We are concerned that early-stage agreements regarding safe equestrian access within this development do not seem to have been followed through into the scheme as has now been presented. There is a terrible lack of joined-up, safe off-road access for Bridleways users throughout our County, which is so often a result of poor design of previous road schemes: where Rights of Way have been severed without thought for the continuity of the RoW network. New road schemes *should* be an opportunity for ensuring that these past errors are now corrected, and that the network is improved, in line with the commitments in the county's RoWIP. My group wishes to have the chance to make a representation regarding these issues of safe off-road access for all Bridleways users."
Parish Councils
David Pope on behalf of Elsworth Parish Council
"As a Parish we adjoin the A428 as it passes Cambourne. Our village suffers from rat running from vehicles avoiding the traffic jams at the Caxton Gibbet roundabout. We are concerned on two accounts: 1. That the absence of a free flow junction from the A1198 will mean vehicles will still rat run through our village 2. The possible siting of a new train station and then extra housing in this location, just north of the A428, will mean that there will be increased traffic at this junction and at Cambourne. Again the Caxton junction should encourage traffic flowing southbound on A1198 from Papworth (and from villages north) to use the A428 rather than rat run to get to the station."
Members of the Public/Businesses
Janet Good
"I have 2 teenage granddaughters who need safe places to ride and this is sadly lacking in our area.They do not ride over the bridge crossing the 421 as I believe it to be unsafe for riders. They would cerainly use it if it was made condusive to equestrians. Any improvements showing care for riders would be appreciated as safety is of primary importance."
Members of the Public/Businesses
Natalie Whitbread
"I am highly concerned that not enough consideration is being given to the horse riders and carriage drivers locally, my stables are located in chawston I can ride one of my horses over the Roxton bridge but fear for my safety and well being of my other horses so can’t use it as it stands with them due to the railings not being sufficient and not enough space and consideration being given by the current drivers on that road. I would like to ask that sufficient safety barriers on the new bridge be installed as many more of us would be able to safely use that route on a regular basis. We are very limited in the local area on safe spaces to ride and with the future increase in traffic load due to the proposed layout I think it is imperative for our safety and the safety of others. May I also suggest that the local authority upgrade a good number of the local footpaths to allow horses other safe routes to go, locally the amount of traffic during the proposed works is going to be horrendous and it’s already risky at the current levels, it may be wise to upgrade these footpaths to bridleways as a matter of urgency, there have already been a few accidents involving vehicles and horses/riders and I fear that it’s only a matter of time before it escalates to deaths in either animal or human form"
Parish Councils
Girton Parish Council
"The point we wish to make is that the proposed dualling of the A428 from Caxton Gibbet is a continuation of the existing dual carriageway section of the A428 to Cambridge. A possibly unforeseen consequence of this development will be to increase traffic movements along this road leading to unacceptably high congestion where it meets the A14 east bound and the M11 southbound. The recent A14 upgrade has provided a link to the A14 westbound but that to the east is only via a single lane. No improvements have been made to the M11 access which remains via the single carriageway A1303 where it crosses the M11. Following the removal of the link to the A14 East bound at Oakington/Dry Drayton Road, this junction is the only link to the southbound M11 other than directly from the A14 at Bar Hill. Current traffic flows mean that there is constant congestion along the A1303 at Madingley Hill and any increased traffic will make this intolerable. While the current pandemic has prevented proper assessment of congestion as the A428 leads to the A14 east it is likely that the restriction to one lane will lead to congestion and increase in air pollution in this area which already has poor air quality. We request therefore that as part of this project the links between the A428 and the M11 and A14 be upgraded to allow improved traffic flows. This will effectively mean an upgrade to the Girton Interchange to allow 4 way traffic movements. We would add that this must be achieved without adding to the level of noise and air pollution already experience by Girton village from the current raised sections of carriageway at this junction."
Members of the Public/Businesses
Josh Welby
"Yes, I agree with the whole scheme When I was living in Wyboston, Bedford next to the Black Cat Roundabout, there were many accidents on that Roundabout at one time one lane was closed, the fast lane towards the Roundabout from St Neots because it was full of Fire Engines attending an accident there Anything to improve the Road is most welcome, it is a very fast Road that links St Neots with Bedford Town Centre My Previous address was [Redacted] Thank You"
Members of the Public/Businesses
Camcycle
"Camcycle is a volunteer-led charity with over 1,550 members working for more, better and safer cycling for all ages and abilities in the Cambridge region. We focus on cycling as a mode of sustainable general transportation for everyday purposes. Many of our members transport themselves and their families using a wide variety of cycles, such as cargo cycles, tandems, tricycles, disability-adapted cycles and cycles with trailers. Our interest in the A428 scheme is to ensure that the five core design principles of Local Transport Note 1/20 are achieved for people cycling, alongside other active travel users. Those design principles are: safety, coherency, comfort, directness and attractiveness. Inclusivity must be integral to all of those principles. Furthermore, the A428 scheme as proposed will significantly increase motor traffic levels in the region, and correspondingly, it will significantly increase air pollution and carbon emissions. In light of the climate emergency, it is absolutely vital that every step be taken to prevent or reduce the increase of carbon emissions, and those steps must include major enhancements to active travel. Issues to be raised: 1. The A428 project must provide active travel connectivity for the existing and future settlements between St Neots and Cambourne. As currently planned, the A428 project mainly caters for motor vehicle users in that region, with only crumbs for active travel. This is unsuitable and does not comply with the government's Gear Change policy (2020), which requires all highway projects to provide active travel infrastructure in compliance with the five principles outlined above. We accept that active travel connectivity is best provided on a separate alignment from the dual carriageway; however, it is the principle of providing connectivity that must be established as part of this process. 2. The A428 project must provide suitably safe and convenient active travel crossings of busy roads and junctions, usable by people of all ages and abilities. As currently planned, the A428 project proposes several hazardous uncontrolled at-grade crossings of roads and junctions forcing people to brave very wide expanses of carriageway and high-volume, high-speed motor traffic. This is unsuitable: these crossings must be redesigned to make them much safer to use, so that they are accessible to everyone, as required by Gear Change and the Equality Act (2010). It is perfectly possible to design safe crossings for these contexts, however the project team has made it clear that they will do so only if they are directed to do so by higher authorities. 3. The A428 project (a) must not sever existing active travel routes and (b) where structures are planned to be built for the benefit of motorists who need to cross existing barriers (such as the A1, the River Great Ouse and the East Coast Main Line) those structures should incorporate provision that allows active travel users also to cross those barriers, such as with suitably designed active travel user side-paths on bridges. This effort may be coordinated with the East West Rail project, which is also designing infrastructure in the same region."
Members of the Public/Businesses
Chris Turner
"Increased traffic volumes on the A428 eastbound will encounter the inadequate Girton Interchange with the M11 and A14 where the A428 reduces to a single lane and queues form. This will cause some traffic to seek an alternative route and 'rat run' through the village of Dry Drayton where the class C road is already overloaded and its 30 mph speed limit is continuously exceeded. In my opinion, the A428 scheme should be required to also improve the Girton Interchange."
Members of the Public/Businesses
Carter Jonas LLP on behalf of Eynesbury Group
"Eynesbury Group consists of two separate companies; Eynesbury Plant Hire Co Ltd and Eynesbury warehousing operating out of our site at Potton Rd, Saint Neots, PE19 6XJ (the ‘Site’). Numerous customers visiting our Site each day; typically 30 – 40 HGV movements a day in addition to vans and cars. Together the companies have 17 employees. If approved the A428 scheme would take land from the entrance of the Site on both a temporary and permanent basis. Our principle objective is to protect the business and jobs of our employees by ensuring unfettered access to the Site is maintained throughout the A428 construction and operational phases. Specifically we note the following concerns and reserve our position to raise any further issues during the DCO Examination as relevant to the potential impact of the scheme on the Site: 1. The Site entrance needs to be able to accommodate large STGO HGV’s. Vehicle tracking design to be undertaken for vehicles entering and existing our premises from both directions. This is to include large rigid and articulated HGVs as well as emergency vehicles and refuse. 2. Local road to be moved as far back from our premises as possible to maintain suitable and safe access, vision splays & drainage. 3. We will need signage from the Abbotsley road B1046, directing HGV’s and visitors to ‘Eynesbury warehouse and Plant Hire depot’ otherwise all our HGV traffic following our postcode is likely to miss the turn towards us and end up in Abbotsley village where it would be difficult for HGV traffic to turn around. 4. Our Business name board that is currently situated by our entrance will need to be repositioned. 5. The junction off the B1046 that will bring traffic to us needs to be large enough and suitable for large STGO HGV’s to access the new link road towards our premises bearing in mind there could be more than one HGV at the junction at any one time. 6. The surface water drainage from the direction of Abbotsley golf course and neighbouring property’s that runs along the eastern edge of the road and under our main entrance into the adjacent ditch, needs to be considered as this will be cut off further downstream by the new bypass. Both our premises and neighbouring properties discharge into this ditch. We are therefore concerned how the surface water drainage will work once removed. Our neighbours had problems a few years ago when the part of the drainage system became blocked and caused properties to flood. Once the underground blockage had been cleared, the water drained away down the ditch freely so we know any interruption to the current drainage system could course serious issues. 7. We require our new entrance to be constructed of reinforced concrete as it is now. Tarmac will not be suitable. Once works complete we need to maintain freehold ownership of our entrance/crossover abutting the public highway as we do now. 8. We need to ensure that noise levels from the new bypass are kept to a minimum by introducing noise reducing measures. Not only for us but also for our neighbours. 9. Landscaping between our premises and the new by-pass to be carried out to minimise the impact the new bypass will have on us. 10. 24 hour access to our premises will be required during the works otherwise we will come to a complete standstill as we have multiple vehicles and HGV’s visiting both our Plant Hire Depot and warehousing facility. 11. Electric, phone lines, Broadband, water supply and drainage etc needs to be maintained at all times whilst services are redirected."
Parish Councils
Eltisley Parish Council
"Eltisley has been plagued with increasing rat run traffic for many years because of its proximity to the junction of the A428 and the B1040, which many drivers try to avoid. We hope that the new scheme will end our nightmare, but we fear that the opposite will be the case. Although the new scheme channels east west traffic past the village, it does nothing to alleviate the north south traffic short-cutting through the village. In fact, the proposed new layout of the Eltisley junction exacerbates the desire for traffic to find the shortest route. We have found that a significant volume of traffic travelling west from Cambridge on the A428 and then heading south on the B1040 will drive through the village to cut the corner to take a perceivably shorter and therefore faster route. We have evidence to show that around 300 cars a day take this route. Although cutting the corner through the village may not be faster, it is human nature to seek out a perceived faster route. A proportion of this traffic exceeds the village speed limits (speed watch data), alongside the village playground. Similarly, traffic travelling north on the B1040 will be unable to join the new trunk road at Eltisley, so will have to travel East on the old A428. Again, they are likely to cut through the village to access the old road because of the perceived short cut. Looking into the future we fear that the geometry of the new Eltisley Link junction will continue to perpetuate the rat running problem and an opportunity to solve it will be missed. Unfortunately, the Eltisley Link is designed as a dogleg with north south traffic expected to travel a significant distance along the ‘old’ A428 before turning back onto the B1040. We believe this will offer motorists, especially those with local knowledge, the temptation to continue to ‘cut the corner’ through the village. Compounding this is the design of the southerly roundabout at Eltisley. Traffic from the north arriving at the junction will be expected to turn right to head south on the B1040, whereas the natural expectation will be to take the southerly exit which will take traffic through the village. While signage will encourage drivers to take the correct route there will be many with local knowledge, entrenched habits and satnavs which will take them through the village. So, it would be much safer if drivers were denied that option by repositioning the roundabout. We would like to see north south traffic exit the southernmost Eltisley roundabout directly to the B1040. This would appear a cost-effective solution to keeping through traffic out of Eltisley, and making the village a safer, greener, and more pleasant environment."
Members of the Public/Businesses
Frances Stephen
"I am the owner of 2 horses, and regularly visit Wyboston to ride with friends. At present we won`t use the current bridge as it is unsafe to do so. Any new bridge MUST provide a safe passing for riders by installing a horse height parapet. My daughter rides with me, an d I would be terrified to allow her to pass over a bridge that meant that she could fall over the bridge should her horse spook at something. A bridge crossing must have the correct safety in place for all users to be deemed safe to use and not discriminating against those sections of society who use it for their own personal leisure pursuits."
Members of the Public/Businesses
Joanne Dagley-Cleworth
"i have two horses, and currently don't use the bridge over the A421 out towards roxton, but i would like to, Please can consideration be given to making this horse safe in the new development"
Members of the Public/Businesses
Brown & Co on behalf of Emma Louise Banks
"1. Our client is Miss Emma Louise Banks. Our client is the freehold owner of plot 1/45a and the land is currently occupied by Bates Bros (Farms) Ltd. 2. Our client is concerned that the works within this area do not impact on their retained land and are concerned about drainage flows within this area. 3. Our client does not see the relevance of plot 1/45a to the scheme and request that it is removed from the Development Consent Order."
Members of the Public/Businesses
Bletsoes on behalf of Lanesons Ltd
"We are instructed to act on behalf of Lanesons Limited of [redacted] who as tenant under an Agricultural Holdings Act 1986 tenancy of [redacted] are affected by the scheme with plots 9/6a-e. The representations are made without prejudice to making further objections/representations for different reasons, or in order to amplify these representations. We submitted representations to the supplementary consultation held in July 2020. Following the representations, we held an online meeting with Highways England and their consultants on 14th August 2020, during which Highways England undertook to provide various information and details and to respond back with comments in respect of the representations. Despite numerous requests for the information to be provided, Highways England has not provided any further feedback or detail. The proposed scheme will have a significant impact upon [redacted], severing [redacted] from the rest of the farm. The boundary of the road runs adjacent to the cottages with increased noise and visual intrusion from the proposed road and junction. The cottages need protecting from the noise and visual intrusion from mitigation works such as double glazing, bunding, landscaping, etc. We have sought greater detail to understand the impact of the road of the cottages and proposals for mitigation but this has not been provided. The access to [redacted] will be varied via the realigned A428. The access to the cottages is required to be available constantly throughout construction and subsequent to the road being built, for both private vehicles, delivery vehicles and for service vehicles. We have sought details of the design to ensure that the cottages can be serviced by the tanker emptying the private drainage, the dustcart, oil deliveries etc. Highways England has not provided this information. [redacted] are connected to a private sewage system which includes a soakaway connected to a ditch on land being acquired. Provision needs to be made for the continuation of the sewage system and appropriate arrangements or rights granted for the future. It would seem to make sense to arrange an appropriate discharge of the drains to land to the east being acquired by Highways England under Plot 9/7g. There is insufficient ground within the area left unacquired around the cottages in order to adequately provide for the continuation of the private drainage system. Due account needs to be taken during construction to ensure that the private drainage system continues to operate successfully. The proposed scheme will sever the existing services to [redacted], including the water supply which runs via [redacted] from the north west. It is important that throughout the construction phase and thereafter, the cottages maintain full services and that those are not interrupted. This will require bringing in a new water supply to replace the existing supply running from [redacted] which will be severed. [redacted] will be severely impacted during construction for noise, dust and vibration. Appropriate mitigation measures should be put in place. We have requested details of these but Highways England has not provided the information. The proposed road will also have a significant impact on the balance of [redacted] to the north including [redacted] being a residential property at the entrance track to [redacted]. Appropriate glazing, landscaping and bunding should be installed to reduce the visual and noise impact on these residential properties. The land being acquired has underground land drainage schemes and appropriate arrangements should be put in place to provide for and deal with the continuation of the existing land drainage schemes so as to not impact the drainage to the remainder of [redacted]. There is considerable concern regarding continued access arrangements both in and out of [redacted] and also to the wider area and that access is maintained at all times and suitable for agricultural vehicles to allow the business to continue to farm and operate. We had been promised by Highways England that a draft Schedule of Accommodation Works would be provided, following the online meeting in August 2020. Nothing has been provided. We would seek that accommodation works are discussed and agreed prior to the granting of the DCO to avoid the issues being faced with the A14 where accommodation works were not agreed until after a number of years after commencement of the road scheme."
Members of the Public/Businesses
Maxine Warner
"I have 3 horses at home in [Redacted], Wyboston. I currently do not ride them over the A421 bridge as it feels unsafe. The sides are not high enough. If the bridge had higher sides and the cycle way was also a bridle way, then I definitely would ride as it would enable suitable road exercise for my horses."
Members of the Public/Businesses
Brown & Co on behalf of Nicholas Wolstenholme
"1. Our client and his family are the occupiers of [redacted]. Of the 98.32 ha included within their Agricultural Holdings Act Tenancy, 14.22 ha are identified for acquisition as part of the proposed A428 scheme, which sees our clients farm severed by the new road. The Agricultural Holdings Act Tenancy is held by Mr Nicholas Wolstenholme. 2. Our client notes the proposals on sheet 3 of the rights of way and access plans which impacts severely on the existing farm access arrangements. 3. Our client seeks confirmation that the current access drive including all existing planting and signage are to be reinstated to the same finish as is currently in place and that the drive is constructed of a sufficient standard, size and construction to ensure it is suitable for all machinery and deliveries associated with the farm. 4. Our client notes that in respect of plots 3/10j and 4/1g that new rights are to be provided and it is understood that these rights will extend to Network Rail and Highways England only for the purpose of undertaking inspections of the bridge and that this route will not be used for construction purposes. Our client is concerned over frequency of visits and future maintenance. 5. Our client is concerned that the proposed field entrance identified within private access no. 24 is of a sufficient standard to allow farm machinery to enter this field and provide adequate turning circles. 6. Our client is concerned about ensuring access to their retained land throughout the scheme. 7. Our client has concerns regarding the provision of appropriate fencing along highway boundaries and concerns there is effective maintenance of existing drainage schemes. 8. Our client is also concerned over land drainage provision and requests that these are installed at an early opportunity. 9. Our client is extremely concerned over the provision of utility diversions to ensure that their electricity and mains water supplies remain uninterrupted throughout the scheme. 10. Our client is concerned to ensure that the proposed underpass within plot 4/1e and served by plots 4.1g and 4/1d is of an adequate size and width to ensure that all modern farm machinery can pass uninterrupted through this underpass and that the surface within this area should be concrete. 11. Our client remains concerned over the proximity of the proposed type A laybys and the security of their holding. Whilst the bunding and planting is welcomed in the context of providing privacy, it is requested that these laybys are also close board fenced to ensure that no unauthorised access is taken from the laybys onto our clients holding."
Members of the Public/Businesses
Emily de Gray
"I have been loaning a horse in wyboston for the last 3 years and we need more access to bridlesways as the current ones are around 2 miles away. If the cycleway over the bridge was changed so it included riders we would have more access to safe routes. The bridge isn’t current used by horse riders as the parapets are too low which makes it dangerous to cross. If the parapets were higher we would be safe to cross the bridge and it would open up access for a large equine community who currently either live in wyboston or keep their horses in the village. Please give this some careful consideration and allow access for horse riders too."
Members of the Public/Businesses
Geraldine Pearson
"I cannot use the crossings at Black Cat and A428 when riding or driving my horse. The present arrangement is too dangerous due to the proximity of heavy goods vehicles and fast moving traffic. I could make far more use of the area with the right type of crossing facility with high sides that can’t be jumped over and a wide and comfortable surface. Mounting blocks either end are also necessary for mounting larger horses who may be upset due to the traffic noise and speed below. Geraldine Pearson"
Members of the Public/Businesses
Hannah Hambleton-Jewell
"I am a veterinary surgeon & horse rider who lives in the local area. We have 4 horses on our yard, each with different riders. I have personally experienced many near misses riding on the roads in the area as I believe commuters often skip through the villages from the black cat roundabout to avoid traffic. These road users are often very impolite and drive very close, leaving minimal room & are unwilling to slow down. I really do fear for my safety, the safety of the drivers, other riders, cyclists & my horse. I have personally through work seen the damage that can be done in road traffic accidents involving horses & I believe it is only a matter of time a until a tragedy occurs on our roads. I also had an accident on my horse two years ago, where a bridleway bridge gave away underneath us and my horse got trapped. Thankfully I managed to get away without being injured but it was extremely scary. I also ended up having to call the fire brigade to help free my horse from this bridge. All of which could have been completely avoidable if there were more appropriate off road hacking routes in our area. It is for this reason I strongly urge you to consider the safety of people’s daughters/children/wives/mothers/fathers who all just enjoy getting out in the countryside with their horses and provide safer routes whilst there is the opportunity (during a time of development-which I suspect will only make the roads busier & more dangerous) and hence prevent an inevitable accident under the current circumstances."
Members of the Public/Businesses
Jacqueline Wieczorek
"I am concerned that the remaining old A428 road, having become a local road from St Neots to Caxton Gibbet (and vice versa) decants drivers onto the redesigned new roundabout at Caxton Gibbet, and from there we have to join the dual carriageway with all the non-local fast traffic and juggernauts, before we can leave at the Cambourne junction. Mixing slower (and possibly more timid) vehicles is not in my opinion a sensible idea. On return from Cambridge, we would have to leave the local road at Cambourne and attempt to join the A428 dual carriageway as far as Caxton Gibbet, negotiating the roundabout with the lorries and faster cars, before getting back to the new local road. The sensible link to avoid all this is nearly in existence- however it’s been designated for horses and bicycles only. Please see what can be done to avoid this design flaw, even though it’s not quite in the ‘project envelope’. Thank you."
Members of the Public/Businesses
Theo Cassell
"I sadly am unable to use the bridge due to the height of the sides - if they were to be higher I would ride my horse over the bridge regularly. With development of the area I feel it is important to provide safety for all road users cyclists and horse riders alike."
Members of the Public/Businesses
Lorraine Jewell
"Consideration be made not only for pedestrians, cyclists but also horse riders. Being a rural area the increasing of any roadways results in the need for safer routes across or under roads. So please always make cycleways/footpaths into bridleway to allow for all vulnerable ‘traffic’ (this may need to consider vulnerable wildlife such as frogs and hedgehogs?) My understanding is that for riders special height bridges are required. Many thanks"
Local Authorities
Bedford Borough Council
"Comments received from Bedford Borough Council in its capacity as Local Authority and Highway Authority: Bedford Borough Council Representations: 1.1 The Council is responding to this application for a Development Consent Order as Local Authority and Highway Authority. The Council will be making separate representations as a land owner. 1.2 Bedford Borough Council (BBC) do not object to the overarching principle of the development and it is recognised that there are benefits of the scheme for the Borough as this is a strategic scheme that will reduce congestion and improve journey times, particularly in the BBC area in and around the Black Cat roundabout, albeit with some local network changes. 1.3 At this stage further discussions are ongoing with the applicants and relevant Council Officers and some or all of the issues raised here may be resolved and clarified by the time we reach the hearings. At this time the key issues the Council wish to make representations about relate to: • Highways • Footpaths and Public Rights of Way • Heritage • Pollution and Noise • Air Quality • Contaminated Land • Borrow Pits • Wildlife and Ecology 2.0 Highways 2.1 The Traffic Operations team has agreed to the closure of three direct accesses onto the A1 (Chawston Lane, Nags Head Lane and The Lane) and has agreed preliminary designs for a new link road accessed from a new roundabout junction on Roxton Road, which allows access to all affected properties. The team has also agreed preliminary designs for the reconstruction and slight realignment of Roxton Road overbridge, and for new access arrangements to Kelpie Marina. 2.2 The Traffic Operations team has agreed to the scope and basic principles of the proposed de-trunking scheme, and will continue to work with Highways England on the detail of these proposals, particularly with reference to the viaduct over the River Great Ouse to the south of St Neots. 2.3 With regards to traffic management, diversions and construction management plans, the Traffic Operations team will continue to engage with the relevant Highways England technical teams on the proposed plans and will continue to review these as the details emerge. 2.4 The Transport Policy team has been kept informed of the development of the Traffic Model for the scheme by Highways England, and is in agreement with how it reflects the situation in Bedford Borough in current and future years. 2.5 Discussions have taken place between Highways England and the Transport Policy team on the impact of the scheme for bus users. However, further discussions will be required on the implications of detailed design during and after construction on the location of bus stops on the A1, and the impact on local bus services in adjacent villages. For cyclists, pedestrians and other non-motorised users, further discussion is required on local network access to and around the Black Cat junction. 2.6 The Council wishes to ensure that potential sustainable development in the area is not compromised by the design of the new road. It therefore wishes to be reassured that: • A junction on the new road to serve the proposed East West Railway stations in the area is deliverable. • Sufficient space to accommodate sustainable modes of travel is provided on the Barford Road overbridge. • Sufficient space for north-south pedestrian and cycle paths adjacent to the East Coast Main Line under the new road is maintained. 3.0 Footpaths and Public Rights of Way 3.1 No significant objections to the proposal however it must be ensured appropriate linkages for pedestrians and cyclists are maintained and created particularly where the new road crosses the railway lines. 4.0 Heritage 4.1 The Bedford Borough Historic Environment Team (hereafter Heritage Team) are satisfied that the pre-submission archaeological evaluation work comprising desk-based assessment, aerial photographic analysis, geophysical survey, and trial trenching provide an adequate baseline assessment of the archaeological potential within the proposed route. The assessment allows likely impacts on the archaeological remains to be predicted and a programme of archaeological mitigation work to be formulated. 4.2 The Heritage Team are not in agreement with the proposed Archaeological Mitigation Strategy as submitted and believe further discussion over required amendments is necessary in order to provide further detail and clarification on the work proposed and how it will comply with the Archaeological Design Brief prepared jointly with our counterparts at Cambridgeshire County Council and Central Bedfordshire Council. The Archaeological Mitigation Strategy appears to be trying to set the scope of the required works: however within development led archaeology in the planning system it is the LPA and not the applicant that sets the scope of the required archaeological works within a Design Brief, and the Archaeological Mitigation Strategy should then set out the methodology for meeting the requirements of the Design Brief. 4.3 The Heritage Team do not believe requirement 9 (Archaeology) within the draft Development Consent Order provides sufficient detail on the nature of the archaeological work: indeed alternative wording detailing the programme of work to include preparation of Site Specific WSI’s, fieldwork, post-excavation assessment and analysis, and publication and archiving should be agreed. Clear reference also needs to be made to the archaeological work following an Archaeological Mitigation Strategy and Site Specific WSI’s approved by the relevant LPA’s and prepared in accordance with the Archaeological Design Brief. 4.4 The Heritage Team are not in agreement with the terminology used in assessing the impacts on below ground archaeological remains within Chapter Six of the Environmental Statement (Cultural Heritage), it seems somewhat misleading to describe the effect on remains which will be permanently destroyed as being of ‘slight adverse effect (not significant)’. 4.5 The Heritage Team feel that the setting impact assessment on designated heritage assets contained within Chapter Six of the Environmental Statement (Cultural Heritage) would benefit from illustration of the impacts through viewpoints from and across (i.e. with the scheme in the background of an overall view of the asset) the affected assets towards the scheme and from the scheme towards the assets. These views could also use modelling to illustrate the scheme as proposed on these viewpoints. When conducting the assessment the focus seems to have been on changes to the visible setting of the monument with little account taken of other aspects of the setting such as changes to tranquillity etc. through increased noise. Finally there appears to be little assessment of setting impacts from the proposed borrow pits or in relation to ‘Parish Church of Saint Mary Magdalen’ (Roxton, grade II*). 4.6 Following the information submitted in 7.7 ‘Black Cat Junction Design Options’, the Heritage Team accept that there is no safe or viable way of retaining Brook Cottages (a grade II listed building proposed for demolition) in its current position whilst delivering the objectives of the scheme. 4.7 It is agreed with A.5.2.1 that demolishing without rebuilding Brook Cottages would constitute ‘substantial harm’ to its significance for the purposes of the NPPF. 4.8 However, the Heritage Team have advised that dismantling and reconstructing Brook Cottages could potentially result in a more preferable level of ‘less than substantial harm’ to its significance in this instance; particularly given the contribution currently made by setting and the method of the building’s construction. This depends on details and evidence which have not yet been provided as part of the application (see below). The applicant should be able to demonstrate that every effort to avoid the total loss of the statutorily listed building has been pursued, and there is no evidence within the application to show this. 4.9 The Heritage Team remain seriously concerned that Brook Cottages has not been subject to a detailed survey, and also that such a significant element of the scheme remains unresolved. Document 6.3 is limited in scope (accepted in the body of the text) and does not provide a strong enough evidence basis to justify the assertion that dismantling and relocating the timber framed building would not result in ‘substantial harm’ to its significance. The potential harm to the building following its dismantling, indeed if it could even be dismantled and relocated, has not been clarified by the applicant. The Council are concerned with the arguments set out in A5.6.4 and A.5.6.5, which ‘jump the gun’ in terms of the outcome of any detailed survey. The listed status (A.5.7) would be for Historic England and the Secretary of State to consider. 4.10 The Heritage Team remain seriously concerned regarding the applicant’s approach of seeking to offer the building to the Museum of East Anglian Life (A.5.6.1), which is put forward as the only alternative to its total loss (A.5.5.1). No contract has been produced, and therefore such plans can be afforded no weight at this stage. However, if as the Case for the Scheme asserts its reconstruction will result in substantial harm it is unlikely to prove an attractive proposition for any museum. The application does not demonstrate that an alternative approach has been sought, such as relocating the building within the vicinity of its current position within the Borough (an approach recommended by Officers). 4.11 For these reasons, Officers are of the opinion that the application cannot currently demonstrate that the listed building’s total loss has been clearly justified, as per paragraph 194 of the NPPF and paragraph 5.131 of the National Policy Statement for National Networks. 4.12 Requirement 16 of the DCO states that the method statement for demolition must “include an assessment to determine which structural elements of Brook Cottages are capable of reconstruction”. This should have already been resolved and should not be subject to a Requirement following the making of the Order given the building’s status. There is also concern that this work is of fundamental importance and not a matter which should be reserved for the post-Consent process. The question of whether the building can be reconstructed should be resolved prior to determination; with its eventual location (if feasible) subject to a Discharge of Requirement. On this matter, the Council would welcome the input of Historic England for guidance. 4.13 The Council requests an issue specific hearing on the impact on the historic environment. 5. Pollution and Noise 5.1 Whilst significant information has been supplied as to the potential impact of the operation of the prospective roads, there is very little data to consider for the construction phase and borrow pits. Most of the assessment considers that this will be in further detail at the more detailed design stage but this does not allow Environmental Health to consider viability at this time. 5.2 Areas are of concern with the information supplied at this time are; The noise monitoring was undertaken in 2017 more than three years ago which raises the concern that it is no longer reliable. 5.3 6.1 chapter 11 Noise and vibration • The Scoping assessment was undertaken in mid-2019 and no further baseline monitoring has been undertaken despite agreement with Local Authorities due to COVID. • Precise information on construction works not currently available and suggested to be confirmed at detailed design stage. • Multiple phasing is set to last 45 months if consecutive. Construction works listed in the noise report include utility works, site clearance, earthworks wall construction bridge demolition and road works. • Whilst it could be considered that earthworks may include the borrow pits there is no detailed information on these. • Whilst proposed mitigation systems are suggested these do not include re-siting of borrow pits and if the impact of those pits are unacceptable then this cannot be overcome other than potentially with the “temporary re-housing policy” • Without sufficient information on the use of borrow pits the information supplied at this time is insufficient. 5.4 With respect to the operation of the road once construction has completed, the information supplied in the document suggests that with suitable mitigation road level noise increases would not be a cause for concern. However it should be noted that the exact mitigation is again proposed at the detailed design stage 5.5 For this reason it would be appropriate for Environmental Health to speak at any formal meeting on this to raise our ongoing concerns and we must advise an objection at this time. 6. Air Quality 6.1 The air quality assessment indicated no significant air quality problems for Bedford residents. 7. Contaminated Land 7.1 The associated report indicated no issues of contaminated land and the nature of the proposal is not one that would cause concern from contaminated land. 8. Borrow Pits 8.1 The principle of identifying borrow pits for major infrastructure projects is supported. However, borrow pits are virtual quarries/landfill sites and can have similar environmental impacts. In order to be able to assess any impacts, there needs to be a description of how a site will be worked and then restored. 8.2 As part of the pre-application process, the Council had asked for details of the borrow pits proposed in the Borough area, so that any impacts could be adequately evaluated as part of the environmental impact assessment process. However, a meeting on the optioneering report held a day before the submission of the DCO provided too little detail, too late. 8.3 The Council is concerned that the only control over the borrow pits appears to be through the Environmental Management Plan (EMP). The EMP sets out a list of standard practises that could be applied to any similar development and is not site specific. The EMP contains no assessment of any potential impacts. It is does not appear that any of the topic related chapters in the Environmental Statement (ES) contains any assessment of the operation of the proposed borrow pits. 8.4 The DCO contains two requirements for iterations of the EMP. Whilst the second iteration EMP may be expected to contain more detail on the borrow pits proposals, it is not clear what further impact assessments will be provided at this stage. This brings into question whether the DCO currently contains a sufficient description of the proposal or a proper environmental assessment. 8.5 The procedure for the discharge of requirements (Requirement 22) places the authority for approval on the Secretary of State. It is questioned why it is considered that the Secretary of State should be the decision maker in matters of such detail rather than the relevant local authority. 8.6 Requirement 24 – Register of Requirements Following on from the point above, the undertaker is only required to maintain a register for a period of three years following the completion of the authorised development. Local authorities are required to maintain a register of planning applications and decisions with no end date. This applies to the smallest of developments. Why is it, that some of the largest developments in the country may be ‘invisible’ on the planning record after such a short time? The aftercare period for maintaining the landscaping may still apply after the requirement to keep a record of the approved details has expired. 9. Wildlife and Ecology 9.1 Agreed Points A suitable range of up-to-date ecological surveys which are based on evidence from the Bedfordshire & Luton Biodiversity Recording and Monitoring Centre and pre-application discussions have been completed. The DCO in Bedford Borough does not include any statutory or non-statutory wildlife sites, however, it does cross areas of the countryside with wildlife value and several significant commuting and/or foraging corridors. 9.2 Points for Further Clarification The entrances to the bat tunnel are fenced with a mammal entry point in the corner. It is recommended that this hole is slightly taller than the dimensions included on the current structure diagram. In 8.8.23 (it actually says 6.1.1, I think in error) the ES Chapter 8: Biodiversity makes reference to a Biodiversity Management Plan. The LPA’s representative have been unable to find this amongst the available documents but it is key to achieving the biodiversity enhancements and successful mitigation measures built into the scheme. Monitoring the use of the bat tunnel during the operational phase will be vital for evaluating the success of this mitigation feature within this scheme and for future bat mitigation elsewhere. The LPA’s representative was also unable to find monitoring plans within the documents provided, they should be part of the Biodiversity Management Plan. This eastern agricultural area of Bedfordshire has previously been recognised for its farmland bird assemblages and for raptors. The surveys for this scheme confirmed this and highlighted the presence of barn owls, red kite, hobby and other farmland birds. The road scheme includes woodland planting along the embankments in this section to try and reduce road casualties, particularly for barn owls. It is important to note that this would only become effective once the planting has matured and we would encourage early planting where possible. 9.3 There are no issues which need to be discussed at the formal hearing. 10. Conclusion At the stage there are areas which have been highlighted where the proposal is lacking detail and information. The Council will continue to work to seek clarification and agreement on these matters with the applicants prior to the hearings and some of these may require further in depth examination."
Other Statutory Consultees
Wilkin Chapman LLP on behalf of Bedfordshire and River Ivel Internal Drainage Board
"The Bedfordshire and River Ivel Internal Drainage Board (Board) is a public body and is named in the draft DCO which proposes to disapply section 23 and 32 of the Land Drainage Act 1991 (LDA91). in addition the DCO disapplies the Board's byelaws made pursuant to section 66 of the LDA91. The draft protective protections proposed by the DCO are not yet agreed by the Board and our representation is in connection with ensuring that the Board can continue to exercise its general supervision of all matters relating to the drainage of land and all other matters pursuant to the LDA 1991 within the relevant geographical areas affected by the Scheme."
Members of the Public/Businesses
Lara Davenport-Ray on behalf of Love's Farm Community Association
"Love's Farm Community Association represents the interests of residents (and future residents) living on the eastern edge of St Neots, Cambridgeshire. These residents will be directly impacted by upgrades to the A428/A421, specifically between the Little Barford roundabout and Eltisley. Our future representations will relate to the safety and well-being of residents, as well as the impact of visual and noise pollution on residents."
Members of the Public/Businesses
Mrs Julie Cox
"Dust will be one of the most inevitable consequence of your roadworks. With the Gravel and crushed gravel and hard rock aggregates always contain a proportion of fines, and if the material is dry, a fairly heavy dust cloud can be raised when it is mobilized. The resulting dust can disturb both the population and the local environment. Excess dust production can be treated by a range of means such as watering so will you be actioning this? Or the use of alternative materials, and by using dust binders near houses. Will we be notified of dust levels; we are concerned for our parishioners who we know this could affect? traffic queues are likely to cause unsafe scenarios creating ‘rat-runs’. the fact we have a primary school located on the main road leaving the village with no speed restriction Suitable access for all including bikers, bridleways, walkers and disabled. Under Part I of the Land Compensation Act 1973 (‘the Act’), compensation can be claimed by people who own and also occupy property that has been reduced in value by more than £50 by physical factors caused by the use of a new or altered road. The physical factors are noise, vibration, smell, fumes, smoke and artificial lighting and the discharge on to the property of any solid or liquid substance. The cause of the physical factors must be the new or altered road in use. For example, if a road is altered, the noise and other adverse effects must arise from the traffic using the altered stretch of road. The most damaging effects of road construction is noise. Noise is defined as a sound that is undesirable to the listener. The level of the disturbance caused by sound will depend on its extent and intensity, and on the sensitivity of the persons affected. The Bung you have suggested is not suitable it is not stretching far enough; it will not stop the traffic noise. We will require either a far greater height than 3 meters as sound travels as the sound of sight. As this will be a continuous noise 24/7. We would consider Acoustic fencing but would have to be suitable to stop the noise of all vehicles. public transport, how will this be affected? Work taking place overnight will we be notified? A1 the new access to Kelpie Boat yard. how this will be screened from the village. My biggest concerns is what will be built around us after the construction. Petrol station, hotels and fast food chains. What are the plans for infill lands? When will we know off any land you plan to increase Roxton and local villages traffic visitation? Light pollution, will be lit up over the night time, how is this going to dealt with. How are you repaying the Roxton village residents with disruptions for 4/5 years. What grants that’s you have available to help compensate. Are you helping local groups, churches, sports and anyone effected by road closures when they occur."
Members of the Public/Businesses
Rosemary Neale
"I live in close proximity to the current bridge over the A428. I own 4 horses, three of which I drive (ie in a carriage) and one is ridden by my [Redacted] year old granddaughter. We never use the current bridge as it is too dangerous with traffic travelling too fast but would use it to get to the bridleway network around Roxton if it were to be made safer by having a horse height parapet and ideally making the proposed cycleway into a bridleway. Currently we have little or no off road riding and often fear for our lives with the traffic travelling far too fast on our country roads - if this is to include HGV traffic using the road bridge to get to the A! then we are effectively marooned in our property. There are many horse riders and owners (mainly women) in this area and national statistics show that many more cyclists are men so you are effectively discriminating against the female population who wish to take part in their preferred form of exercise."
Parish Councils
Roxton Parish Council
"The Black Cat roundabout development is a significant infrastructure project that will have short term and long term impacts upon the village of Roxton and upon the health and wellbeing of its residents. To this end, Roxton Parish Council (RPC) have spent a considerable amount of time reviewing and considering the development plans and looking at ways that the villagers can benefit from the new road infrastructure and from general improvements to the surrounding area. To this end, Roxton Parish Council wish to make representations on the following points: 1.0 Noise and Air Pollution during construction and post construction; regarding post construction RPC believe there is insufficient acoustic screening provided. Significantly more soft landscape screening can address both noise and air pollution as well as minimising the negative visual impact of the works. The land between the new Kelpie Marina access road and the A1 have created an opportunity to provide a new patch of native woodland that would in small part reduce the noise and air pollution experienced in Roxton. RPC challenge the extent of the DCO red line; there is an opportunity to fulfil promises made to parishioners during the consultation process of the Gt Barford bypass circa 2000-2005 to protect Roxton from road noise. RPC insist the red line is extended towards the High Barns bridge to extend the acoustic bund & planting along the A421. 2.0 RPC insist that solid barriers are provided along all elevated sections of road/bridge to minimise light pollution from headlights. RPC insist that all lighting poles be fitted with directional lamp heads to deflect light spill away from Roxton. 3.0 Safety in and around the T-junction of new Roxton Road Bridge and C44; RPC insist that this junction be in the form of a roundabout not a T-junction. This junction has experienced many accidents and at least one fatality over recent years. As all existing traffic currently accessing & exiting the Wyboston area onto the A1 will now use the new Roxton Road Bridge this significantly increases the volume of HGV & personised vehicles using this junction those increasing the danger. For the same reason the parapets on the new bridge should be increased to prevent all vulnerable road users from falling over onto the A421. RPC insist that the new 40mph speed limit along the C44 be implemented from day one of the works. 4.0 Highways England should demonstrate how the works will facilitate future means of road, cycle & footpath access from Roxton to the future train station planned at St Neots South/Tempsford North on the East West Rail line. In conclusion by increasing the soft landscape screening to at least 20m from the A421 and A1, Highways England could provide meaningful protection to the long suffering parishioners of Roxton from the air and noise pollution that will inevitably result from this project. RPC look forward to the opportunity to expand on these issues during the DCO examinations."
Members of the Public/Businesses
Simon Barber
"This dual-carriageway replacement for the A428 will bring no benefit at all to the local communities.The new road will affect green belt areas and will bring more traffic travelling between Cambridge and Milton Keynes.Traffic is already increasing with new housing developments along that corridor. The increased road traffic will in turn increase CO2 emissions by 3.5million tonnes and also air pollution(a serious health emergency),both of which the Government is pitifully complacent. Meanwhile the following measures should also be taken: Upgrade crossings on existing A428 to improve safety for pedestrians,cyclists and horse riders,and create more convenient off-road routes. Improve landscaping by planting locally-sourced trees and shrubs. Changes to current local access roads to help improve driver access."
Members of the Public/Businesses
Alan Thawley
"I object to this scheme on the grounds that road capacity increases are incompatible with the climate emergency declared by this country. Rather than improving emissions, road schemes only create more traffic through induced demand, meaning they ultimately fail to alleviate congestion as well as emitting more carbon and diverting resources from genuine traffic reduction schemes."
Members of the Public/Businesses
Amanda Yorwerth
"I oppose this scheme on the basis of the enormous carbon dioxide emissions that it's construction and use will cause. We are in a climate emergency and we should be spending money on carbon saving, not carbon emitting projects."
Members of the Public/Businesses
Astra Carter-Marsh
"I am objecting on the grounds that major road building projects will prevent the U.K. meeting it's carbon budget and contribute to climate change."
Members of the Public/Businesses
Christine Mayles
"I have two points to make about the area affected by the proposals for the Black Cat Roundabout and the surrounding; 1) Firstly, there needs to be an air and noise pollution monitors put in the village of Roxton. We are currently sandwiched between two major roads. With a big expansion of the Black Cat Interchange the village should have its air quality and noise levels monitored now to provide a baseline and continually monitored during construction and thereafter when this new junction is in use. This will enable public health issues to be predicted and dealt with as they happen and enable the parish council to re-assure residents for both now and for any future developments that they are safe from particulate matter and nitrous oxides and other associated pollutants. 2) Roxton and Wyboston suffer from a distinct lack of bridleways nearby. To get to a bridleway involves a long initial ride on roads and there are no accessible circular routes. As a horse owner whose horse resides in Wyboston, the current bridge over the Bedford Bypass is dangerous as it does not have high enough barriers to make it safe for horse riders. Myself and my children do not use it on horseback for that reason. This needs to be changed to make it safe for riders. Plus any plans for the road network need to take into account walkers and riders access to current routes both during and after construction."
Members of the Public/Businesses
CTC Cambridge part of Cycling UK
"A428 Black Cat to Caxton Gibbet Road Improvement scheme Planning Inspectorate Reference: TR010044 Relevant Representation Summary from CTC Cambridge CTC Cambridge are the local member group of Cycling UK. CTC Cambridge is the local member group of Cycling UK. Our primary activity is a local cycling club that organises led rides for members and guests. Our rides take in a wide area of Cambridgeshire and the neighbouring counties and the area that is affected by the A428 scheme is well within our riding range. We understand that good quality cycling infrastructure should be included as part of all new transport projects in order to comply with the latest Government policies on Active Travel and to meet the Government target for Greenhouse Gas emission reductions. We think Highway England have failed to update their plans to reflect these new requirements and the active travel elements need to be greatly expanded in order to match the ambition of these Government policies on Active Travel. We think the scheme as currently proposed by Highways England fails to meet this new level of ambition for Active Travel and is therefore incompatible with the Government’s published objectives to make a step change in actions to support active travel. It is also incompatible with the Government’s published objectives to reduce greenhouse gas emissions. We therefore argue that this scheme needs to be redesigned and expanded in scope to include a more complete (continuous) network of direct, well-designed, separated cycle routes as an integral part of this SRN scheme. We have identified some of the needed changes in our earlier letter and again in this submission. We understand that Highways England should be designing new road schemes in accordance with RIS2. We consider that this scheme does not meet the relevant requirements laid down in RIS2 for non-motorised users. For example, RIS2 contains the following statements: Page 22: Improved provision for non-motorised users: As well as short-term action to make it easier for these users to travel along or across the SRN, in the longer-term good quality alternative routes for non-motorised users will be an integral part of the design of the SRN. Page 42: Cyclists, pedestrians and equestrians Investment in the SRN can support this agenda by improving cycling and walking provision along trunk ‘A’ roads, and reducing severance effects where local cycling and walking routes cross the SRN or are separated completely by it. Together with the Department’s new future of mobility strategy, they are designed to promote mode shift and assist the transition to a greener and cleaner society. In the long-term, our vision will mean that non-motorised users will be able to access good quality routes for their journeys segregated from an SRN that primarily serves long-distance, higher speed traffic. Provision for these users will be considered in plans for enhancements and major renewals to the network from the start, ensuring that all current users of the SRN benefit from investments. We argue that the current plans for the A428 scheme fall well short of providing the good quality cycling and walking routes that are required under RIS2 as specified in these extracts. Highways England claims that any necessary active travel infrastructure can be provided as part of the Users and Communities Designated Fund scheme within RIS2. We think this is a wrong interpretation of RIS2 and we consider that this is also wholly unrealistic for the reasons detailed below. Failure to provide much more substantial active travel infrastructure as part of the planned A428 scheme is therefore incompatible with the latest Government Policy. RIS2 makes several strong statements about the need to improve provision for active travel. RIS2 does recognise that further improvements to the active travel network can be delivered by the designated funds scheme, but the key words here are “further improvements.” The Designated Funds scheme offers very limited funding and it cannot provide a meaningful replacement for inadequate provision for active travel in the original scheme. As a concrete example, we think a complete active travel route between Cambourne and St Neots should be included in the SRN scheme from the start. This cannot realistically be postponed and/or delegated to the designated fund scheme for several reasons. Most obviously the scheme is too large to be funded using designated funds: the designated fund scheme is a national scheme that can only deliver relatively small improvements to the active travel networks. The scheme funding is spread too thinly and has insufficient funds to deliver major pieces of active travel infrastructure. Moreover the designated funds scheme requires matched funding from local authorities and again a scheme of this magnitude is not affordable by the cash-strapped local authorities. On top of this, it is also much more expensive to add this scale of active travel infrastructure later as part of a separate project due to the difficulties of the land acquisition that will be required (without having the benefit of the land purchase powers that are provided as part of the core scheme) and it is also more cost effective to build the active travel elements at the same (e.g. using the same contractor for all the work). For all these reasons we argue that much more active travel infrastructure work must be included within the SRN scheme itself and cannot be excluded from the core scheme as currently proposed. For the A428 scheme there are several areas where the scheme fails to address the needs for Active Travel Users and where major changes to the plans are needed. 1) The need for a continuous active travel route between Cambourne and St Neots. 2) The need for signal controlled or grade-separated crossings on any new roads where the expected traffic volume and traffic speed make this the required option under LTN 1/20. 3) The need for an improved crossing of the A1 for Non-Motorised Users in the vicinity of the Black Cat junction. 4) Mitigation measures on the adjacent road network especially where the traffic levels are significantly affected by the proposed scheme. Of these items, we consider that only last item (4) can be reasonably delivered by the Designated Funds scheme and that the other three should therefore be provided as part of the core scheme. In conclusion, we would remind you that CTC Cambridge, along with other campaigners, have been talking to Highways England and asking for these changes since the first plans for this scheme were published. Despite our patient and detailed engagement with them, Highways England have refused to make any substantial expansion of their limited plans for active travel infrastructure. Instead they have proposed to use the Designated Funds scheme, despite this being manifestly unsuitable as detailed above. We hope that this enquiry will use its powers to demand that HE make the needed changes to add a much more substantial quantity of Active Travel infrastructure into the core SRN scheme. CTC Cambridge; June 2021"
Members of the Public/Businesses
Bletsoes on behalf of Diane Angela Sharman
"We represent the interests of Mrs Diane Sharman and the Partners of the farming partnership, H G Sharman & Son of [redacted], who are directly affected by the Scheme; the current partners are Diane Sharman, Robert Sharman, Cathryn Sharman & Rebecca Sharman. Mrs Diane Sharman owns land directly affected by the Scheme, which is farmed by the partnership. In addition, the partnership are tenant of several parcels of land directly affected by the Scheme. On behalf of Mrs Sharman and the partnership, we are instructed to make outline representations. Representations are made without prejudice to making further objections/representations at a later stage for different reasons, or to amplify these representations. We have reviewed the plans included within the Developer’s application insofar as they relate to our clients’ and these representations are based upon the information contained therein. The plans do not provide sufficient detail to ascertain the full impact on my clients’ requisite interest. We would therefore like to formally record our principle concerns, based upon the information that is available. We do not wish to be put in a position whereby when it comes to the ‘detailed design stage’ we are told that design issues raised should have been dealt with earlier on in the scheme and it is too late. The Developer cannot say they will deal with matters in dispute at a later stage. These issues should either be dealt with during the application process or determined by the Planning Inspectorate. We submitted representations to the supplementary consultation held in July 2020. To date, we have not received a formal response. Our clients’ wish to make clear their principle concerns: Land East of Roxton Road and North of A421: The northern part of this parcel of land is owned by Mrs Sharman, and the southern part is rented by the partnership; both parts are currently farmed as one by the partnership. During previous consultation with the Developer, we requested detailed design information concerning the proposed accesses to assess whether access will be equally commodious. From the information available, it is not clear whether the existing access will be affected. We have had verbal assurance from the Developer’s representatives the existing access will not be affected, and my clients’ have relied upon that assurance. During previous consultation, we questioned the need for a proposed new ditch given the free draining nature of the soil in this location. If a ditch is considered necessary, we requested that the ditch be aligned closer to the Scheme to reduce the amount of land lost. Following recent discussions with the Developer, we are told the alignment is necessary to avoid an existing underground gas pipeline. The Developer confirmed they would seek confirmation as to whether the ditch is required. Our clients’ object to the provision of the ditch in this location and its proposed alignment. Land South-East of Roxton Garden Centre: The northern part of this parcel is rented by the partnership. The southern part is owned by Mrs Sharman and farmed by the partnership; both parts are currently farmed as one. During previous consultation, we highlighted the short-term development potential of this land. The land is being actively promoted for commercial development in conjunction with Roxton Garden Centre and other adjoining land. We understand that a Planning Application has been submitted in respect of this land. Therefore, the land has an increased value over and above its agricultural value, meaning the compensation will be vastly greater than for agricultural land without development potential and the cost to the taxpayer will be greater. The provision of a new access to Kelpie Marina and a flood storage area will require the permanent acquisition of the majority of my clients’ own land, and a significant amount of land they rent. During previous consultation, we requested the new access road to Kelpie Marina be aligned closer to the A1, and the flood storage area moved to land without development potential, to mitigate compensation. Neither of these requests have been accepted. In recent discussions with the Developer, we reiterated the development potential of this land and once again urged the Developer to reconsider their plans for the new access to Kelpie Marina and the flood storage area. The Developer confirmed they would investigate whether their plans could be changed. For the avoidance of doubt, our clients’ object to the current proposals and require the access road to be routed elsewhere or aligned closer to the A1, and the flood storage area to be moved to land without significant development potential. If the Scheme is consented in its current form, the Developer has confirmed that a separate legal access will be provided to my clients’ land distinct from the land they rent. My clients’ have relied upon this assurance. Land North of Chawston Lane, Chawston: This parcel of land is rented and farmed by the partnership. Our clients’ primary concern relates to the proposed layout of the new junctions onto Chawston Lane. The new junctions are offset from each other by approximately 50m, effectively creating a chicane for vehicles. This may present a problem for vehicles with restricted maneuverability, such as heavy goods vehicles and agricultural traffic. We understand the proposed side road will be the principal access to H E Payne (Transport) Ltd who operate a significant fleet of heavy goods vehicles. We once again urge the Developer to reconsider their proposals and align the junctions opposite each other or as close to that as possible. We understand local residents have expressed similar concerns. Accommodation Works: We have on numerous occasions reiterated the need for accommodation works. We require further details on the proposed accommodation works to ascertain the full impact on our clients’ requisite interest. As a minimum, our clients’ require commodious access, post scheme land drainage, and fencing and hedging of boundaries to mitigate the detrimental impact of this Scheme. East West Rail: We have also asked the Developer for further detail on how their Scheme will relate to the proposed East West Rail, as in some places it appears to use the same land."
Members of the Public/Businesses
Bletsoes on behalf of Diane Sharman, Robert & Catherine Sharman & Rebecca Sharman
"We represent the interests of Mrs Diane Sharman and the Partners of the farming partnership, H G Sharman & Son of [redacted], who are directly affected by the Scheme; the current partners are Diane Sharman, Robert Sharman, Catherine Sharman & Rebecca Sharman. Mrs Diane Sharman owns land directly affected by the Scheme, which is farmed by the partnership. In addition, the partnership are tenant of several parcels of land directly affected by the Scheme. On behalf of Mrs Sharman and the partnership, we are instructed to make outline representations. Representations are made without prejudice to making further objections/representations at a later stage for different reasons, or to amplify these representations. We have reviewed the plans included within the Developer’s application insofar as they relate to our clients’ and these representations are based upon the information contained therein. The plans do not provide sufficient detail to ascertain the full impact on my clients’ requisite interest. We would therefore like to formally record our principle concerns, based upon the information that is available. We do not wish to be put in a position whereby when it comes to the ‘detailed design stage’ we are told that design issues raised should have been dealt with earlier on in the scheme and it is too late. The Developer cannot say they will deal with matters in dispute at a later stage. These issues should either be dealt with during the application process or determined by the Planning Inspectorate. We submitted representations to the supplementary consultation held in July 2020. To date, we have not received a formal response. Our clients’ wish to make clear their principle concerns: Land East of Roxton Road and North of A421: The northern part of this parcel of land is owned by Mrs Sharman, and the southern part is rented by the partnership; both parts are currently farmed as one by the partnership. During previous consultation with the Developer, we requested detailed design information concerning the proposed accesses to assess whether access will be equally commodious. From the information available, it is not clear whether the existing access will be affected. We have had verbal assurance from the Developer’s representatives the existing access will not be affected, and my clients’ have relied upon that assurance. During previous consultation, we questioned the need for a proposed new ditch given the free draining nature of the soil in this location. If a ditch is considered necessary, we requested that the ditch be aligned closer to the Scheme to reduce the amount of land lost. Following recent discussions with the Developer, we are told the alignment is necessary to avoid an existing underground gas pipeline. The Developer confirmed they would seek confirmation as to whether the ditch is required. Our clients’ object to the provision of the ditch in this location and its proposed alignment. Land South-East of Roxton Garden Centre: The northern part of this parcel is rented by the partnership. The southern part is owned by Mrs Sharman and farmed by the partnership; both parts are currently farmed as one. During previous consultation, we highlighted the short-term development potential of this land. The land is being actively promoted for commercial development in conjunction with Roxton Garden Centre and other adjoining land. We understand that a Planning Application has been submitted in respect of this land. Therefore, the land has an increased value over and above its agricultural value, meaning the compensation will be vastly greater than for agricultural land without development potential and the cost to the taxpayer will be greater. The provision of a new access to Kelpie Marina and a flood storage area will require the permanent acquisition of the majority of my clients’ own land, and a significant amount of land they rent. During previous consultation, we requested the new access road to Kelpie Marina be aligned closer to the A1, and the flood storage area moved to land without development potential, to mitigate compensation. Neither of these requests have been accepted. In recent discussions with the Developer, we reiterated the development potential of this land and once again urged the Developer to reconsider their plans for the new access to Kelpie Marina and the flood storage area. The Developer confirmed they would investigate whether their plans could be changed. For the avoidance of doubt, our clients’ object to the current proposals and require the access road to be routed elsewhere or aligned closer to the A1, and the flood storage area to be moved to land without significant development potential. If the Scheme is consented in its current form, the Developer has confirmed that a separate legal access will be provided to my clients’ land distinct from the land they rent. My clients’ have relied upon this assurance. Land North of Chawston Lane, Chawston: This parcel of land is rented and farmed by the partnership. Our clients’ primary concern relates to the proposed layout of the new junctions onto Chawston Lane. The new junctions are offset from each other by approximately 50m, effectively creating a chicane for vehicles. This may present a problem for vehicles with restricted maneuverability, such as heavy goods vehicles and agricultural traffic. We understand the proposed side road will be the principal access to H E Payne (Transport) Ltd who operate a significant fleet of heavy goods vehicles. We once again urge the Developer to reconsider their proposals and align the junctions opposite each other or as close to that as possible. We understand local residents have expressed similar concerns. Accommodation Works: We have on numerous occasions reiterated the need for accommodation works. We require further details on the proposed accommodation works to ascertain the full impact on our clients’ requisite interest. As a minimum, our clients’ require commodious access, post scheme land drainage, and fencing and hedging of boundaries to mitigate the detrimental impact of this Scheme. East West Rail: We have also asked the Developer for further detail on how their Scheme will relate to the proposed East West Rail, as in some places it appears to use the same land."
Members of the Public/Businesses
Bletsoes on behalf of Edward Wootton
"The proposal affects a small parcel of land - Plot 2/17a. Access from the new road to the adjacent land should be provided at this location. Screening should be provided."
Members of the Public/Businesses
Isaac Beevor
"The expansion of a road is a travesty in a climate emergency. 1) This scheme will not produce long-term benefits due to the induced demand, a well evidenced and documented issue, that means that any minimals gains in traffic/commute time will be lost within a decade. 2) This scheme will negatively impact the environment by: a) encouraging more cars on the road. b) the embodied emissioms created through the materials needed to build the road 3) Due to this widening of the section of the road it will just replace the bottleneck further down the road, causing the traffic jam to be somewhere else. 4) By encouraging more cars on the road it will negatively impact air pollution which kills both people and nature. It is not in line with the UKs national carbon budgets. I hope this extension of the road is not built for the above 4 reasons."
Members of the Public/Businesses
Mini Grey
"This road scheme would increase carbon emissions by over 3 million tonnes (the third worst scheme in the RIS2 roads programme for carbon). I am rgistering my objection on climate grounds."
Members of the Public/Businesses
Nick Gellatly
"I support the proposed upgrading to the A428. The recent expansion in housing developments in this part of England, and to the west, means that improved infrastructure is required to ensure the safe passage of vehicles and their occupants to the East including Cambridge. I do think, however, that the opportunity to improve connectivity between St Neots and the towns and villages between there and Cambridge should also be improved, not least to provide improved opportunity for cycling - particularly in view of the growth and potential growth in e-cycling."
Members of the Public/Businesses
Nilam Moorcroft
"I object to this scheme on environmental grounds as it will increase carbon emissions to catastrophic and unacceptable levels.This is not where we should be heading in the year when the U.K. is meant to be giving a lead at COP27, or indeed at any other time given the need to address climate change and environmental issues."
Members of the Public/Businesses
Strutt & Parker on behalf of Tempsford Estate
"We reiterate our previous representations to Highways England for the widening of the proposed A428 bridge over the East Coast Main Railway, providing a private farm bridge and internal estate and farm access road thereby reducing the need to take large tractors and other agricultural machinery through Tempsford village via Station Road (with potential safety implications), a generally narrow road made worse and frequently impassable with parked vehicles either side."
Members of the Public/Businesses
Bidwells on behalf of The Executors of N A Alington
"EXECUTORS N ALINGTON DECEASED – LITTLE BARFORD ESTATE Plot no.s 43a, 43b, 43c, 43d, 51a, 51b, 51c, 51d, 51e, 51f The Executors own and occupy the Little Barford Estate located to the south east of St Neots. The Estate extends to 451 hectares and comprises farmland and woodland, farm buildings, cottages, and houses. The principal activity is arable farming, on 332 ha at Top Farm where agricultural operations are centred. The alignment of the A428 severs the main block of farm land, separating the farm buildings from farm land, the means of access to the public highway and to the remainder of the Estate; the under pass on the East Coast main line being too small for modern agricultural equipment. The Executors’ objections to the scheme and matters on which consultation is required are:- 1. General The route selected severs the Estate disrupting the main estate business. The Executors are aware of other representations by Central Bedfordshire and Bedford Borough Councils which seek to ensure sustainable modes of travel are incorporated in the design of the scheme so as not to prejudice due process in the consideration of housing and employment growth options for those authorities. The Executors support CBC/BBC representations in respect of seeking a segregated cycle lane on the Barford Road including on the overbridge, north-south pedestrian and cycle paths adjacent to the East Coast main line under the A428 improvement, and confirmation that the status of the A428 does not prohibit new junctions on to the new road in the future. Disregarding these creates the probability of future disruption to the Estate. 2. Permanent/Temporary Land Take The permanent land takes extends to 21.8ha and includes land to be planted to woodland or other environmental mitigation. This creates significant intrusion to the Estate, severed access to arable land, and third party access rights. The Executors require that woodland and environmental mitigation areas are rearranged and taken on a temporary basis being returned when woodland works are completed. The Estate has owned and managed woodland and other habitat for many years. 3. Access Bridge The proposals provide for a bridge over the A428 at Top Farm. This is a single carriageway bridge with a width between parapets of 4.7m. Currently the Estate has access over a farm track unrestricted in width or weight. This width is sufficient to accommodate road traffic but is insufficient for the working width of modern farm equipment - from 3m to 8m+. The Executors need a wider equivalent to two carriageways to allow uninterrupted access for working farm equipment (eg ref CD127 fig. 2.1.1N1E 7.3m running surface plus 1x1m hard verge and 1x3.5m hard verge would allow for this). Detail of provisions for access to Top Farm during works is required. 4. Land Drainage The general layout plans indicate provision for new drainage alongside the road but provide no detail to ensure that: i. The alignment is sufficient to drain the landscape ii. It can accommodate reinstated underdrainage schemes iii. Is of sufficient capacity to take both land water and road water 5. Environmental Mitigation The Executors object to the location of significant areas of the additional woodland habitat as supplements to existing wood elsewhere on the Estate would be preferable. (Please also refer to point 2 above re interest taken)."
Members of the Public/Businesses
Anglian Water Services Limited
"Anglian Water Services Limited (Anglian Water) is in active discussion with Highways England's legal advisors regarding the form of modified protective provisions within the DCO. Anglian Water is submitting this Relevant Representation following the advice in Advice Note 8.2 and in agreement with Highways England that to ensure clarity on our position as a utility provider and landowner/ occupier affected by the proposed scheme and so to assist the Examining Authority. Anglian Water has no in principle objection to the scheme and seeks to ensure that through the agreement of protective provisions we continue to provide customers with uninterrupted water and waste water services during construction and then the operation of the scheme. The issues on which we are in discussion with Highways England are in summary: 1. Definitions, in particular “apparatus”. 2. The application of NRSWA and specifically were it applies, notification(s) to Anglian Water. 3. Anglian Water's facilities and rights when alternative apparatus has been constructed and is in operation to our reasonable satisfaction. 4. Step in rights for approved works and notification. 5. Clarity regarding the undertakers works near to or which affect Anglian Water apparatus in part to assist the undertaker in flagging and so minimise the risk of damage by Highways England's contractors. 6. Time limits being able to be altered by written agreement between the undertaker and Anglian Water. 7. Safeguards to ensure emergency works on our apparatus by the undertaker are carried using best endeavours to keep the impact of those emergency works on Anglian Water’s apparatus and network on end-users/Anglian Water customers to a minimum. 8. Tightening up references so that paragraphs are self contained were possible including when we incur expense on the undertaker’s behalf. 9. Cost's as a result on the undertakers scheme which necessitate the provision of new Anglian Water infrastructure. 10. Ensuring definitions provide for adequate compensation following damage to Anglian Water's network by the undertaker. 11. The processes for exchange of documentation and requests by Anglian Water. 12. A Memorandum of Understanding on stage payments to Anglian Water with reconciliation at the end or works. On land and rights acquistion, Anglian Water remains committed to reaching agreement on resolving the question of the access to the Chawston-Wyboston Water Recycling Centre (WRC) that Highways England seek to acquire permanently. Anglian Water's preference remains for the undertaker to maintain continuous access to the WRC to operate and maintain access to the site for our customers. Anglian Water therefore seek agreement to ensure that access is maintained until an acceptable replacement is constructed, operable and in Anglian Water's control as an occupier. Similarly, we seek to agree the approach of the undertaker to the proposed temporary use of Anglian Water's land and reservoir (covered) to the south-east of Rectory Farm Cottage and west of Potton Road, Eynesbury Hardwicke,St Neots."
Local Authorities
Carter Jonas LLP on behalf of Bedford Borough Council
"Comments received from Bedford Borough Council in its capacity as landowner: RELEVANT REPRESENTATION OF BEDFORD BOROUGH COUNCIL – LAND TO EAST OF GREAT NORTH ROAD, CHAWSTON, BEDFORD 1 I write on behalf of Bedford Borough Council (the ‘Council’) responding to the A428 Black Cat to Caxton Gibbett improvement scheme (the ‘Scheme’) being promoted by Highways England Company Limited (‘Applicant’). 2 The Council owns the freehold interest in approximately 66 acres of land at Black Cat Roundabout, Great North Road, Roxton held in title P128267, Z1440Z, Z1441Z, Z1444Z (the ‘Land’). The Land is located to the immediate east of the existing Black Cat Roundabout. It is bounded to the west by the Black Cat Roundabout and A1, and to the west by the Great Ouse River. 3 This Relevant Representation relates to the Council’s interest of the Land only. Other matters relevant to the Council will be referred to in seperate representations. 4 The Land comprises a partially reinstated quarry; mineral extraction is expected to be finished by the commencement of construction of the Scheme. 5 The Council has development aspirations for the western part of the Land which is strategically located in a sustainable location for employment development with direct access onto the Black Cat Roundabout, the A1, A421 and the strategic highway network beyond. EFFECTS OF SCHEME 6 The Land is affected by the Scheme, as summarised below: - Plot 1/8p – 575 sqm, temporary possession and permanent rights - 1/8q – 30,994 sqm, temporary possession - 1/8r – 148,549 sqm, permanent acquisition - 1/8s – 18 sqm, permanent acquisition - 1/8t – 1,156 sqm, temporary possession - 1/8u – 1,706 sqm, temporary possession - 1/8v – 474 sqm, permanent acquisition - 3/3a – 69,824 sqm, permanent acquisition - 3/3b – 4,796 sqm, temporary possession and permanent rights - 3/3c – 5,426 sqm, temporary possession - 3/4a – 128 sqm, permanent acquisition 7 The Scheme’s core economic rational is to support new development and growth: “Economic growth: Enable growth by improving connections between people and jobs and supporting new development projects.” (paragraph 2.2.1 of ‘Introduction to the Application’). 8 The Council seeks commitments from the Applicant to safeguard delivery of the full potential of the Land (in particular in respect of plot 1/8q) for a sustainable strategic employment development. To date there has been engagement between the parties, but no tangible commitments from the Applicant to safeguard suitable access to the Land from the new junction. The Council, in its capacity as a directly affected landowner, therefore objects to the detail of the Scheme including any recourse to the use compulsory purchase powers until such safeguards are agreed. 9 The Scheme affects the Land more specifically as follows: MAINLINE CARRIAGEWAY 10 Approximately 10 hectares (permanent acquisition) comprising a strip of land running east to west to the north of the Land is identified for the mainline carriageway, extension of the Black Cat Roundabout and associate landscaping. FLOOD COMPENSATION 11 Approximately 12 hectares identified for permanent acquisition. The Council objects to the detail of the Scheme proposals because the permanent acquisition of the Land for flood compensation is not reasonably necessary in the circumstances. The case of ‘R(oao FCC Environment (UK) Ltd) v Secretary of State for Energy & Climate Change [2015] EWCA Civ 55’ considered, among other things, the statutory requirement in S.122(3) of the 2008 Act. In the decision in that case the example was provided that a compelling case in the public interest may not be demonstrated where acquisition of a right over the land, rather than its acquisition, would suffice. The temporary acquisition of this part of the Land by agreement would be sufficient and the Council is ready to negotiate with the Applicant to enter into covenants or management agreements necessary to satisfy the Applicant’s requirements here in the long term. 12 At a meeting between the Council’s agent and the Applicant (11th August 2020) the possibility of the flood compensation requirement being satisfied by temporary possession and rights was discussed. It was agreed that the Applicant would provide details of requirements for flood compensation management as required in order to progress negotiations for the provision of land and rights needed for the Scheme by agreement. To date these details are still awaited. 13 Generally, the area identified for Flood compensation appears excessive and the Council seeks this be reduced or to see evidence that this is fully justified. UTILITIES DIVERSIONS & ‘WORKING ROOM (TEMPORARY POSSESSION AND PERMANENT RIGHTS) 14 It is assumed the use refers to utility diversions and construction works. The Council requires full details of uses proposed on this area of the Land. 15 The effect of permanently acquiring the land identified for flood storage would in effect ‘landlock’ this part of the Land identified for temporary acquisition for ‘Permanent Access Rights’ and ‘Working Room’. The Council therefore objects to the current proposals in the absence of further information and safeguards. CONSTRUCTION COMPOUND – TEMPORARY ACQUISITION (PLOT 1/8Q) 16 This part of the Land comprises approximately 3.1 hectares. A direct access onto the new Black Cat Roundabout is proposed. We understand a construction compound of approximately three years duration will be located here. The Scheme’s Statement of Works states the use as follows: “Required to provide a temporary construction area. Required to provide temporary storage, laydown areas, access and working space for this construction area, the construction of the realigned Greenacres access track, the construction of the flood compensation area south east of the new Black Cat junction circulatory, and the quarry restoration works.” This part of the land is suitable for a sustainable employment development and the Council seeks agreement with the Applicant to ensure this potential is not fettered by the Scheme. PROVISION OF LAND AND RIGHTS BY AGREEMENT 17 The Council now seeks urgent engagement with the Applicant aimed at reaching agreement to provide the land and rights necessary to deliver the Scheme while also safeguarding the potential of a sustainable strategic employment development on the Land. Specifically the Council seeks the following: i. Securing access to the Land in this location from the Black Cat Roundabout and which will be suitable for the proposed development ii. Design sufficient capacity into the new road layout to accommodate associated traffic iii. Agreement on terms for condition of this part of plot 1/8q when possession is returned to the Council iv. Protective provisions for satisfactory drainage v. Minimisation of the flood storage area to maximise the developable area on a sustainable and well-connected development and ensure that drainage strategy does not prejudice the delivery of development on what is a strategically important site vi. Agreement to provide rights sufficient to satisfy Scheme flood mitigation requirements on the Land, there-by obviating the need for permanent compulsory acquisition."
Members of the Public/Businesses
Henry H Bletsoe & Son LLP on behalf of C Croft & Sons
"This representation is made on behalf of Michael Croft, Neil Croft and Joyce Croft T/A C Croft & Sons of [redacted] as occupies of land affected by the A428 scheme. These representations are made without prejudice to making further objections/representations for different reasons, or to amplify these representations. We have reviewed the plans included within the Developer’s application insofar as they relate to our client and these representations are based upon the information contained therein. The proposed scheme affects land occupied by C Croft & Sons located to the west of Black Cat Roundabout on the north and south side of the A421. Based on the information available part of the land to the north of the A421 has been identified as permanent acquisition and the land to the south of the A421 has been identified as temporary acquisition. The proposed scheme affects the main entrance to the land located to the north of the A421. The existing access to this land is via a gate adjacent to the Travel Lodge which is included within the permanent acquisition. Once the new scheme has been developed, it appears that the remaining area of this land will be accessed off the new link road between ‘Roxton Road’ and ‘The Lane’. It is important that this access is as equally commodious as the existing access, and is at a similar level to the finished road level to allow for a safe and efficient operation when exiting the access point with heavy loads and restricted maneuverability such as tractors, sprayers and combines. The land identified also benefits from an existing land drainage scheme and appropriate arrangements should be put in place to provide for, and deal with the continuation of the existing land drainage scheme, so as not to impact the drainage of the remainder of the field to the north. The land located to the south of the A421 has been identified a temporary acquisition, this land should be reinstated to it’s former condition and level before being returned back to the landowners. We require further details on the proposed accommodation works to ascertain the full impact on my client’s leasehold interest. As a minimum, our client requires commodious access, post scheme land drainage, and fencing and hedge of boundaries to mitigate the detrimental affect of this scheme. This representation has been made by Verity Garlick BSc(Hons) MRICS FAAV of Bletsoes, as Agent on behalf of C Croft & Sons."
Members of the Public/Businesses
Charlotte Ditchburn
"I wish to record my OBJECTION to the Development Consent Order as submitted because of the failure to include opportunities for equestrians which I believe has occurred due to the lack of consultation with equestrians unlike the consultation with cyclists. I would like to have the opportunity to explain my views to the Inspector due to the failure to accommodate the needs of equestrians contrary to National and Local Policies. For example: • The failure to provide for equestrian usage of the new bridge over the A421 at Roxton compounds an omission made when the A421 was built. The Society accepts that this current bridge is rarely used by horses because local riders consider it to be too dangerous. But there is a demand for it to be equestrian safe in order to create some riding circuits in an area has a shortage of bridleways. Further, the bridge will be used by a significantly higher number of HGVs than is currently the case making the need to segregate horses from the carriageway even greater. The Society considers it wholly unacceptable, and contrary to policy, that the proposed cycleway is not a bridleway in order to protect the safety of horse riders. • Caxton Gibbet roundabout. Needs safe and segregated NMU access for all users including equestrians. Failure to provide this facility will be disadvantage equestrians in perpetuity from accessing any A428 NMU provision. Opportunities to link to the new peripheral bridleway at Cambourne West have been ignored. • Bridleway 74/6 - could be provided no must be included in the project • New foot cycleway Cambourne to St. Ives – needs to be NMU • Minutes of NMU Meetings with CCC. Need for new NMU path alongside de trunked A428 was recorded as was path alongside new A428 • 4.4 NMU data survey – no equestrian activity bears no reflection on suppressed demand where facilities are inadequate. Huge changes since 2017 • 2.21.2 Data from Jacobs survey in no way captures the suppressed demand from all three users arising from the lack of facilities. How was this information captured? Massive changes in demand since lockdown. Building for the future not the past. • 2.15.1 Equality Act – females not mentioned. • Wintringham. The proposals made in the WCHAR only provide for cycling and walking whereas the existing footpaths are all to be upgraded to bridleways. This information was provided by the BHS but clearly has been ignored. • Constant reference throughout the document for the need to provide shared cycling and pedestrian access which is contrary to the Cambridgeshire and Peterborough Local Transport Plan requirement for Active Travel provision i.e. pedestrians, cyclists and equestrians. • The provision of NMU access is not a ‘nicety’ ‘if money allows’ but of high importance in terms of health and wellbeing. Any route should be designed to be safe, enjoyable and welcoming to use for all NMU’s and not simply something squeezed on to the edge of the carriageway. Identification of funds and their source should be part of the Planning Inspectorate approval."
Members of the Public/Businesses
Claudia Zennig
"this highways development presents a unique opportunity (in terms of funding and access to land) to work in partnership with the consultants, developers, local highway authority and Local Access Forum to ensure that existing Public Rights of Way are both protected and enhanced (by changing from Footpath (walkers) to Bridleway (walkers, cyclists, horse riders) or Restricted Byways (all non-motorised users). Also we wish to see that all possible new opportunities are taken to increase the PROW network in an inclusive way by the provision of new routes, both to provide circular routes, to provide links in broken networks, and to link villages and communities together, with safe crossing points. The standard has already been set with the A14 work from which much can be seen as good example and also much can be learnt in terms of mistakes made. We are pleased to see the same Highways England lead person is employed on the A428 as was on the A14."" My representation supports the representations of the British Horse Society (Lynda Warth) and Swavesey & District Bridleways Association"
Members of the Public/Businesses
Brown & Co on behalf of D.H.T. Limited
"This representation is made on behalf of D.H.T. Limited who are the owners of the plots 1/1/37a, 1/37b, 3/1a, 3/1b, 3/1c and 3/1d as detailed within the Book of Reference. My clients strongly object to the proposed A428 works and feel that they will detrimentally impact upon the surrounding area and offer minimal benefit to the local community. My clients live within close proximity to the proposed route and this will have a detrimental impact upon their enjoyment of their property. The Directors of D.H.T. Limited retain their residential property to the north of the proposed A428 and my client is concerned that access is maintained at all times during construction. My client also owns a number of commercial units which enjoy access directly from the A1. This access is being replaced by a new link road. This will primarily be for traffic to exit the services and so my client will be required to cross passing traffic in order to access their property. My client is concerned with the safety of passing oncoming traffic and seeks clarity on the speed restriction enforcement following completion of the scheme. The current occupiers of the commercial units have expressed concerns to my clients that they will lose passing trade. My client wants to ensure that access can be taken at all times during the scheme to his property and also the commercial units. It is unclear when the new link road will be constructed. My clients existing access is suitable for HGV’s and as such seeks clarification on the design and width of the new access point. Due to the commercial businesses on site it is crucial that HGV access is maintained throughout the scheme. My clients land is identified as being used as a Borrow Pit. This land has previously been used for gravel extraction and as such is identified as filled land. Survey work undertaken by the Highways England team was taken outside of the borrow pit area and as such my clients feels that a borrow pit in this area is unnecessary. My client feels that increasing the size of other borrow pits in the area would be better and more effective. My clients request that this area is removed from the Development Consent Order. If the borrow pit is to be located on my clients land then my clients seek details of the bund to be put in place to protect his existing properties together with details of security fencing to ensure that his property is protected during the works. My client also seeks clarification on the measures to be put in place to control noise and dust during construction and also what equipment will be used to monitor vibration and the impact on their residential property. Accordingly our client will represent that the DCO should be amended to reflect the points set out above."
Members of the Public/Businesses
Carter Jonas LLP on behalf of Davison & Company Great Barford Limited
"1. INTRODUCTION 1.1. This is the Relevant Representation of Davison & Company (Great Barford) Limited (the ‘Landowner’) to the A428 Black Cat to Caxton Gibbet Road Improvement Development Consent Order (the ‘Scheme’) application being promoted by Highways England Company Limited (the ‘Applicant’). 1.2. The Landowner’s property at Crow Green (the ‘Land’) comprises 164 hectares situated to the northeast of Caxton Gibbet junction. If consented, the Scheme would impact a significant proportion of the Land as follows: • Plot 14/16a (35.04ha) – proposed Permanent acquisition powers for ‘borrow-pits’ purposes. • 14/16b (3.53ha) – proposed temporary possession powers to provide temporary storage, laydown areas, access and working space to facilitate a construction area • 15/6a (0.36ha) – permanent acquisition powers for highway purposes. • 15/6b (6.79ha) – temporary possession powers for construction compound and ecology areas purposes 1.3. The Landowner has advanced proposals for a strategically important major employment development on the Land. They seek agreement with the Applicant to safeguard the proposed development of the Land, which may otherwise be adversely impacted by the Scheme. In the absence of such safeguards and protective provisions the Landowner objects to the details of the Scheme and the proposed permanent and temporary compulsory purchase powers sought by the Applicant over the Land. 2. THE LAND 2.1. The Land is being promoted by the Landowner and Endurance Estates as part of a sustainable strategic employment development for allocation in the emerging Greater Cambridge Local Plan (the ‘Proposed Development’). The Planning Authority has recently carried out a consultation on the emerging Local Plan and they aim to consult on a Preferred Option in summer or autumn 2021 with a Draft Plan prepared by summer 2022. 2.2. 77 hectares of the Land is suitable for built development with the remainder for green infrastructure and solar photovoltaic electricity generation. The Proposed Development can accommodate a range of end-user requirements within Use Classes B1b (R&D), B1c (light industry), B2 (general industrial) and B8 (storage & distribution). Using ‘employment density’ figures from Homes & Communities Agency guidance, it is estimated that the Proposed Development could provide between 4,500 and 6,500 new jobs FTE. 2.3. While the Proposed Development is deliverable with or without the Scheme it is considered to be consistent with the Scheme’s core economic rational: “Economic growth: Enable growth by improving connections between people and jobs and supporting new development projects.” (paragraph 2.2.1 of ‘Introduction to the Application’) 2.4. The Proposed Development and the Scheme are therefore complimentary in principle and purpose. However much of the Land is included in the DCO for permanent acquisition and there is also the significant risk that absent suitable safeguards and protective provisions that the Scheme could fetter or complicate access to the Proposed Development (compared to existing arrangement). 3. COMPULSORY ACQUISITION & AGREEMENT 3.1. The Landowner seeks urgent detailed engagement with the Applicant aimed at reaching agreement both to safeguard delivery of the Proposed Development and secure relevant synergies with the Scheme. 3.2. Specifically, the Landowner is seeking to enter into an agreement with the Applicant providing them with the temporary rights necessary in respect of plot 14/16a (for the purposes of borrow pits) thereby rendering the proposed permanent acquisition of this land as provided for in the draft DCO unnecessary. Borrow pits are areas of land where materials are extracted (typically clay, sand and gravel) to supply construction material where there is a net deficit. 3.3. The Applicant’s has confirmed they do not intend to permanent retain Plot 14/16a, which could be returned to the Landowner. While the suite of DCO application documents, including the statement of reasons, is silent on this point, we understand the Applicant is seeking permanent compulsory acquisition of this land because the borrow pit works would result in permanent change to the land (notwithstanding their planned restoration). We do not consider this is an adequate public interest justification for the permanent acquisition of the land, among other things, when: a. The Applicant has been granted approval for a succession of new highway DCO’s with powers of temporary possession providing for permanent alteration of land (which then reverts to the landowner on completion). b. The temporary possession provisions in the Scheme draft DCO (Article 40 ‘Temporary use of land for carrying out the authorised development’) include powers for the Applicant to “construct any permanent works” [paragraph (1)(d)] and to not be required to “restore the land on which any permanent works have been constructed under paragraph (1)(d)” [paragraph (4)(d)]. c. In accordance with the Planning Act 2008 (‘2008 Act’), the Secretary of State may only authorise the permanent compulsory acquisition of land where there is a compelling case in the public interest for the proposed acquisition [S.122(3) 2008 Act]. The DCO’s ‘Statement of Reasons’ is silent on the reasons for permanent acquisition of land required for borrow pits. It states however that the Applicant will seek to acquire land by negotiation wherever practicable. The case of ‘R(oao FCC Environment (UK) Ltd) v Secretary of State for Energy & Climate Change [2015] EWCA Civ 55’ considered the requirements in S.122(3) of the 2008 Act. Three examples were given in that case by the Secretary of State (paragraph 11) of circumstances where a decision maker may conclude that there is not a compelling case in the public interest for the proposed compulsory acquisition notwithstanding an established need for the proposed DCO development, namely where: - Land proposed to be acquired may be excessive because development proposals can be constructed without needing the land to be acquired; - Acquisition of a right over the land, rather than its acquisition, might suffice; - Land may be necessary for the development, but the landowner may be willing to agree to sell. d. Subject to agreement, the Landowner is open in principle to granting the Applicant such reasonable and proportionate temporary rights over the Land as are reasonably necessary for the purposes of the construction of the Scheme, thereby obviating the need for the proposed permanent and temporary powers of compulsion sought in the application for the Scheme over the land. 3.4. For the main reasons summarised above (to be further particularised in the Written Representations) the Landowner considers that there is no or no compelling case in the public interest for the permanent acquisition of the Land (and in particular Plot 14/16a) given that powers of temporary possession will suffice, and the Landowner is, in any event, willing to enter into a suitably worded agreement with the Applicant to grant them, subject to appropriate safeguards and protective provisions, the temporary rights necessary for the purposes of the Scheme. 3.5. The Landowner has been open to negotiating an agreement with the Applicant at the pre examination stage and requested an early meeting with the Applicant’s representatives to discuss matters which was held on 23 June 2020. At this meeting the Applicant agreed to a number of actions necessary to reaching a suitable agreement including: - Preparing draft agreements for acquisition of land and rights - Providing estimates of the soil to be removed from borrow pits - Providing the proposed justification for the permanent acquisition of Plot 14/16a - layout and location of construction compound. 3.6. Some 12 months on from this meeting, while progress has been made on some issues (e.g. location of SUDS pond) the bulk of these actions remain outstanding. 3.7. The Landowner requests that the Applicant now proactively engages with it in detailed discussions to agree a suitably worded lands agreement to provide the temporary rights for the construction of the Scheme, while protecting the Landowner’s ability to deliver the Proposed Development. 3.8. In the absence of a suitable agreement being reached which avoids the permanent acquisition of Plot 14/16a and secures appropriate safeguards to avoid or mitigate significant adverse impacts of the Scheme on the Proposed Development, the Landowner objects to the details of the Scheme and the proposed powers sought over the Land."
Members of the Public/Businesses
Brown & Co on behalf of Gemma Jane Gape Tucker
"This representation is made on behalf of Mrs GJG Tucker as owner and [Redacted] of the land identified as plots 14/8a, 14/8b, 14/8c, 14/8d, 14/8e and 14/8f. My client is concerned regarding the electrical diversion on their land as this is the supply for Pastures Farmhouse and the agricultural buildings. My client wants to ensure that an adequate supply is put in place for the dwellings and buildings following the scheme and diversion. My client has also agreed with Highways England that they will be contacted during these works to ensure that appropriate services can also be connected to their retained farm buildings. My client understands from the plans submitted for the Development Consent order that a new roundabout access is to be included as the Caxton Gibbet West roundabout and my clients request further details on the width and type of access to be created here. It is also noted that the cycle lane included from Caxton Gibbet running south is not linking to any of the proposed paths included within the Cambourne development and my client would ask that the scheme revisit the proposed cycle path to ensure it links appropriately with local cycle networks. My client is concerned regarding land drainage on the fields affected by the scheme. My client seeks confirmation that drainage surveys will be undertaken prior to entry to ensure that land drainage can be put in place prior to any damage being caused. My client practices Regenerative Agriculture and has invested considerable time and money into creating high quality, biologically healthy, well structured soil. My client seeks confirmation that appropriate soil surveys and consideration will be given to this on the temporary land take to ensure they are returned to them in the same condition following completion of the scheme. My client also seeks confirmation of the boundary treatments along the route to ensure the security of his property both during construction and following completion. My client will require access to all land at all times during construction of the project and seeks confirmation that this will be available and details on the proposed method of works to ensure that access is not interrupted. Accordingly our client will represent that the DCO should be amended to reflect the matters set out above."
Other Statutory Consultees
Historic England
"Historic England (retaining the formal title of the Historic Buildings and Monuments Commission for England) is the government service championing England’s heritage and giving expert, constructive advice. We summarise our representation regarding this proposed project as follows: 1. The development would include construction and operation of a new section of the A428 in Cambridgeshire and Bedfordshire including 16km of new carriageway with crossings over the River Great Ouse, the East Coast Mainline railway and multiple minor roads, a three level junction with the A1 at the Black Cat roundabout with associated slip roads and an improved junction at the Caxton Gibbet roundabout facilities. 2. The applicant has carried out an assessment of the historic environment within a defined study area. Assets within this area which could be affected by the proposed development include 11 scheduled monuments, one grade II* registered historic park, nine grade II* listed buildings, 124 grade II listed buildings and five conservation areas along with 406 undesignated heritage assets. We will comment on the assessment of and impact on the grade II* listed buildings, the scheduled monuments and the grade II* registered park where there is potential for impact on their setting. We will defer advice on grade II listed buildings and conservation areas to the respective local planning authorities with the exception of four grade II listed buildings which would be physically affected by the development. These are three milestones on the existing A428 and Brook Cottages near Wyboston. We will comment on these grade II listed assets specifically. 3. The development has the potential to harm archaeological deposits of interest, both directly and indirectly. A mitigation strategy has been presented by the applicant, which includes a programme of archaeological works including geoarchaeological boreholes that will inform preservation strategies, either preserving remains in situ or by record. We will comment on this strategy and associated document to ensure that the significance of the impacted remains/deposits is not lost."
Members of the Public/Businesses
Brown & Co on behalf of JAC Settlement Trust Corporation Limited
"1. Our clients are the owners and [Redacted] of Rectory Farm, Eynesbury an equipped arable unit of approximately 106.56 ha of which 19.3885 ha are affected by the current proposal. 1. The new road will sever our clients farm into parts and, as such, access is an important issue. 1. Our clients are the freeholder owners of plots 5/2f, 5/2k, 6/2k & 6/2c as identified in the Book of Reference to be acquired. 1. As frontage owners to both sides of the Potton Road, their ownership extends to the centre of the highway as recorded within the Book of Reference by reference to being part owners and it is noted that as a result of this road being stopped up the ownership of plot 6/3b will revert to our client. 1. With regard to plot 6/6a, note that the ownership of this plot, as a result of the B1046 diversion will revert to our client. Our client is particularly concerned over ensuring sufficient access to the properties known as Nos. 1 & 2 Rectory Farm Cottages is provided with the entrance to No. 2 being of a particular concern and further details are requested. 2. In respect of plot 6/2l, we note that a single field entrance has been indicated on the General Arrangement plan and the access to this land must be suitable for farm machinery and equipment there should be adequate turning circles and visibility splays. 3. We note that the existing field access to the rear of Nos. 1 & 2 Rectory Farm Cottages as currently exists, has not been provided for within the General Arrangements plan sheet 6, As this is an existing entrance, our client requests that this is reinstated as part of the overall scheme. 4. In respect of plot 6/3b, our client has a concern regarding the final road surface and wants to ensure that access to their farm is uninterrupted at all times throughout the scheme. Within plot 6/3b an access gate is to be installed to prevent unauthorised access. 5. With regard to plot 5/2f, it is noted on the General Arrangement plan that the newly aligned watercourse will be planted with trees on to the eastern boundary and it is currently proposed that a new hedge is planted along the western boundary. It is requested that the proposed hedge line is removed as maintenance will be restricted to this watercourse under the current proposal. 6. In respect of plot 5/2h identified on the General Arrangement plan, the area for soil storage encompasses part of the Brook. 7. Our client is concerned to ensure that the new access proposed to serve plot 5/2k as shared with the adjoining landowner is of a sufficient specification to ensure both accesses are suitable for both the machinery and equipment associated with Eynesbury Plant Hire and farm machinery and equipment used by our client and that there should be adequate turning circles and visibility splays for both parties. 8. In respect of plot 5/2a, the green temporary possession area extends to the edge of plot 5/2f and this is incorrect. The General Arrangement plan sheet 5 only extends to the watercourse, and it is plot 5/2a needs to be updated to reflect the General Arrangement Plan. 9. Our client notes that there is currently no future access provision to the flood storage area identified within plot 5/2f. Our client has concerns regarding the provisions of appropriate fencing alongside the highway boundaries and concerns over the effective maintenance of the draining schemes. 10. Our client is concerned about ensuring suitable and adequate land drainage schemes are installed at early stage. 11. Our clients overriding concern is the impact of the overall scheme on Rectory Farm and the 4 dwellings associated with the farm and seek to minimise the impact of the scheme on their property. 12. Our clients have noted that the utility diversions and the proposals to divert existing water mains and our anxious to ensure that water supply and pressure are maintained at all times."
Members of the Public/Businesses
Brown & Co on behalf of Judith Anne Clements
"1. Our clients are the owners and [Redacted] of Rectory Farm, Eynesbury an equipped arable unit of approximately 106.56 ha of which 19.3885 ha are affected by the current proposal. 1. The new road will sever our clients farm into parts and, as such, access is an important issue. 1. Our clients are the freeholder owners of plots 5/2f, 5/2k, 6/2k & 6/2c as identified in the Book of Reference to be acquired. 1. As frontage owners to both sides of the Potton Road, their ownership extends to the centre of the highway as recorded within the Book of Reference by reference to being part owners and it is noted that as a result of this road being stopped up the ownership of plot 6/3b will revert to our client. 1. With regard to plot 6/6a, note that the ownership of this plot, as a result of the B1046 diversion will revert to our client. Our client is particularly concerned over ensuring sufficient access to the properties known as Nos. 1 & 2 Rectory Farm Cottages is provided with the entrance to No. 2 being of a particular concern and further details are requested. 2. In respect of plot 6/2l, we note that a single field entrance has been indicated on the General Arrangement plan and the access to this land must be suitable for farm machinery and equipment there should be adequate turning circles and visibility splays. 3. We note that the existing field access to the rear of Nos. 1 & 2 Rectory Farm Cottages as currently exists, has not been provided for within the General Arrangements plan sheet 6, As this is an existing entrance, our client requests that this is reinstated as part of the overall scheme. 4. In respect of plot 6/3b, our client has a concern regarding the final road surface and wants to ensure that access to their farm is uninterrupted at all times throughout the scheme. Within plot 6/3b an access gate is to be installed to prevent unauthorised access. 5. With regard to plot 5/2f, it is noted on the General Arrangement plan that the newly aligned watercourse will be planted with trees on to the eastern boundary and it is currently proposed that a new hedge is planted along the western boundary. It is requested that the proposed hedge line is removed as maintenance will be restricted to this watercourse under the current proposal. 6. In respect of plot 5/2h identified on the General Arrangement plan, the area for soil storage encompasses part of the Brook. 7. Our client is concerned to ensure that the new access proposed to serve plot 5/2k as shared with the adjoining landowner is of a sufficient specification to ensure both accesses are suitable for both the machinery and equipment associated with Eynesbury Plant Hire and farm machinery and equipment used by our client and that there should be adequate turning circles and visibility splays for both parties. 8. In respect of plot 5/2a, the green temporary possession area extends to the edge of plot 5/2f and this is incorrect. The General Arrangement plan sheet 5 only extends to the watercourse, and it is plot 5/2a needs to be updated to reflect the General Arrangement Plan. 9. Our client notes that there is currently no future access provision to the flood storage area identified within plot 5/2f. Our client has concerns regarding the provisions of appropriate fencing alongside the highway boundaries and concerns over the effective maintenance of the draining schemes. 10. Our client is concerned about ensuring suitable and adequate land drainage schemes are installed at early stage. 11. Our clients overriding concern is the impact of the overall scheme on Rectory Farm and the 4 dwellings associated with the farm and seek to minimise the impact of the scheme on their property. 12. Our clients have noted that the utility diversions and the proposals to divert existing water mains and our anxious to ensure that water supply and pressure are maintained at all times."
Members of the Public/Businesses
Brown & Co on behalf of Judith Penelope Glossop Bennett Gape Pearson
"This representation is made on behalf of Mrs JPGBG Tucker as owner and [Redacted] of the land identified as plots 14/8a, 14/8b, 14/8c, 14/8d, 14/8e and 14/8f. My client is concerned regarding the electrical diversion on their land as this is the supply for Pastures Farmhouse and the agricultural buildings. My client wants to ensure that an adequate supply is put in place for the dwellings and buildings following the scheme and diversion. My client has also agreed with Highways England that they will be contacted during these works to ensure that appropriate services can also be connected to their retained farm buildings. My client understands from the plans submitted for the Development Consent order that a new roundabout access is to be included as the Caxton Gibbet West roundabout and my clients request further details on the width and type of access to be created here. It is also noted that the cycle lane included from Caxton Gibbet running south is not linking to any of the proposed paths included within the Cambourne development and my client would ask that the scheme revisit the proposed cycle path to ensure it links appropriately with local cycle networks. My client is concerned regarding land drainage on the fields affected by the scheme. My client seeks confirmation that drainage surveys will be undertaken prior to entry to ensure that land drainage can be put in place prior to any damage being caused. My client practices Regenerative Agriculture and has invested considerable time and money into creating high quality, biologically healthy, well structured soil. My client seeks confirmation that appropriate soil surveys and consideration will be given to this on the temporary land take to ensure they are returned to them in the same condition following completion of the scheme. My client also seeks confirmation of the boundary treatments along the route to ensure the security of his property both during construction and following completion. My client will require access to all land at all times during construction of the project and seeks confirmation that this will be available and details on the proposed method of works to ensure that access is not interrupted. Accordingly our client will represent that the DCO should be amended to reflect the matters set out above."
Members of the Public/Businesses
Brown & Co on behalf of Maureen Elizabeth Wright
"This representation is made on behalf of Maureen Elizabeth Wright who is the owner of plots 2/18a, 2/18b and 2/18c detailed within the Book of Reference. My client is concerned regarding the provision of appropriate fencing alongside the boundaries both during construction and following completion to ensure the security of the field. The land is let on a Farm Business Tenancy for the grazing of livestock and so the field must be secure at all times. My client currently enjoys access from a gate located onto Chawston Lane and this is being removed by the new link road. A new access has been provided however further details have not been provided as to width and size of apron, my client required clarity on this to ensure it is adequate."
Members of the Public/Businesses
Henry H Bletsoe & Son LLP on behalf of Mr R Bates & Ms J Must
"This representation is made on behalf of Richard Bates of [redacted] and Janet Must of [redacted] as landowners of land affected by the A428 scheme. These representations are made without prejudice to making further objections/representations at a later stage for different reasons, or to amplify these representations. We have reviewed the plans included within the Developer’s application insofar as they relate to our client and these representations are based upon the information contained therein. The proposed scheme affects land owned by Richard Bates and Janet Must located to the west of Roxton Road on the north and south side of the A421, and land to the north of School Lane. Based on the information available this land has been identified as permanent acquisition. This land is located within close proximity to Chawston, where we believe there to be potential for residential development. The landowners are seeking to promote the site for development and are currently in discussions with a major PLC housebuilder. In addition we consider that there are minerals present which will ultimately need paying for and cannot simply be taken and not compensated for. As such, we believe that the land has increased value over and above agricultural value. Based on the information available the majority of this land is only required for the construction phase, therefore there cannot be a compelling case in the public interest for this land to be acquired permanently, especially when you consider the increased land values highlighted above. Instead, the land should be acquired temporarily and reinstated to it’s former condition and level, and returned to the landowners. School Lane has also been identified as permanent acquisition. The Bates & Must family own land to the north of School Lane which is being promoted for development. A development standard access needs to be incorporated in the scheme (a plan of the land and a design of the access has been sent to Ardent), and further details have been requested from Ardent regarding the proposed highway works to School Lane. Uninterrupted agricultural access is also required, at all times, along parts of School Lane to access land farmed by the Bates & Must family, the access points must be suitable for heavy agricultural machinery, with a minimum width of 4m and allow for safe and efficient operation when entering and exiting the agricultural fields with heavy loads and restricted maneuverability such as tractors, sprayers and combines. The plans available do not provide sufficient detail in order to ascertain the full impact on my client’s interest. In respect of the ‘Land Plans Regulation 5(2)(i) Sheet 1’ we would like further details on the size of reference point ‘1/16e’ and ‘1/16f’ as my client requires access through these points into the field to the north. A plan of School Lane has been emailed to Ardent which also identifies two further access points which are required for agricultural machinery as mentioned above. Accommodation works will also be necessary due to the closure of School Lane. An irrigation pipe which currently goes under the road at the south side of School Lane will need to be replaced so that the land on the north side can be irrigated. The irrigation abstraction point will also need to be maintained. We require further details on the proposed accommodation works to ascertain the full impact on my client’s interest. As a minimum, our client requires, post scheme land drainage, and fencing and hedge of boundaries to mitigate the detrimental affect of this scheme. Any Basic Payment Scheme Entitlements in respect of the land must also be kept by our client if relevant at the time of acquisition. This representation has been made by Verity Garlick BSc(Hons) MRICS FAAV and Peter Moore BSc(Hons) MRICS FAAV of Bletsoes, as Agents on behalf of the Bates & Must family."
Other Statutory Consultees
Bryan Cave Leighton Paisner LLP on behalf of National Grid NGET plc and NGG plc
"Representation by National Grid Electricity Transmission Plc and National Grid Gas Plc (together, “National Grid”) in respect of the Highways England A428 Black Cat to Caxton Gibbet Improvements Scheme DCO (the “Project”) This relevant representation is submitted on behalf of National Grid Electricity Transmission Plc (“NGET”) and National Grid Gas Plc (“NGG”) (together, “National Grid”) in respect of the Project, and in particular National Grid’s infrastructure and land which is within or in close proximity to the proposed Order limits. National Grid will require appropriate protection for retained apparatus including compliance with relevant standards for works proposed within close proximity of its apparatus. National Grid’s rights of access to inspect, maintain, renew and repair such apparatus must also be maintained at all times and access to inspect and maintain such apparatus must not be restricted. Further, where the Promoter intends to acquire land or rights, or interfere with any of National Grid’s interests in land or National Grid’s apparatus, National Grid will require appropriate protection and further discussion is required on the impact to its apparatus and rights. Further detail is set out below. National Grid infrastructure within/in close proximity to the proposed Order Limits National Grid owns or operates the following infrastructure within or in close proximity to the proposed Order limits for the Project: Electricity Transmission NGET has a high voltage electricity overhead transmission line within or in close proximity to the proposed Order limits. The overhead line forms an essential part of the electricity transmission network in England and Wales. The details of the electricity assets are as follows: - Overhead Lines: 4VK (400kV) overhead line Eaton Socon – Wymondley Main; Cottam – Eaton Socon – Wymondley 2 - Fibre Cable: Fibre cable alongside the existing A428 alignment Gas Transmission NGG has a high pressure gas transmission pipeline and above ground installation (“AGI”) located within or in close proximity to the proposed Order limits. The transmission pipeline and AGI form an essential part of the gas transmission network in England, Wales and Scotland: - Feeder Main 18 Huntingdon to St Neots; St Neots to Little Barford Power Station; St Neots to New Wimpole - AGI Little Barford Power Station NGG is working with the Promoter regarding a diversion of the gas main. Protection of National Grid Assets As a responsible statutory undertaker, National Grid’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. As such, National Grid has a duty to protect its position in relation to infrastructure and land which is within or in close proximity to the Order limits of the proposed Project. As noted, National Grid’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. National Grid will require protective provisions to be included within the DCO for the Project to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. National Grid is liaising with the Promoter in relation to such protective provisions, along with any supplementary agreements which may be required. National Grid requests that the Promoter continues to engage with it to provide explanation and reassurances as to how the Promoter’s works pursuant to the Order (if made) will ensure protection for those National Grid assets which will remain in situ, along with facilitating all future access and other rights as are necessary to allow National Grid to properly discharge its statutory obligations. National Grid will continue to liaise with the Promoter in this regard with a view to concluding matters as soon as possible during the DCO Examination and will keep the Examining Authority updated in relation to these discussions. Compulsory Acquisition Powers in respect of the Project As noted, where the Promoter intends to acquire land or rights, or interfere with any of National Grid’s interests in land, National Grid will require further discussion with the Promoter. National Grid is particularly concerned that a number of plots are included in the Book of Reference for the Project where National Grid has fibre cables assets that do not appear to be referenced. National Grid has confirmed the existence of the fibre cable assets with the Promoter in its earlier consultation responses. National Grid reserves the right to make further representations as part of the Examination process but in the meantime will continue to liaise with the applicant with a view to reaching a satisfactory agreement."
Other Statutory Consultees
response has attachments
Natural England
"Please see separate letter"
Members of the Public/Businesses
Brown & Co on behalf of Neal Gerard Doherty
"This representation is made on behalf of Mr Neal Gerard Doherty who is the owner of the plots 1/36a, 1/36b, 1/36c, 2/38a, 2/38b, 2/38c, 3/2a, 3/2b and 3/9a detailed within the book of reference and who has an interest in plots 1/37a, 1/37b, 3/1a, 3/1b, 3/1c and 3/1d as Director of D.H.T. Limited, a separate registration will be submitted for D.H.T. Limited. My client strongly objects to the proposed A428 works and feel that they will detrimentally impact upon the surrounding area and offer minimal benefit to the local community. My clients live within close proximity to the proposed route and this will have a detrimental impact upon their enjoyment of their property. My client retains his residential property to the north of the proposed A428 and my client is concerned that access is maintained at all times during construction. My client also owns a number of commercial units which enjoy access directly from the A1. This access is being replaced by a new link road. This will primarily be for traffic to exit the services and so my client will be required to cross passing traffic in order to access their property. My client is concerned with the safety of passing oncoming traffic and seeks clarity on the speed restriction enforcement following completion of the scheme. The current occupiers of the commercial units have expressed concerns to my clients that they will lose passing trade. My client wants to ensure that access can be taken at all times during the scheme to his property and also the commercial units. It is unclear when the new link road will be constructed. My clients existing access is suitable for HGV’s and as such seeks clarification on the design and width of the new access point. Due to the commercial businesses on site it is crucial that HGV access is maintained throughout the scheme. My clients land is identified as being used as a Borrow Pit. This land has previously been used for gravel extraction and as such is identified as filled land. Survey work undertaken by the Highways England team was taken outside of the borrow pit area and as such my clients feels that a borrow pit in this area is unnecessary. My client feels that increasing the size of other borrow pits in the area would be better and more effective. My clients request that this area is removed from the Development Consent Order. If the borrow pit is to be located on my clients land then my clients seek details of the bund to be put in place to protect his existing properties together with details of security fencing to ensure that his property is protected during the works. My client also seeks clarification on the measures to be put in place to control noise and dust during construction and also what equipment will be used to monitor vibration and the impact on their residential property. Accordingly our client will represent that the DCO should be amended to reflect the points set out above."
Other Statutory Consultees
Network Rail Infrastructure Limited
"I refer to the A428 Black Cat to Caxton Gibbet Improvements Development Consent Order and I write to formerly object to the Order on behalf of Network Rail Infrastructure Limited of 1 Eversholt Street, London, NW1 2DN, on the grounds that operational railway land is adversely affected. Whilst Network Rail does not object to the principle of the proposed Order, it does object to the compulsory acquisition of operational railway land and the compulsory acquisition of permanent and temporary rights over operational railway land where that would compromise Network Rail's ability to perform its statutory undertaking. Network Rail has interests in several of the Plots identified in the Book of Reference which affect sections of the East Coast Mainline railway as well as providing access to the operational railway. Network Rail objects to the seeking of powers to carry out works on/over/under the operational railway without first securing appropriate protections for Network Rail's statutory undertaking. The safe and efficient operation of the railway has not been adequately addressed within the application documents and there is insufficient explanation or justification for the extent and nature of the land and rights being sought. It should be noted that prior to the release of any land and rights as detailed within the Book of Reference, such land and rights will require submission for approval through Network Rail’s Land Clearance process and if such approval is not granted then this may give rise to further grounds of objection to the proposed Order. Network Rail is unable to release any land and rights for disposal without Clearance approval having first been obtained. Before Network Rail can consider withdrawing its objection it requires: a) Detailed information as to the precise nature of all works proposed on/over/under the operational railway. b) Clarity on the land and various rights being acquired on/over/under the operational railway. c) Agreement from the applicant that the acquisition of operational land is on terms to be agreed with Network Rail for the protection of its statutory undertaking and an undertaking that compulsory powers will not be exercised in relation to such land and rights. d) That sufficient protections for Network Rail's statutory undertaking are put in place for the carrying out of works on/over/under the operational railway. Without further details being provided and adequate protections put in place, Network Rail considers the proposed Order would cause serious detriment to Network Rail's statutory undertaking and therefore the proposed Order should not be made. Until such time as Network Rail is given the adequate protection and assurances requested as detailed in this objection, Network Rail's objection to the proposed Order will not be withdrawn. Network Rail reserves the right to raise further issues in evidence and intends to take a full part in the examination process, including attending and making oral representations at relevant hearings."
Members of the Public/Businesses
Brown & Co on behalf of Patricia Martha Mary Eayrs
"This representation is made on behalf of Patricia Martha Mary Eayrs as owner of plots 2/25a, 2/25b and 2/39a together with part of plot 2/32a as frontager to one side of the highway. My client also holds other interest in plots 2/24a, 2/24b,2/24c, 2/24d, 2/24e, 2/24f, 2/26a and 2/26b. My client holds this land as an investment with the intention of commercial development being obtained. It is proposed that the entirety of the land is to be acquired as part of the scheme to mainly provide a flood alleviation area. A small section of the land is required for the new link road. My client believes that the flood alleviation area would be better suited closer to and alongside the existing river rather than creating additional area further away from the river on high value land. My clients therefore suggest that the land taken in this area is altered to reflect the areas at greater risk of flooding. The land alongside the river is detailed as lying within Flood Zones 2 and 3 and so would be better suited as flood compensation areas. Accordingly our client will represent that the DCO should be amended to reflect the matter set out above."
Members of the Public/Businesses
Brown & Co on behalf of Pearson Gape Farming Partnership
"This representation is made on behalf of The Pearson Gape Farming Partnership as [Redacted] of the land identified as plots 14/8a, 14/8b, 14/8c, 14/8d, 14/8e and 14/8f. My client is concerned regarding the electrical diversion on their land as this is the supply for Pastures Farmhouse and the agricultural buildings. My client wants to ensure that an adequate supply is put in place for the dwellings and buildings following the scheme and diversion. My client has also agreed with Highways England that they will be contacted during these works to ensure that appropriate services can also be connected to their retained farm buildings. My client understands from the plans submitted for the Development Consent order that a new roundabout access is to be included as the Caxton Gibbet West roundabout and my clients request further details on the width and type of access to be created here. It is also noted that the cycle lane included from Caxton Gibbet running south is not linking to any of the proposed paths included within the Cambourne development and my client would ask that the scheme revisit the proposed cycle path to ensure it links appropriately with local cycle networks. My client is concerned regarding land drainage on the fields affected by the scheme. My client seeks confirmation that drainage surveys will be undertaken prior to entry to ensure that land drainage can be put in place prior to any damage being caused. My client practices Regenerative Agriculture and has invested considerable time and money into creating high quality, biologically healthy, well structured soil. My client seeks confirmation that appropriate soil surveys and consideration will be given to this on the temporary land take to ensure they are returned to them in the same condition following completion of the scheme. My client also seeks confirmation of the boundary treatments along the route to ensure the security of his property both during construction and following completion. My client will require access to all land at all times during construction of the project and seeks confirmation that this will be available and details on the proposed method of works to ensure that access is not interrupted. Accordingly our client will represent that the DCO should be amended to reflect the matters set out above."
Other Statutory Consultees
Public Health England
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project and can confirm that: Air Quality Impacts It is unclear how the applicant has evaluated the long and short-term impacts on air quality in relation to human health during the construction phase. The Environment Statement (ES) should clearly set out the long and short-term impacts on air quality in relation to human health (specifically particulate matter PM10 and PM2.5) from the construction phase of the development, or provide suitable justification as to why no further assessment is required. Human Health and Wellbeing This section of PHE’s response, identifies the wider determinants of health and wellbeing we expect the ES to address, to demonstrate whether they are likely to give rise to significant effects. PHE has focused its approach on scoping determinants of health and wellbeing under four themes, which have been derived from an analysis of the wider determinants of health mentioned in the National Policy Statements. The four themes are: • Access • Traffic and Transport • Socioeconomic • Land Use Having considered the submitted ES PHE wish to make the following specific comments and recommendations: Eltisley Manor An approach to the identification of vulnerable populations was provided within the ES but does not appear to adequately reflect the findings within the Equality Impact Assessment (EqIA). The impacts on health and wellbeing and health inequalities of the scheme may have particular effect on vulnerable or disadvantaged populations, including those that fall within the list of protected characteristics. The assessments and findings of the ES and any EqIA should be cross referenced between the two documents, particularly to ensure the comprehensive assessment of potential impacts/effects for health and inequalities and where resulting mitigation measures are mutually supportive. Chapter 12 considers access to Eltisley Manor nursing home, which is a 37-bed psychiatric nursing home offering specialist mental health care services for the over 50s, separate care for over 18s with complex mental health issues and patients coming to the end of their rehabilitation process. The nursing home can only be accessed by using the existing A428. Chapter 12 assesses the impact from overnight road closures and offers mitigation to maintain access for staff movement and emergency access. It does not provide an estimate for the potential delay in journey time, particularly in case of emergency access or egress. It does not provide any details on the frequency of any emergency access or egress for the facility. It should also be noted that this sensitive location was not identified within the PEIR and contact with the Care Home Manager in January 2021 appears very late in the process. Chapter 12 does not however, consider the potential for delays in journeys during daytime movement of staff or residents, but is identified within the EqIA. The EqIA does consider this aspect and the potential effect on residents who will be highly sensitive to increased journey time length or changes in routine and journey routes. There will also be impacts on staff and visitors. There is also insufficient justification that the residents of Eltisley Manor are to be considered a medium sensitivity. The vulnerability of this population group should be highly sensitive to both temporary and permanent change and impacts. It should also be noted that the PHE response to the PEIR also contained a specific recommendation to the inclusion of mental health impacts within the scope of population and human health. Recommendations The ES should contain greater detail in relation to the identification, assessment of impacts / effects and agreed mitigation measures with regards to Eltisley Manor and this should include consideration of emergency service access."
Members of the Public/Businesses
Brown & Co on behalf of R. H. Topham & Sons Limited
"This representation is made on behalf of R H Topham & Sons as owners of the land north of the existing A428 and who hold an interest in other land affected by the proposed route. My client occupies the land identified as plots 9/9a, 9/10a, 10/4a, 10/4b, 10/4c, 10/4d, 10/5a, 10/5b, 10/5c, 10/5d, 11/4a, 11/4b, 11/4c, 11/4d, 11/4e, 11/4f, 11/4g, 11/5a, 12/3a, 12/3b, 12/3c, 12/4a, 12/4b, 13/5a and 13/5b. My client also has an interest in the following plots, 6/8a, 6/8b, 6/8c, 6/8d, 6/8e, 6/8f, 6/8g, 6/8h, 8/4a, 14/19a and 14/19b. The Book of Reference shows the following plots 9/11a and 9/11b as unregistered and they are owned by my clients R H Topham Ltd. The Book of Reference also shows 9/12a and 9/12b as being owned by Abbotsley Farms Ltd, this is a registration error and these are owned by R H Topham & Sons. My client also owns 10/7a and 10/7b which is identified as unregistered. I would be grateful if the Book of Reference could be amended to reflect these changes. My client strongly objects to this proposal and feels that an alignment closer to the existing A428 will have a reduced impact on the surrounding area together with their farming operations with a reduced area being severed as a result of the scheme. The proposed A428 project will have a significant impact on my clients farming operations with a significant amount of land being acquired as part of the scheme. In addition to this the main farming site of my client is to be split in half. My client currently prides themselves on maximising efficiency with farming operations in order to reduce costs and farm in an environmentally friendly way. The scheme will make this very difficult to continue due to the creation of a number of small fields and difficult field shapes. My clients currently enjoy uninterrupted access over all of their land north of the existing A428 over a series of farm tracks. During construction my clients will require access over bridleway 1/18 at plot 10/7b. My clients are also concerned regarding the on and off ramps of the new bridleway bridge at this location and whether they will be suitable for modern farm machinery. It has been brought to Highways Englands attention that the spur from the bridleway to the existing A428 is coloured pink however this should be temporary possession land (green) so that possession and control reverts back to my client at the completion of the scheme. In addition to this during our most recent meeting with Highways England it was discussed that a permanent access track will be required from this point along the southern border of plot 10/4b and along the rear of the other properties at this point in order to access my client retained land which is severed as a result of the scheme. It was agreed that this is to be included as green land within the DCO. My client also requires access to the fields located to the south of the proposed A428 during construction and note that no access is being provided. During our most recent meeting the Highways England it was suggested that a new access track is temporarily installed running south of the proposed multi-purpose construction area and into the fields at this location. My clients are concerned regarding provision of adequate post scheme drainage at this proposed multi-purpose construction area following completion of the scheme when this temporary possession land is handed back to them. My client seeks confirmation that soil surveys will be undertaken prior to commencement to ensure the land is returned in the same condition, mainly in relation to compaction and drainage. In relation to the new Toseland road flyover area my client notes significant areas of land are being used for multi-purpose construction areas. These are spread over two locations and my client suggests that these are amalgamated in order to minimize the impact on farming operations. My client also seeks details on what these areas will specifically be used for. It is also noted that there are areas of soil storage at this location which my client feels can be amalgamated with the other temporary land take areas and in line with field boundaries in order to minimize the impact on farming operations during the scheme. In relation to all temporary areas my client requests that soil surveys are undertaken prior to entry to ensure that the land is returned to them in the same condition as when it is taken. My client is concerned regarding the diversion of Footpath 278/7. My client is concerned that the public will make use of their farm tracks as footpaths rather than using the proposed diversion. This increases the risk of accidents with farm machinery. We understand that signage will be put in place to direct people along the footpath however my client requests further action is taken to ensure that footpath users remain on the proposed route. My client enjoys good access from Toseland Road which is suitable for HGV access and requires further detail on the proposed accesses to ensure they are suitable for HGV access following completion of the scheme. My client is concerned regarding land drainage on the fields affected by the scheme. My client seeks confirmation that drainage surveys will be undertaken prior to entry to ensure that land drainage can be put in place prior to any damage being caused. My client also seeks confirmation of the boundary treatments along the route to ensure the security of his property both during construction and following completion. My client will require access to all land at all times during construction of the project and seeks confirmation that this will be available and details on the proposed method of works to ensure that access is not interrupted. Accordingly our client will represent that the DCO should be amended to reflect the matters set out above."
Members of the Public/Businesses
Brown & Co on behalf of Robert John Millard
"This representation is made on behalf of Mr Robert Millard who is the owner and occupier of [Redacted] and who own and [Redacted] the plot identified as 13/7a within the book of reference. Plot 13/7a is identified on the General Arrangement Plan as being temporary use for the new Eltisley link road. The land forms part of my clients residential garden and comprises a very thin strip which is not necessary for the construction of the link road. The link road follows the existing road at this point which already has a wide verge. My client is concerned regarding the provision of appropriate fencing alongside the boundaries both during construction and following completion to ensure the security of his residential property is not compromised. Accordingly our client will represent that the DCO should be amended to reflect the matters set out above."
Members of the Public/Businesses
Brown & Co on behalf of Roger Graham
"This representation is made on behalf of Mr Roger Graham who is the owner and occupier of [Redacted] and who is the owner of the plots identified as 1/42a and 1/42c within the Book of Reference. Mr Graham also benefits from rights of access over plots 1/8t, 1/8u, 1/43a, 1/43b and 1/43d. My client strongly objects to the proposals and feels that they will have a detrimental impact on the surrounding area and do not deliver the benefits they set out to achieve. Widening of the existing road network would achieve the same result. My client retains his residential dwelling to the East of the current A1. My client is concerned that access is maintained at all times during construction to his dwelling onto the main road network. The current access route lies over plots 1/8u, 1/8t, 1/8q and 1/8p. The new access track is proposed under Works No. 15 however it is unclear when this new access track will become operational. My client is also concerned that services such as electricity and telephone remain connected throughout the scheme. Plot 1/8q is identified as being a site compound area. My client is concerned regarding what mitigation measures will be put in place to reduce this impact of this area on his property. My client also seeks confirmation of the working hours, lighting, noise and pollution impacts on his property. During the consultation my client was provided with an extensive reinstatement program for his residential garden land which is being acquired temporarily, we note that this has not formed part of the DCO application and seeks to clarify that this will be discussed further with Highways England at the detailed design stages. My client is concerned regarding the provision of appropriate fencing alongside the boundaries both during construction and following completion to ensure the security of his residential property is not compromised. My client also seeks clarification of the planting to be undertaken alongside his new access track so as to reduce the noise and visual impact of the proposals. My client is concerned regarding the height of the flyovers and slip road to the North and South of Green Acres including the height of the Kelpie Marina access and their visual impact on his property. My client seeks confirmation of the mitigation measures which will be put in place to protect his property. My client is also concerned with the height of these flyovers and the privacy of his property. My client seeks confirmation of what measures will be put in place to reduce this impact. My client asks that the above concerns are considered as part of the planning process."
Members of the Public/Businesses
Carter Jonas LLP on behalf of SIR Trustee 17 & SIR Trustee 18 Limited
"INTRODUCTION 1. We write on behalf of SIR Trustee 17 & SIR Trustee 18 Limited (the ‘Freeholder’) making Relevant Representations to the A428 Black Cat to Caxton Gibbet Improvements Development Consent Order (the Scheme) being promoted by Highways England Ltd (the ‘Applicant’). 2. The Freeholder own a hotel (the ‘Hotel’) leased to Travelodge on the existing Black Cat roundabout. The Hotel is a 40 bed budget hotel, located to the immediate north of the existing Black Cat roundabout. 3. The Hotel is well established and has been trading for approximately 19 years, from August 2000 in a well-connected location on the strategic road network. COMULSORY PURCHASE AND EXTINGUISHMENT 4. The Hotel will compulsorily acquire (Plots 1/29a 1/30a) and be demolished as part of the Scheme. The Applicant has said in their view it will be reasonably necessary to extinguish the Hotel. ROADSIDE SERVICES AND ROAD SAFETY 5. As well as a commercial enterprise the Hotel serves an important function in supporting the strategic road network. The Department for Transport policy on roadside services states: “The primary function of roadside facilities… is to support the safety and welfare of the road user.” 6. The provision of comprehensive services on this key junction serving two major routes (A1 and A428) provides a higher quality of roadside facilities, and more sustainable land use than a number of smaller services scattered along both routes. 7. Government policy and industry guidance emphasises the risks of driver fatigue in road accidents, and the benefits of regular breaks, consumption of caffeinated drinks and over-night stops in preventing accidents. 8. Government policy in DfT Circular 02/2013 ‘The strategic road network and the delivery of sustainable development’ (10th September 2013) states: “Motorway service areas and other roadside facilities perform an important road safety function by providing opportunities for the travelling public to stop and take a break in the course of their journey. Government advice is that motorists should stop and take a break of at least 15 minutes every two hours. Drivers of many commercial and public service vehicles are subject to a regime of statutory breaks and other working time restrictions and these facilities assist in compliance with such requirements.” IMPACT OF THE SCHEME 9. The Scheme would result in significantly increased traffic volumes on the east / west route. Following extinguishment of the Hotel there will be an 18 mile gap between services and over-night stays on this route. The intensification of traffic on the east/west route due to the Scheme would therefore be associated with a reduction in roadside services in a key location, which would be potentially detrimental to the welfare of drivers. 10. There are other services and a hotel on the A1 in this area for north and south bound travellers, however these do not offer such comprehensive provision of hotel, fuel and hot food options, and in some cases are only accessible from one side of the carriageway. Planned upgrades of the A1 are likely to extinguish more roadside services. 11. This risk underlines the importance of retaining a comprehensive hotel service offering at the Black Cat roundabout. This is a strategic location that will provide services to both the A1 and improved A428/A421 route more efficiently and sustainably, maximising the benefit to road users and with less impact on land use than smaller roadside provisions scattered along both routes. 12. A key objective of the Scheme (Environment Statement [ES] Chapter 2, 2.2.2) “Safety: Improve safety at junctions, side roads and private accesses by reducing traffic flows on the existing A428. Improve safety on the A1 by removing existing substandard side road junctions and private accesses onto the carriageway” 13. ES ‘Chapter 12: Population and Human Health’ concludes that the Scheme would have a beneficial impact upon road safety and is therefore assessed to have a positive health outcome. 14. We note however that the ES (specifically the Transport Assessment) appears to have no regard to the following when arriving at its conclusions on the Scheme’s impact on safety: - DfT policy on roadside facilities and road user safety - The provision of roadside facilities - The impact of the loss of services at Black Cat Roundabout (including the Hotel) CONCLUSION 15. The Freeholder object to the compulsory purchase of the Hotel and extinguishment of the business and loss of jobs. They consider that the Applicant should provide for the provision of roadside services in this sustainable location as an integral part of the Scheme, in order to safeguard road safety in accordance with government policy. 16. The omission of consideration of this important policy factor (roadside facilities and road user safety) in the ES mean that the true adverse impacts of the Scheme have not been properly assessed. In the context of the increase in traffic associated with the Scheme and loss of roadside facilities such as the Hotel, the Scheme design is potentially inadequate. 17. In the absence of any tangible support to the Freeholder to assist a re-location they consider the Applicant has not taken reasonable steps to avoid compulsory purchase and that there is therefore no compelling case in the public interest to justify the use of such powers."
Parish Councils
Staploe Parish Council
"Staploe Parish Council support the proposals for the new Black Cat roundabout and the A428. We believe it will lead to improved traffic flow, less congestion and less use of local roads as “rat runs”. We have two concerns which are: 1. That there appears to be very little space for some of the proposed more northerly East West rail routes to run directly adjacent to the new roundabout at Black Cat 2. How will you prevent people using local back roads to avoid congestion during construction?"
Members of the Public/Businesses
Swavesey & District Bridleways Association
"This highways develoment presents a unique opportunity (in terms of funding and access to land) to work in partnersehip with the consultants, developers, local highway authority and Local Access Forum to ensure that existing Public Rights of Way are both protected and enhanced (by changing from Footpath (walkers) to Bridleway (walkers, cyclists, horseriders) or Restricted Byways (all non-motorised users). Also we wish to see that all possible new opportunities are taken to increase the PROW network in an inclusive way by the provision of new routes, both to provide circular routes, to provide links in broken networks, and to link villages and communities together, with safe crossing points. The standard has already been set with the A14 work from which much can be seen as good example and also much can be learnt in terms of mistakes made. We are pleased to see the same Highways England lead person is employed on the A428 as was on the A14."
Members of the Public/Businesses
Brown & Co on behalf of Terence John Wright
"This representation is made on behalf of Terence John Wright who is the owner of plots 2/18a, 2/18b and 2/18c detailed within the Book of Reference. My client is concerned regarding the provision of appropriate fencing alongside the boundaries both during construction and following completion to ensure the security of the field. The land is let on a Farm Business Tenancy for the grazing of livestock and so the field must be secure at all times. My client currently enjoys access from a gate located onto Chawston Lane and this is being removed by the new link road. A new access has been provided however further details have not been provided as to width and size of apron, my client required clarity on this to ensure it is adequate."
Members of the Public/Businesses
Brown & Co on behalf of The Huntingdon Freemen
"Our clients are the Huntingdon Freemen’s Trust, a registered charity with land holdings around the Black Cat area. In total our clients land, identified within the Development Consent Order extends to approximately 9.4912 ha due and is made up as follows: • Land to rear of Travelodge (Plots 1/23a & 1/23d) – 6.5936 Ha • Land opposite Roxton Garden Centre (Plots 1/23e & 1/23f) – 0.8526 Ha • Land adjoining Roxton Garden Centre (Plot 1/23j) – 1.5505 Ha • Land south of Black Cat (Plots 1/23k & 1/23l) – 0.4945 Ha Our clients note the proposed access shown on the General Arrangements Plan sheet 1 and identified as new and approved private means of access no. 2 and the access at this point must be suitable for farm machinery and equipment and should be of a suitable width and construction and ensure there is adequate visibility splays and turning circles. Our clients are also concerned about the camber and height of field access and installation of gates at this point. Our clients note the location of footpaths 7 & 8 as they cross their land and are concerned what access arrangements are to be installed along the boundary and how this shall ingrate with the highway fencing. In respect of our clients land identified under plot 1/23g, which is being taken for temporary possession, we note that within plot 1/23e provision is made on the rights of way and access plans sheet 1B for access to the attenuation basin, however, no field access is provided at this location and such provision needs to be added to the Development Consent Order to ensure our clients can access their retained land. The access to be provided needs to be suitable for farm machinery and equipment and in particular there should be adequate turning circles and visibility splays. Our client, as owners of plot 1/23j note the provision for a field access from the proposed service road as shown on the General Arrangement plan and wish to ensure that the field access road shown on the plan extends beyond the permanent acquisition land, to our clients retained land identified within Land Registry Title BD296658 and wish to ensure that any access does not fall short of their boundary. During the scheme provision for accessing land outside the scheme adjoining plot 1/23h needs to be provided. Our client has concerns regarding the provision of appropriate fencing alongside highway boundary and effective maintenance of all existing drainage schemes. Our clients seek clarification over the specification of the culvert and gate to be constructed at plot 1/23n and to ensure all existing water flows are not interrupted."
Members of the Public/Businesses
response has attachments
The Woodland Trust (WITHDRAWN) (The Woodland Trust (WITHDRAWN))
"The Woodland Trust welcomes the opportunity to register a representation to the following project. We hold concerns with regards to the removal of G61, a group of Cherry Plum trees recognised as veteran specimens within the applicant’s Arboricultural Impact Assessment (AIA) Report [APP-183]. The Trust asks that all veteran trees are retained, and adequately protected during construction in line with Natural England’s Standing Advice which states: “A buffer zone around an ancient or veteran tree should be at least 15 times larger than the diameter of the tree. The buffer zone should be 5m from the edge of the tree’s canopy if that area is larger than 15 times the tree’s diameter.” Furthermore, we would appreciate clarity on the Root Protection Area (RPA) afforded to T311, a veteran elm adjacent to the proposed scheme that is also recorded on the Ancient Tree Inventory (ATI no: 189122). We note within the Arboricultural Impact Assessment that “T311 has been provided an increased RPA of 15 times the trunk diameter, as set out in Veteran Trees: A guide to good management (Ref 1-12).” However, Sheet 35 of the Tree Protection Plan [APP-186] denotes T311 with an RPA in line with the BS:5837:2012, which is usually calculated at 12 times the stem diameter. Can the applicants please confirm that T311 will be afforded an increased buffer zone as per the AIA? In summary, the Woodland Trust objects to the proposed development on the grounds of direct loss of veteran trees. We hope our comments are of use to you. Submission withdrawn - see attached"
Members of the Public/Businesses
Brown & Co on behalf of Thomas Pearson
"This representation is made on behalf of Mr Thomas Pearson as [Redacted] of the land identified as plots 14/8a, 14/8b, 14/8c, 14/8d, 14/8e and 14/8f and who also has an interest in plot 14/20a. My client is concerned regarding the electrical diversion on their land as this is the supply for Pastures Farmhouse and the agricultural buildings. My client wants to ensure that an adequate supply is put in place for the dwellings and buildings following the scheme and diversion. My client has also agreed with Highways England that they will be contacted during these works to ensure that appropriate services can also be connected to their retained farm buildings. My client understands from the plans submitted for the Development Consent order that a new roundabout access is to be included as the Caxton Gibbet West roundabout and my clients request further details on the width and type of access to be created here. It is also noted that the cycle lane included from Caxton Gibbet running south is not linking to any of the proposed paths included within the Cambourne development and my client would ask that the scheme revisit the proposed cycle path to ensure it links appropriately with local cycle networks. My client is concerned regarding land drainage on the fields affected by the scheme. My client seeks confirmation that drainage surveys will be undertaken prior to entry to ensure that land drainage can be put in place prior to any damage being caused. My client practices Regenerative Agriculture and has invested considerable time and money into creating high quality, biologically healthy, well structured soil. My client seeks confirmation that appropriate soil surveys and consideration will be given to this on the temporary land take to ensure they are returned to them in the same condition following completion of the scheme. My client also seeks confirmation of the boundary treatments along the route to ensure the security of his property both during construction and following completion. My client will require access to all land at all times during construction of the project and seeks confirmation that this will be available and details on the proposed method of works to ensure that access is not interrupted. Accordingly our client will represent that the DCO should be amended to reflect the matters set out above."
Members of the Public/Businesses
Tina Yates
"It is vital that all routes for non-motorised users (NMUs) include provision for horse riders. This is a great opportunity to enhance the NMU connectivity as has been done alongside the A1307 with the creation of the new A14. As development continues in Cambridgeshire, safe routes for horse riders have come under pressure and further dualling of the A428 adds to that pressure. The A428 presents a major block for horse riders and other NMU groups trying to go from one side to the other, and prevents connectivity between villages. This opportunity should be used to enhance connectivity so that all NMU groups are encouraged to get outside for exercise and for going between villages. This ability to connect has proved vital for health during the pandemic, and should be enhanced and encouraged. The A14 development demonstrates some good examples of best practice, and this best practice should be followed with the A428. On no account should horse riders have routes truncated by the development, or be placed in danger by the development."
Members of the Public/Businesses
Carter Jonas LLP on behalf of Travelodge Hotels Ltd
"INTRODUCTION 1. We write on behalf of Travelodge Hotels Ltd (‘Travelodge’) making Relevant Representations to the A428 Black Cat to Caxton Gibbet Improvements Development Consent Order (the Scheme) being promoted by Highways England Ltd (the ‘Applicant’). 2. Travelodge are leaseholder of a hotel (the ‘Hotel’) on the existing Black Cat roundabout. The Hotel is a 40 bed budget hotel, located to the immediate north of the existing Black Cat roundabout. 3. The Hotel is well established and has been trading for approximately 19 years, from August 2000 in a well-connected location on the strategic road network. COMULSORY PURCHASE AND EXTINGUISHMENT 4. The Hotel will compulsorily acquire (Plots 1/29a 1/30a) and be demolished as part of the Scheme. The Applicant has said in their view it will be reasonably necessary to extinguish the Hotel. ROADSIDE SERVICES AND ROAD SAFETY 5. As well as a commercial enterprise the Hotel serves an important function in supporting the strategic road network. The Department for Transport policy on roadside services states: “The primary function of roadside facilities… is to support the safety and welfare of the road user.” 6. The provision of comprehensive services on this key junction serving two major routes (A1 and A428) provides a higher quality of roadside facilities, and more sustainable land use than a number of smaller services scattered along both routes. 7. Government policy and industry guidance emphasises the risks of driver fatigue in road accidents, and the benefits of regular breaks, consumption of caffeinated drinks and over-night stops in preventing accidents. 8. Government policy in DfT Circular 02/2013 ‘The strategic road network and the delivery of sustainable development’ (10th September 2013) states: “Motorway service areas and other roadside facilities perform an important road safety function by providing opportunities for the travelling public to stop and take a break in the course of their journey. Government advice is that motorists should stop and take a break of at least 15 minutes every two hours. Drivers of many commercial and public service vehicles are subject to a regime of statutory breaks and other working time restrictions and these facilities assist in compliance with such requirements.” IMPACT OF THE SCHEME 9. The Scheme would result in significantly increased traffic volumes on the east / west route. Following extinguishment of the Hotel there will be an 18 mile gap between services and over-night stays on this route. The intensification of traffic on the east/west route due to the Scheme would therefore be associated with a reduction in roadside services in a key location, which would be potentially detrimental to the welfare of drivers. 10. There are other services and a hotel on the A1 in this area for north and south bound travellers, however these do not offer such comprehensive provision of hotel, fuel and hot food options, and in some cases are only accessible from one side of the carriageway. Planned upgrades of the A1 are likely to extinguish more roadside services. 11. This risk underlines the importance of retaining a comprehensive hotel service offering at the Black Cat roundabout. This is a strategic location that will provide services to both the A1 and improved A428/A421 route more efficiently and sustainably, maximising the benefit to road users and with less impact on land use than smaller roadside provisions scattered along both routes. 12. A key objective of the Scheme (Environment Statement [ES] Chapter 2, 2.2.2) “Safety: Improve safety at junctions, side roads and private accesses by reducing traffic flows on the existing A428. Improve safety on the A1 by removing existing substandard side road junctions and private accesses onto the carriageway” 13. ES ‘Chapter 12: Population and Human Health’ concludes that the Scheme would have a beneficial impact upon road safety and is therefore assessed to have a positive health outcome. 14. We note however that the ES (specifically the Transport Assessment) appears to have no regard to the following when arriving at its conclusions on the Scheme’s impact on safety: - DfT policy on roadside facilities and road user safety - The provision of roadside facilities - The impact of the loss of services at Black Cat Roundabout (including the Hotel) CONCLUSION 15. Travelodge object to the compulsory purchase of the Hotel and extinguishment of the business and loss of jobs. They consider that the Applicant should provide for the provision of roadside services in this sustainable location as an integral part of the Scheme, in order to safeguard road safety in accordance with government policy. 16. The omission of consideration of this important policy factor (roadside facilities and road user safety) in the ES mean that the true adverse impacts of the Scheme have not been properly assessed. In the context of the increase in traffic associated with the Scheme and loss of roadside facilities such as the Hotel, the Scheme design is potentially inadequate. 17. In the absence of any tangible support to Travelodge to assist a re-location they consider the Applicant has not taken reasonable steps to avoid compulsory purchase and that there is therefore no compelling case in the public interest to justify the use of such powers."
Members of the Public/Businesses
Foot Anstey on behalf of Welcome Break Services Limited
"1. Welcome Break Services Limited has responded to several of Highways England's consultations relating to the proposed Development Consent Order including in 2019 and 2020 and it has had several meetings with Highways England to discuss the impact of the proposed highways scheme on its Wyboston Service Area (WSA). 2. Highways England is aware of the potential impact of the proposed Scheme on the WSA business as its proposal involves closing the existing slip road leading from the WSA to the A-road and its replacement with a 1km egress via a 30mph service road. This will have a significant detrimental effect on the WSA business and will make the WSA significantly less commodious for travellers, undermining the very benefits that such facilities and services provide to road users. 3. Welcome Break Services Limited has made several proposals to Highways England in terms of an alternative slip road design, layout and access point onto the A-road. These alternatives are technically viable and would be more commodious for travellers. Highways England has not adopted these proposals and this will be to the detriment of those using the highway network and will detract from and not be offset by the other benefits which Highways England claims the Scheme will deliver. 4. Highways England does not appear to have followed DMRB guidance in its own designs yet it objects to Welcome Break Services Limited's proposals to retain and adapt the existing slip road along similar principles. 5. The new service road will not have traffic lights at its junction with the new roundabout. Phasing arrangements will make entry on to the roundabout difficult further undermining the claimed benefits of the Scheme. Highways England does not appear to addressed this in the Development Consent Order application. 6. The "Introduction to the Application" document states at paragraph 2.2.1 (g) "Customer satisfaction" that Highways England "listen to what is important to our customers to deliver a better road for everyone and improve customer satisfaction". There is no evidence that Highways England has sought to canvas customers of the WSA. The provision of WSAs is an important aspect of the highway network. If customers of the WSA have not been canvassed there is no clear evidence that Highways England has factored in to the design of the Scheme or its understanding of the impacts of the design of the Scheme on customer satisfaction or dissatisfaction. This goes to the heart of claims by Highways England that the Scheme will improve the highway network and the experience of road users. 7. Reducing the slip road to a 1km 30 mph service road undermines the Government policy requirements relating to the services to be provided at service areas. 8. Highways England does not appear to have assessed either the impact of the changes to the slip road on the WSA business or its convenience of use for road users. Its proposal in so far as it affects WSA is inconsistent with Nation Policy Statement for National Networks which sets both the Government's vision and strategy to include improvement to journey quality. 9. Highway England has not given due consideration to alternative solutions in terms of the egress from the WSA to the A-road contrary to Government guidance on the pursuit and use of compulsory purchase powers."
Members of the Public/Businesses
Brown & Co on behalf of William Eayrs
"1. This representation is made on behalf of Mr William Eayrs of [Redacted] and is the owner of plots 2/25a, 2/25b and 2/39a together with part of plot 2/32a as frontager to one side of the highway. My client also holds other interest in plots 2/24a, 2/24b,2/24c, 2/24d, 2/24e, 2/24f, 2/26a and 2/26b. 2. My client holds this land as an investment with the intention of commercial development being obtained. It is proposed that the entirety of the land is to be acquired as part of the scheme to mainly provide a flood alleviation area. A small section of the land is required for the new link road. 3. My client believes that the flood alleviation area would be better suited closer to and alongside the existing river rather than creating additional area further away from the river on high value land. My clients therefore suggest that the land taken in this area is altered to reflect the areas at greater risk of flooding. The land alongside the river is detailed as lying within Flood Zones 2 and 3 and so would be better suited as flood compensation areas. 4. Accordingly our client will represent that the DCO should be amended to reflect the matter set out above."
Members of the Public/Businesses
Savills UK Limited on behalf of Woodthorpe Hall Garden Centres Limited
"Savills (UK) Ltd are instructed by Woodthorpe Hall Garden Centres Limited, who own and operate Roxton Garden Centre, to act on their behalf in relation to the A428 Black Cat to Caxton Gibbet Improvements scheme (“the Scheme”). In accordance with the DCO application “Land Plans Regulation 5(2)(i) Improvements Sheet 1”, the above mentioned parties own plots 1//40a, 1/40b and 1/40c, which are affected by either temporary or permanent acquisition, or acquisition of new rights. Roxton Garden Centre comprises a 12.25 acre (approx.) site which includes a garden centre, and restaurant, car parking, and fields either side, used for recreational uses (a maze) and overflow car parking. The site is also occupied by four concessions: Gap Home Improvements Limited, Merit Garden Products, Happy Brewer and the Black Cat Farm Shop. The garden centre is open seven days a week and has a customer base from a wide geographical area. Peak visitor times are during the weekends with customers being more family based, however during the week there is a consistent trade of more senior customers who use the restaurant facility also. The four concessions also attract a range of customers on a regular basis. The land parcels affected by the scheme are situated on the north-eastern side of Roxton Garden Centre, and comprise a grass field which is regularly used by the garden centre as overflow car parking when required, the main car park proving to be inadequate at peak times. This therefore means that the garden centre is at risk of losing a significant amount of car parking for the duration of the scheme. The entrance to the garden centre, off Bedford Road, is also included within the affected land parcels. This presents some logistical and operational concerns for the garden centre which will need to be addressed. It is for these reasons that we have been instructed to submit the following representation to the Highways England scheme. The majority of the field used for car parking is included within plot 1/40a. This plot is required for temporary possession purposes only. The south eastern corner of this field falls within plot 1/40b, which is to be permanently acquired, and through which the proposed new ‘Kelpie Marina Access Track’ will be constructed. The south-western corner of the field is due to have rights acquired, as well as temporary possession taken. The largest plot, plot 1/40a includes not only the entrance to the garden centre, but also the track leading to the back of the garden centre, and to a separate concession, Gap Home Improvements Ltd, who use this track daily for the operation of their business. The loss of this field will result in a significant reduction in car parking available for customers as well as potential restrictions or loss of access to the garden centre depending on how the land will be used and the duration of such use. Further, any works to, or closure of Bedford Road, even on a temporary basis may result in a reduction in customer traffic which would have an adverse impact on the profitability of the garden centre. Equally a full car park is likely to deter customers, and may also lead to customers who cannot park within the site, parking on the verge of the public highway of Bedford Road. Therefore it is important that the garden centre are consulted early on in this scheme so that sufficient measures can be put in place to ensure these impacts are mitigated/managed."
Members of the Public/Businesses
Abbey Developments Cambridgeshire Limited
"Abbey Developments Cambridgeshire Limited own the land under title number [Redacted] which is located to the south of the existing Caxton Gibbet roundabout which connects the A428 with the A1198. [Redacted] is divided by Cambridge Road. Our existing land essentially falls into three parcels as follows: 1) Land to the west of [Redacted] is developed as a food retail services site consisting of 4 units and a car park. Tenants include McDonald’s, Costa Coffee and Subway. 2) Land to the centre of [Redacted] (west of Cambridge Road) is undeveloped land for which planning permission is being sought from South Cambridgeshire District Council for some small industrial units. 3) Land to the east of [Redacted] (east of Cambridge Road) is undeveloped land. We have held discussions with Highways England since the inception of the A428 proposals and appreciate the revisions that have been made to the scheme to reflect our comments. Our comments fall within three categories as set out below. Landscaping The proposal landscaping scheme is acceptable to us following the revisions that have been made. It is important for the viability of the food retail services site to ensure that good visibility of the site is available from roads and the landscaping scheme proposed within the DCO application achieves this. We would not wish to see the landscaping scheme alter from that currently and proposed and would request consultation be undertaken if changes are proposed. Signage We have discussed this matter in some detail previously with Highways England. We note the comments within Chapter 2 of the Environmental Statement which at paragraphs 2.5.77 to 2.5.79 state that: New road signage and markings would be installed across the Scheme to ensure route legibility for road users travelling on new and improved roads, and to support the Scheme objectives of cutting congestion and improving safety. As the Scheme would involve modifications to both the SRN and local road network, static road signage would be agreed with the relevant local authorities to ensure continuity is achieved along the following routes: a. The existing A428. b. Bedford Road. c. Roxton Road. d. Barford Road. e. B1046. f. Potton Road. g. B1428 Cambridge Road. h. Toseland Road. i. B1040. j. A1198. Where existing signs do not conform to new or modified road layouts within the Scheme, these would be removed and replaced with new signage containing updated information. New and modified sections of road would be permanently marked using a combination of road markings and road studs. We are disappointed that there are no details of signage at this stage given the importance of signage to the viability of the existing food retail services site. It is essential given the proposed level of the A428 road at Caxton Gibbet that appropriate signage is in place well before the junctions to enable customers to be aware of the service facilities so that they are able to plan to leave the proposed A428 in advance of the junction. This applies for vehicles travelling both east and west bound on the proposed A428. We would request that details of signage be provided at this stage and that adequate consultation be undertaken with ourselves and our tenants such that views can be exchanged and a signage design (or as a minimum a strategy) agreed. We consider that these matters are critical to the scheme and therefore we reserve the right to object to the scheme if signage details are not provided. CPO Area 14/17a We note the requirement for temporary possession and acquisition of an area of our land at the access from Cambridge Road to the centre of [Redacted]. We do not object to this requirement but, as already discussed with Highways England, would welcome ongoing communication in this regard given our current proposal to develop the centre parcel to which access is required over the CPO area. We would welcome further discussions in relation to the above matters particularly in respect of signage."
Members of the Public/Businesses
response has attachments
CMS Cameron McKenna LLP on behalf of Cadent Gas Limited
"Please refer to the Relevant Representation submitted to '[email protected]' at 14:13 on 10 June 2021."
Local Authorities
Cambridgeshire County Council
"A428 Relevant Representations Cambridgeshire County Council (CCC), Huntingdonshire District Council (HDC) and South Cambridgeshire District Council (SCDC) are reviewing the A428 Black Cat to Caxton Gibbet Development Consent Order Application (the Application) and believe that discussion, further information, and changes to the Application will be required in the areas set out below. This is based on the current understanding of the information and may be altered, added to or amended as the review continues and discussion with Highways England begins. These are the combined representations of CCC, HDC and SCDC. Note: CCC is submitting this response in advance of a Committee resolution but will be considering at the next Highways and Transport Committee. Biodiversity • There are concerns about the robustness of the baseline survey data. The Councils are seeking firm commitment to biodiversity net gain from an agreed baseline and measured using established methodology. • The assessment of net gain and the total has not used standard methodology • Changes to the proposed species mix and habitats in some areas may be required. • Mitigation for impact to other habitats such as arable field margins needs to be discussed and agreed • The Environmental Masterplan needs to be updated. It is currently incomplete, doesn’t reflect general works arrangement and doesn’t maximise biodiversity opportunities • CCC requirements from other disciplines (e.g. requirement for underpasses / works to the local roads) will need to be incorporated into the ecological assessment • The borrow pit remediation should be reconsidered to improve biodiversity • Further consideration of the impact on Hen Brook and Wintringham Brook is required in terms of biodiversity and water quality. • Some of the assessments of ecological impact do not present robust evidence to justify the predicted impact. Landscape • HE’s commitment to timing of planting, and maintenance regime needs to be clarified • Changes to some planting mixes and species may be necessary. • Some areas (St Neots, Caxton-Toseland) are likely to need more landscape mitigation proposals. • Limited connections are provided between some habitats (specifically near Hen Brook) and should be improved • Hedgerows are not considered in the application and this is potentially a significant issue • The borrow pit remediation should be reconsidered from a landscape perspective • An agricultural mitigation strategy should be provided to clarify the removal and reinstatement of agricultural grade land Noise • Commitment to hours of operation of works, and monitoring during construction and operation is required • Commitment to officer input and control during construction is required • Cambourne West receptors have not been assessed • Commitment to detailed local management plans required for specific areas is required • Insufficient reasons have been given for the decision to discount mitigation at the eastern end of the scheme. Further explanation must be given and discussed with the Councils. Commitment is required for works not to start until certain conditions are met (i.e. affected properties insulated or residents relocated) Air Quality • The Summary report has been reviewed and currently it is not expected to be a significant issue, unless there are changes to the Transport Assessment • Commitment to officer input and control during construction required Contaminated Land • Summary report reviewed, unlikely to be a material issue but commitment and further detail on approach to backfilling borrow pits required Cultural Heritage • Requirement for the joint authorities’ archaeology brief to be fully integrated into the application • Officers require agreement and approval of areas of the excavation strategy affected by an over-simplification of evaluation evidence • Commitment that temporary works will not affect archaeological excavation areas • Changes needed on applicant’s objectives and methods for archaeological investigation and post excavation assessment • Inconsistency of approach within the proposed scheme at specific areas e.g. land adjacent to Wintringham Scheduled Ancient Monument needs adjustment for clarification • Consideration within the application of archaeology at affected watercourses required, key areas likely to be Hen Brook and Wintringham Brook • Changes to the DCO application needed , to include mapping the archaeological investigation and protection areas on the General Arrangement drawings • Engagement with CCC Museums Liaison Officer required for the Public Archaeology and Community Engagement Strategy • Commitment to skills development and training in the area of cultural heritage Minerals and Waste • Insufficient detail exists on the borrow pits to meaningfully assess the proposals and impacts that will arise from them, including cumulative impacts and implications for wider specialisms such as cultural heritage. • Clarity required on the restoration and biodiversity net gain benefits from the borrow pits • Borrow pits have not been considered in cumulative assessment which is a potentially significant concern. • The works and associated haul routes etc. need to be controlled properly from the outset. Changes to drafting and Requirements needed Flooding and Drainage • Lead Local Flooding Authorities (LLFA) are responding jointly to the application, noting that the Environment Agency’s concerns are largely addressed • Protective Provisions for CCC as Lead Local Flood Authority are required • The dis-application of s23 of the Land Drainage Act 1991 has not been agreed • CCC noted as maintaining ponds and outfalls although this hasn’t been discussed and isn’t agreed • Preference for the design to include reed planting instead of treatment plants • Design for watercourses and ponds needs early engagement as soon as possible • There is a need to discuss and agree how much work will be using LLFA consenting routes • Further consideration of the impact on Hen Brook and Wintringham Brook is required in terms of biodiversity and water quality • Further evidence is needed to demonstrate there are no downstream flooding issues at Wintringham Brook • Flood modelling impact on neighbouring communities needs to be updated and reviewed if changes are made to the scheme Climate Change • The authorities have concerns about the carbon and climate change impact of the project • Impact of induced traffic potentially significant • Clarity needed on conflicts within the documents (i.e. are EV in assessment) • Impacts on neighbouring communities were raised in scoping but are not covered in the application • 6th Carbon Budget and its assessment within the DCO application requires clarification and discussion • The cumulative impact and relationship of the project with EastWestRail / other projects require clarification and discussion NMU and Rights of Way • Significant detailed design, routing, and procedural issues to discuss and resolve • There is currently insufficient support for NMUs. The applicant needs to set out further consideration of the relevant policy requirements regarding supporting NMUsincluding Government Guidelines, the Cambridgeshire and Peterborough Local Transport Plan and Local Plan policies, which require new development to contribute to an enhanced transport network that supports an increasing proportion of journeys being undertaken by sustainable travel modes and seeks an proposal affecting a PROW or other formal NMU route to protect and enhance it. • Changes to DCO proposals are required • Some NMU provision is proposed to be downgraded, this hasn’t been agreed • Comments in work packages have not been addressed • Generally, connectivity to local communities is poor • There are unnecessary gaps in continuous route provision Traffic Modelling • Some routing in the base and forecast year models isn’t realistic, insufficient information has been supplied to the transport authority to enable it to be checked • Strategic model flows have been used to build the local junction models but these flows haven’t been validated for this purpose • Impacts of the scheme on particular areas of the local road network are of concern and need to be understood in more detail (specifically St Neots, Girton Interchange, Coton, others) • Construction traffic flows need to be understood in more detail to assess impacts on local communities and the highway asset Cycling • LTN 1/20 compliance required for any asset to be maintained by, or handed over to CCC. A compliant route is required between Cambourne and St Neots • Provision for users seems to be sub-standard with a lack of segregation and gaps in provision (for example at Eltisley) • Crossings are not acceptable, specifically at A1198 where a grade separated crossing would meet LTN 1/20 guidance and an underpass for cyclists and pedestrians could also be used as a bat crossing. • Eltisley Link North roundabout needs to facilitate cyclists who wish to continue north up the B1040 with a suitable transition from off to on road and be designed to slow traffic speeds. • Lack of crossing facility on the old A428 between Abbotsley Rd and the proposed footway/cycle track on Toseland Rd • The proposed footway/cycle track on the proposed bridge on Toseland Rd needs to allow for cyclists continuing north with a suitable transition from off to on road • Lack of safe crossing facilities at New Cambridge Rd junction where the proposed footway/cycle track crosses the slip roads. The proposed bridge on the B1046 should have provision for cyclists and pedestrians to facilitate a future segregated route between the villages and St. Neots. • Some provision for cyclists (Toseland Road) has been removed from the application Highway Design • An enforceable commitment from the applicant to Vision Zero is required • Approval In Principle for highway design including Standards not yet agreed • The submitted plans do not take account of the County Council’s requirements regarding Local Road Highway Design Principles. As such the proposals include unnecessary Departures of Standard for carriageway widths/cross sections. The principles to be applied in the design and construction of the Scheme’s local roads within Cambridgeshire are as follows: o Consistent application of MCDHW standards and specifications o Full compliance with standards wherever possible, but departures from standard are not justified for carriageway width/cross section o The methods of highway drainage should be considered at the preliminary design stage o Holistic design approach is required to avoid unnecessary maintenance risk/cost to the County Council • A lighting strategy is not in place and will be required to secure acceptable lighting design for both the new assets and those on the sections to be detrunked. • Commitment to the principle that no street lighting assets should be older than 2 years old at the point of handover whether on new or detrunked sections is required. • Detrunking and Assets requires extensive discussion • Boundaries need to be defined, including the land to be handed over. In principle, CCC will not accept land that is not required for highways purposes. • Changes to DCO drafting required to ensure appropriate protective provisions in relation to asset handover of local road network, NMU routes, and RoW • Detrunking process as set out is unacceptable and requires changes to the drafting of the DCO to follow a process agreed with the Highway Authority. De-trunked roads should not be handed over to the Highway Authority until they are at a reasonable standard agreed with the Highway Authority. • In particular the DCO should require either Protective Provisions with regard to Highway matters, or entry into an agreement as to handover of new and de-trunked roads. The agreed Handover Plan and Legal Agreement to be required under the DCO • Numbering of detrunked roads needs to be included within the application Highway Network Impact • Impact on network from construction traffic and re-routing needs to be understood and how any adverse impacts will be mitigated • Proposals in the DCO relating to Traffic Manager responsibilities are unacceptable and will require redrafting to allow for an agreed process • Permitted construction network routes need to be revised and the restrictions clarified • Effective ways of measuring and managing temporary traffic diversions need to be secured • More information required on the construction programme and timings for closures Digital Connectivity • The Councils request that the opportunity is taken as part of this major investment to install a fibre backbone along the route to enable connectivity along the corridor Other Matters • There has been no discussion to date of Development Consent Obligations • There is no provision or discussion of a legal agreement or Protective Provisions covering Highway matters although this has been requested • There has been no discussion to date of the detail of drafting in the DCO • There has been limited discussion to date of matters for the Statement of Common Ground • Finally agreement in principle is required in the following areas, followed by agreement and execution of a detailed legal agreement as part of the DCO as referred to above and specifically covering: o Commuted sums o Remedial maintenance of local highway assets impacted by the project o Adoption of assets o Funding to cover resource costs in the development of the scheme and ongoing matters via a Planning Performance Agreement or other mechanism o Commitment to minimise cost pressure on the Cambridgeshire Local Authorities"
Local Authorities
Central Bedfordshire Council
"Central Bedfordshire Council is responding to this application for a Development Consent Order. As the Council it has a wide range of functions and responsibilities including its role as local planning authority, this representation and its participation in this application process reflects and draws on the breadth of its relevant functions and responsibilities. Only a small section of the route is located directly within the Central Bedfordshire Local Authority Area, with a short section of the new proposed dual carriageway to the south of Little Barford, passing under Barford Road. Notwithstanding this, Advice Note 2 (S18) encourages local authorities to register to take part in the process. On behalf of Central Bedfordshire District Council my representations are likely to be limited to the effects the proposal may have on this local authority area rather than the broader issues of the proposal. The issues that are likely to be relevant to Central Bedfordshire include - The implications within Central Bedfordshire for the highway network to the south of the scheme, in particular the A1. - A need for the preparation and agreement of appropriate traffic management and improvement schemes and / or the identification of alternate routes for larger vehicles or abnormal loads, prior to the construction works in question commencing. In particular, (although not limited to), the proposed use of Station Road, Tempsford for construction traffic. - The implications with Central Bedfordshire of diversionary routes during road closures considered necessary to facilitate the construction works. - The impact of the development on a known archaeology landscape. Specifically the need to design a robust and consistent mitigation strategy whether carried out as Advanced Works/Enabling Works or Main Works - Noise impacts for the construction or operational use of the development - Air quality impact on the Sandy AQMA, caused by increased traffic on the A1 south from this proposal. The Council wishes to participate in the Examination as and when it would aid the Planning Inspectorate in determining the proposal and will send either detailed written representation or relevant officers to the Examination discussions."
Members of the Public/Businesses
David Morton
"Dear Sirs, My representation is that I oppose this scheme, primarily because of the increase in greenhouse gases that would entail not only due to its construction, but the inevitable increase in road traffic. The climate and ecological emergency is upon us. Other considerations are the effect on local wildlife, air quality and the lack of provision for active travel which should be promoted instead. It may also have an impact on the availability of agricultural land that is going to be required in future years. Thank you for your consideration."
Members of the Public/Businesses
Dr Larch Maxey
"Will include a number of points all pertaining to A428 Black Cat to Caxton Gibbet Road Improvement scheme Planning Inspectorate Reference: TR010044: Firstly, that the proposed development would contribute significant Carbon emissions (these have been estimated at 3 Million Tons of CO2 from vehicle emissions alone. Additional CO2e emissions from soil disturbance and other sources need consideration which I will address in my detailed written representation. These CO2 and CO2e emissions need consideration against a range of relevant national policies including the UK's target for zero Cargon by 2050. Secondly, there is also a risk of significant biodiversity impacts from the proposed development and these impacts must be considered against relevant national policies and local biodiversity priorities. Thirdly, the proposed development would add significant air pollution risks to those living near to the proposed development. There are a growing number of relevant policies which seek to address this, given the growing data on deaths from air pollution which, in the UK are approximately 40 000 premature deaths/year and the UK has recently had a landmark case linking air pollution with the death of a child."
Members of the Public/Businesses
Savills UK Limited on behalf of Duncan Buchanan
"In response to Highways England’s proposals, we are instructed to give notice of our client’s objection to the Scheme and to make the following representations: (i) There has been no meaningful engagement between Highways England and our Client to discuss the Order and the potential acquisition of our Client's Land, despite repeated requests. No offer has been made that has enabled appropriate discussions that could have enabled early acquisition by agreement before resorting to making the Order, which goes against the guidance set out in MHCLG’s Guidance on the Compulsory Purchase Process and the Crichel Down Rules. (ii) Insufficient information or explanation has been provided to our Client to enable proper understanding of why the inclusion of the Property is required for the Scheme. In particular the changes in the design of the Scheme between the 2019 and 2020 consultation that included additional land for the creation of the flood storage area. (iii) From the limited information provided to date there is no supporting evidence to demonstrate the benefits of using our Client’s land, as opposed to using alternative sites or as to whether any alternative methods could have been considered to reduce the impact on our Client’s land."
Members of the Public/Businesses
Howard James Rees
"With forecast carbon emissions of over three million tonnes, this scheme is not consistent with the UK's commitments under the Paris Agreement. It also falls foul of many areas of Government commitments, policy and legislation regarding limits on greenhouse gas emissions and the protection of biodiversity."
Local Authorities
Huntingdonshire District Council
"A428 Relevant Representations Cambridgeshire County Council (CCC), Huntingdonshire District Council (HDC) and South Cambridgeshire District Council (SCDC) are reviewing the A428 Black Cat to Caxton Gibbet Development Consent Order Application (the Application) and believe that discussion, further information, and changes to the Application will be required in the areas set out below. This is based on the current understanding of the information and may be altered, added to or amended as the review continues and discussion with Highways England begins. These are the combined representations of CCC, HDC and SCDC. Note: CCC is submitting this response in advance of a Committee resolution but will be considering at the next Highways and Transport Committee. Biodiversity • There are concerns about the robustness of the baseline survey data. The Councils are seeking firm commitment to biodiversity net gain from an agreed baseline and measured using established methodology. • The assessment of net gain and the total has not used standard methodology • Changes to the proposed species mix and habitats in some areas may be required. • Mitigation for impact to other habitats such as arable field margins needs to be discussed and agreed • The Environmental Masterplan needs to be updated. It is currently incomplete, doesn’t reflect general works arrangement and doesn’t maximise biodiversity opportunities • CCC requirements from other disciplines (e.g. requirement for underpasses / works to the local roads) will need to be incorporated into the ecological assessment • The borrow pit remediation should be reconsidered to improve biodiversity • Further consideration of the impact on Hen Brook and Wintringham Brook is required in terms of biodiversity and water quality. • Some of the assessments of ecological impact do not present robust evidence to justify the predicted impact. Landscape • HE’s commitment to timing of planting, and maintenance regime needs to be clarified • Changes to some planting mixes and species may be necessary. • Some areas (St Neots, Caxton-Toseland) are likely to need more landscape mitigation proposals. • Limited connections are provided between some habitats (specifically near Hen Brook) and should be improved • Hedgerows are not considered in the application and this is potentially a significant issue • The borrow pit remediation should be reconsidered from a landscape perspective • An agricultural mitigation strategy should be provided to clarify the removal and reinstatement of agricultural grade land Noise • Commitment to hours of operation of works, and monitoring during construction and operation is required • Commitment to officer input and control during construction is required • Cambourne West receptors have not been assessed • Commitment to detailed local management plans required for specific areas is required • Insufficient reasons have been given for the decision to discount mitigation at the eastern end of the scheme. Further explanation must be given and discussed with the Councils. Commitment is required for works not to start until certain conditions are met (i.e. affected properties insulated or residents relocated) Air Quality • The Summary report has been reviewed and currently it is not expected to be a significant issue, unless there are changes to the Transport Assessment • Commitment to officer input and control during construction required Contaminated Land • Summary report reviewed, unlikely to be a material issue but commitment and further detail on approach to backfilling borrow pits required Cultural Heritage • Requirement for the joint authorities’ archaeology brief to be fully integrated into the application • Officers require agreement and approval of areas of the excavation strategy affected by an over-simplification of evaluation evidence • Commitment that temporary works will not affect archaeological excavation areas • Changes needed on applicant’s objectives and methods for archaeological investigation and post excavation assessment • Inconsistency of approach within the proposed scheme at specific areas e.g. land adjacent to Wintringham Scheduled Ancient Monument needs adjustment for clarification • Consideration within the application of archaeology at affected watercourses required, key areas likely to be Hen Brook and Wintringham Brook • Changes to the DCO application needed , to include mapping the archaeological investigation and protection areas on the General Arrangement drawings • Engagement with CCC Museums Liaison Officer required for the Public Archaeology and Community Engagement Strategy • Commitment to skills development and training in the area of cultural heritage Minerals and Waste • Insufficient detail exists on the borrow pits to meaningfully assess the proposals and impacts that will arise from them, including cumulative impacts and implications for wider specialisms such as cultural heritage. • Clarity required on the restoration and biodiversity net gain benefits from the borrow pits • Borrow pits have not been considered in cumulative assessment which is a potentially significant concern. • The works and associated haul routes etc. need to be controlled properly from the outset. Changes to drafting and Requirements needed Flooding and Drainage • Lead Local Flooding Authorities (LLFA) are responding jointly to the application, noting that the Environment Agency’s concerns are largely addressed • Protective Provisions for CCC as Lead Local Flood Authority are required • The dis-application of s23 of the Land Drainage Act 1991 has not been agreed • CCC noted as maintaining ponds and outfalls although this hasn’t been discussed and isn’t agreed • Preference for the design to include reed planting instead of treatment plants • Design for watercourses and ponds needs early engagement as soon as possible • There is a need to discuss and agree how much work will be using LLFA consenting routes • Further consideration of the impact on Hen Brook and Wintringham Brook is required in terms of biodiversity and water quality • Further evidence is needed to demonstrate there are no downstream flooding issues at Wintringham Brook • Flood modelling impact on neighbouring communities needs to be updated and reviewed if changes are made to the scheme Climate Change • The authorities have concerns about the carbon and climate change impact of the project • Impact of induced traffic potentially significant • Clarity needed on conflicts within the documents (i.e. are EV in assessment) • Impacts on neighbouring communities were raised in scoping but are not covered in the application • 6th Carbon Budget and its assessment within the DCO application requires clarification and discussion • The cumulative impact and relationship of the project with EastWestRail / other projects require clarification and discussion NMU and Rights of Way • Significant detailed design, routing, and procedural issues to discuss and resolve • There is currently insufficient support for NMUs. The applicant needs to set out further consideration of the relevant policy requirements regarding supporting NMUs including Government Guidelines, the Cambridgeshire and Peterborough Local Transport Plan and Local Plan policies, which require new development to contribute to an enhanced transport network that supports an increasing proportion of journeys being undertaken by sustainable travel modes and seeks an proposal affecting a PROW or other formal NMU route to protect and enhance it. • Changes to DCO proposals are required • Some NMU provision is proposed to be downgraded, this hasn’t been agreed • Comments in work packages have not been addressed • Generally, connectivity to local communities is poor • There are unnecessary gaps in continuous route provision Traffic Modelling • Some routing in the base and forecast year models isn’t realistic, insufficient information has been supplied to the transport authority to enable it to be checked • Strategic model flows have been used to build the local junction models but these flows haven’t been validated for this purpose • Impacts of the scheme on particular areas of the local road network are of concern and need to be understood in more detail (specifically St Neots, Girton Interchange, Coton, others) • Construction traffic flows need to be understood in more detail to assess impacts on local communities and the highway asset Cycling • LTN 1/20 compliance required for any asset to be maintained by, or handed over to CCC. A compliant route is required between Cambourne and St Neots • Provision for users seems to be sub-standard with a lack of segregation and gaps in provision (for example at Eltisley) • Crossings are not acceptable, specifically at A1198 where a grade separated crossing would meet LTN 1/20 guidance and an underpass for cyclists and pedestrians could also be used as a bat crossing. • Eltisley Link North roundabout needs to facilitate cyclists who wish to continue north up the B1040 with a suitable transition from off to on road and be designed to slow traffic speeds. • Lack of crossing facility on the old A428 between Abbotsley Rd and the proposed footway/cycle track on Toseland Rd • The proposed footway/cycle track on the proposed bridge on Toseland Rd needs to allow for cyclists continuing north with a suitable transition from off to on road • Lack of safe crossing facilities at New Cambridge Rd junction where the proposed footway/cycle track crosses the slip roads. The proposed bridge on the B1046 should have provision for cyclists and pedestrians to facilitate a future segregated route between the villages and St. Neots. • Some provision for cyclists (Toseland Road) has been removed from the application Highway Design • An enforceable commitment from the applicant to Vision Zero is required • Approval In Principle for highway design including Standards not yet agreed • The submitted plans do not take account of the County Council’s requirements regarding Local Road Highway Design Principles. As such the proposals include unnecessary Departures of Standard for carriageway widths/cross sections. The principles to be applied in the design and construction of the Scheme’s local roads within Cambridgeshire are as follows: o Consistent application of MCDHW standards and specifications o Full compliance with standards wherever possible, but departures from standard are not justified for carriageway width/cross section o The methods of highway drainage should be considered at the preliminary design stage o Holistic design approach is required to avoid unnecessary maintenance risk/cost to the County Council • A lighting strategy is not in place and will be required to secure acceptable lighting design for both the new assets and those on the sections to be detrunked. • Commitment to the principle that no street lighting assets should be older than 2 years old at the point of handover whether on new or detrunked sections is required. • Detrunking and Assets requires extensive discussion • Boundaries need to be defined, including the land to be handed over. In principle, CCC will not accept land that is not required for highways purposes. • Changes to DCO drafting required to ensure appropriate protective provisions in relation to asset handover of local road network, NMU routes, and RoW • Detrunking process as set out is unacceptable and requires changes to the drafting of the DCO to follow a process agreed with the Highway Authority. De-trunked roads should not be handed over to the Highway Authority until they are at a reasonable standard agreed with the Highway Authority. • In particular the DCO should require either Protective Provisions with regard to Highway matters, or entry into an agreement as to handover of new and de-trunked roads. The agreed Handover Plan and Legal Agreement to be required under the DCO • Numbering of detrunked roads needs to be included within the application Highway Network Impact • Impact on network from construction traffic and re-routing needs to be understood and how any adverse impacts will be mitigated • Proposals in the DCO relating to Traffic Manager responsibilities are unacceptable and will require redrafting to allow for an agreed process • Permitted construction network routes need to be revised and the restrictions clarified • Effective ways of measuring and managing temporary traffic diversions need to be secured • More information required on the construction programme and timings for closures Digital Connectivity • The Councils request that the opportunity is taken as part of this major investment to install a fibre backbone along the route to enable connectivity along the corridor Other Matters • There has been no discussion to date of Development Consent Obligations • There is no provision or discussion of a legal agreement or Protective Provisions covering Highway matters although this has been requested • There has been no discussion to date of the detail of drafting in the DCO • There has been limited discussion to date of matters for the Statement of Common Ground • Finally agreement in principle is required in the following areas, followed by agreement and execution of a detailed legal agreement as part of the DCO as referred to above and specifically covering: o Commuted sums o Remedial maintenance of local highway assets impacted by the project o Adoption of assets o Funding to cover resource costs in the development of the scheme and ongoing matters via a Planning Performance Agreement or other mechanism o Commitment to minimise cost pressure on the Cambridgeshire Local Authorities"
Members of the Public/Businesses
Bletsoes on behalf of John Lammie
"We represent the interests of John Lammie in his capacity as tenant under an Agricultural Holdings Act 1986 tenancy and partner of the farming partnership, J & J W Lammie. Mr Lammie occupies various parcels of land affected by the Scheme, some of which lie within the Order Limits for permanent and temporary land acquisition. We are instructed to make outline representations on behalf of our client. Representations are made without prejudice to making further objections/representations at a later stage for different reasons, or to amplify these representations. We have reviewed the plans included within the Developer’s application insofar as they relate to our client and these representations are based upon the information contained therein. The aforementioned plans do not provide sufficient detail in order to ascertain the full impact on my client’s leasehold interest. We would therefore like to formally record our principal concerns, based upon the information that is available. We do not wish to be put in a position whereby when it comes to the ‘detailed design stage’ we are told that design issues raised should have been dealt with earlier on in the scheme and it is too late. The Developer cannot say that they will deal with matters in dispute at a later stage. These issues should either be dealt with during the application process or determined by the Planning Inspectorate. We submitted representations to the supplementary consultation held in July 2020. To date, we have not received a formal response from the Developer. Our client wishes to make clear his principal concerns: Provision of Accesses: At present, the affected land benefits from numerous access points along the Barford Road. My client is prepared to stop-up some of those access points in return for the provision of 6 purpose-built accesses (3 on either side of the Barford Road) in order to make the Barford Road safer and generally mitigate the detrimentally effect of the Scheme on my client’s leasehold interest. From the information available, it appears that provision for 4 purpose-built accesses will be provided; two either side of the Barford Road. In addition to those already provided, our client requires additional accesses located opposite each other to provide access into field parcels Parcel ID: TL1654 4959 & TL1654 6725. We are liaising directly with the Developer concerning the provision of accesses but wish to reserve our position within this representation. Design of Accesses: During previous consultation with the Developer, we requested detailed design information concerning the proposed accesses to assess whether the new accesses are as equally commodious as the existing accesses. To date, this information has not been forthcoming. Consequently, we still have concerns regarding the design of the accesses, principally relating to widths and gradient. We require confirmation that the accesses will be at a similar level to the finished road surface to avoid steep gradients that are dangerous for slow moving agricultural traffic entering and exiting the field parcels; and require confirmation the accesses will be of a sufficient width to allow safe access for agricultural traffic with restricted maneuverability. For the avoidance of doubt, we wish to make clear that the new accesses should be at least 30ft wide and gated to provide secure commodious access. Safety: During previous consultation with the Developer, we raised concerns concerning the safety of the Barford Road after alterations have been made because of the Scheme. In summary, the principal concern relates to the proposed alterations to straighten the alignment of Barford Rad and flatten its contours, which we believe will allow motorists to travel faster thus increasing the risk of accidents, especially between road users and slow-moving agricultural equipment entering and exiting fields. We requested a reduction in the speed limit from 60mph, perhaps to 40 or 50 mph, and traffic calming measures, such as on-road markings and road signs highlighting the presence of agriculture traffic. Based on the information available, we note that our request for a reduced speed limit has not been implemented. Furthermore, there is no information available concerning traffic calming measures. Parking Provision: During previous consultation, we highlighted the potential need for off road parking for a local angling club, who enjoy short term rights to fish the River Great Ouse. Whilst this request has been acknowledged by the Developer, the information available does not make provision for such access. At present, the anglers park on the side of the Barford Road and walk to the river; this has little impact on my client’s use of the land. If access and parking is provided for this purpose, we request that any such provision is accommodated on land that is already identified as being permanently required to reduce the impact on client. Accommodation Works: We have on numerous occasions reiterated the need for accommodation works. We require further details on the proposed accommodation works to ascertain the full impact on my client’s leasehold interest. As a minimum, our client requires commodious access, post scheme land drainage, and fencing and hedge of boundaries to mitigate the detrimental effect of this scheme."
Members of the Public/Businesses
Lucie Thring
"Will include a number of points all pertaining to A428 Black Cat to Caxton Gibbet Road Improvement scheme Planning Inspectorate Reference: TR010044: Firstly, that the proposed development would contribute significant Carbon emissions (these have been estimated at 3 Million Tons of CO2 from vehicle emissions alone. Additional CO2e emissions from soil disturbance and other sources need consideration which I will address in my detailed written representation. These CO2 and CO2e emissions need consideration against a range of relevant national policies including the UK's target for zero Cargon by 2050. Secondly, there is also a risk of significant biodiversity impacts from the proposed development and these impacts must be considered against relevant national policies and local biodiversity priorities. Thirdly, the proposed development would add significant air pollution risks to those living near to the proposed development. There are a growing number of relevant policies which seek to address this, given the growing data on deaths from air pollution which, in the UK are approximately 40 000 premature deaths/year and the UK has recently had a landmark case linking air pollution with the death of a child."
Members of the Public/Businesses
Rapleys on behalf of Mactaggart and Mickel
"Mactaggart and Mickel (M&M) controls circa 55ha of land to the east of [] South, located to the south of Papworth Everard and to the north of the proposed Caxton Gibbett junction improvements. M&M is promoting the land for residential/ mixed-use development via the emerging Greater Cambridge Local Plan. The proposed Caxton Gibbett junction improvements are located less than 300m from the boundary of land controlled by M&M. In principle, M&M supports the implementation of an appropriate A428 Black Cat to Caxton Gibbet Road Improvement Scheme. However, M&M has the following comments to make via representations: • Further clarification is needed in relation to the design of the proposed shared use path connecting Papworth Everard to Cambourne West across the A428, notably the interaction between pedestrians, cyclists and vehicles at the proposed slip roads. These active travel routes will be crucial to ensure that residents living to the north of the A428 are not segregated from the amenities and services available within Cambourne • The application does not consider future growth scenarios associated with the emerging Greater Cambridge Local Plan (GCLP), which has a plan period of 2017 to 2040. The design of the junction should be future proofed to ensure that sufficient capacity exists to accommodate potential strategic growth options on the A428 corridor, which are being analysed through the preparation of the GCLP. • The assessment of the Cambourne junction to the east is not consistent with the assessment undertaken for the Caxton Gibbett junction. The latter has been subject to a strategic microsimulation model while the former has been subject to traditional capacity assessment. No explanation has been provided. • The application does not have regard to the emerging E-W rail proposals and potential new railway station at Cambourne. While the E-W scheme is at an early stage of development, the co-ordination of comprehensive strategic transport package in the locality is essential to safeguard strategic growth objectives associated with the Oxford-Cambridge Arc, the CPCA Strategic Economic Plan, and the Greater Cambridge Local Plan. • As part of the application consideration should be given to the opportunity to deliver strategic development to the north of the A428 and the south of Papworth Everard. Land proposed to be used for ‘borrow pits’ should be appropriately remediated to avoid sterilisation of the land for development."
Non-Statutory Organisations
National Farmers Union NFU
"NFU OUTLINE REPRESENTATIONS ______________________________ 1. Introduction 1.1 These are the Outline Written Representations of the National Farmers Union (“NFU”) on behalf of their members to the application for a Development Consent Order by Highways England for the identified scheme A428 Black Cat to Caxton Gibbet Improvements. 1.2 The objectives of the NFU are to champion farming in England and Wales and to provide professional representation and service to its members. 1.3 The matters raised in these Written Representations are matters not only of concern to the farming owners of agricultural land affected by this DCO, but also of concern to, and raise points of principle that will affect, members of the NFU having farm holdings that may be affected by similar infrastructure schemes. 2. Consultation and Engagement 2.1 One to one meetings have been held between landowners and Ardent the agents acting for Highways England (HE) and the NFU would like to see negotiations continuing with members who are directly affected. The NFU understands from agents that HE is not keeping landowners updated and it is taking HE too long to respond to queries raised by agents. Further the NFU would like to enter into a Statement of Common Ground to understand and agree outstanding issues, especially the wording that is being sought on practical issues and the NFU would like to see being included in the First Iteration Environmental Management Plan (FIEMP). 3. Habitat Mitigation 3.1. Further to the response submitted to the consultation the NFU would still like to receive clarification as to why so much land is being taken for habitat mitigation and it is understood that (HE) have now identified a 20.5 % net gain. We understand that this might be being achieved through the enhancement of previous identified sites. Further clarification is required as the NFU would not want to see more land being compulsorily purchased to achieve a net gain on a linear infrastructure scheme. The NFU would like confirmation on what management agreements are to be put in place to maintain the habitat mitigation sites. 4. Access Routes and Accommodation Works 4.1. The NFU raised concerns over (HE) addressing new access routes that will be required once the new road is operational to land and also temporary access routes during construction which will be severed by the works. Further concerns where in regard to agreeing accommodation works at an early stage. The response provided by HE in the response consultation document is brief with no detail. The NFU understand from agents acting for members that meetings have been taking place, but further confirmation is required. 5. Construction Compound Sites 5.1 HE on plans submitted under the DCO has identified some large areas of land to be taken for construction compound sites. The NFU would like to see the detail of use for each compound site being detailed in the DCO particularly within Schedule 7, Article 40. At the present time it is stated that the areas will be used as a construction area ‘required to provide temporary storage, laydown areas, access and working space to facilitate the construction of…’ We require further detail on exactly what works may take place and what type of storage. This should be explicitly detailed for each compound. 6. Powers to Survey Land 6.1 It is noted that in the DCO under Paragraph 23: Authority to survey and investigate the land under 23.1 (b) ii it is stated that HE can discharge water from sampling operations. The NFU would like further detail on the types of sampling that is to be undertaken and the quantities water that could be discharged. The NFU is pleased to see that 23.3. does state that the nature of the survey must be stated in the notice. The NFU would further like to see that the ALO as part of its role is to: “Provide preconstruction survey information to landowners including company name, survey type and equipment to be used, an estimate of how long the surveys are expected to take and where surveys are to take place on land outside of the Order limits, an explanation of why such land is required”. 7. Temporary use of land for carrying out the authorised development 7.1 It is noted that in the DCO at Paragraph 40 ‘Temporary use of land for carrying out the authorised development’ it is stated that a 14 day notice has to be served before taking entry. At a minimum the NFU will want to see a 28 day notice being served before entry is taken on to land on a temporary basis. Experience form other schemes is showing that a 14 day notice is not adequate. 8. Balance Ponds 8.1 The NFU would like information to be provided to explain why the size and location of balance ponds are required and where these are to be located. Further relocation next to field boundaries would help minimise the impact on the farmland in question. The NFU would like to see further negotiations with landowners on balance ponds and refinement as design is developed. 9.0 Waste and Spoil 9.1 The NFU would like information to be provided to explain how waste and spoil is to be treated. The response to the NFU after the first consultation does not clarify where waste and spoil is to be used within the construction. It just states that soils will be delivered back to the respective locations from the storage zones. It will not be possible to return soil back to respective soil locations without changing the surface level and agricultural classification 10. Private Water Supply 10.1 There is no information in the FIEMP as to how private water supplies will be treated if affected on a temporary or permanent basis. The main works contractors should have to provide an alternative supply if a private supply is contaminated, cut off or the supply is affected in anyway during the construction of the road. The NFU has specific wording that it would like to see agreed and included in the FIEMP to guarantee that farms will have a temporary and/or a permanent water supply. 11.0 Field Drainage 11.1 Land drainage is always one of the main issues which landowners and agricultural tenants are concerned about when land is taken for construction purposes of a major road. Further to raising issues in a response to the consultations in regard to field drainage HE responded that the Drainage Strategy report covers operational drainage and that the FIEMP describes how construction drainage will be dealt with. The NFU is disappointed that HE has not addressed agricultural field drainage that will be severely affected by the construction works. This is particularly important where land will be returned to agricultural use. 11.2 The NFU has specific wording that it would like to see agreed and included in the FIEMP to guarantee that land drainage will be fully reinstated. 12. Soils 12.1. The NFU is pleased to see that there is a detailed section on Soil Handling and Management at Appendix E of the FIEMP which covers soil preparation, sub and top soil stripping, controls during construction, soil storage and restoration. The NFU would like to see further detail included to cover a pre-construction soil survey which will form the basis of a soil statement to be included within a record of condition. 12.2. Further the NFU would like to see wording agreed to cover soil aftercare which will be linked back to the soil statement and condition of the soil before the construction works started. 13. Dust 13.1 It is noted that within the FIEMP that dust will be controlled during construction, but clarification is needed on how dust will be controlled during construction to protect arable crops. The project will impact a vast area of arable crops that are grown in this area, quality of the crop is paramount. NFU would like to see details specific to dust control for agricultural crops. 14. Irrigation Systems 14.1. The NFU has not been able to find any information in the FIEMP as to how the effect of construction can be minimised on irrigation systems. The NFU has specific wording that it would like to see agreed and included in the FIEMP to guarantee that irrigation systems are maintained. 15. Agricultural Liaison officer 15.1 Liaison with landowners, tenants and agents is essential but there is only mention of a Community Relations Manager within the FIEMP. This is not adequate and the NFU would like to see that the main works contractors will have to employ an agricultural liaison officer to carry out liaison with landowners. The NFU has specific wording that it would like to see agreed and included in the FIEMP which covers the roles which need to be undertaken by the ALO. 16. Agricultural Use of the A428 16.1 The NFU requested confirmation that the proposed A428 will remain for the use of all traffic including agricultural vehicles. HE has confirmed that the new dual carriageway will be designated an all-purpose trunk road. The NFU would like to see this stated in the DCO. 17.0 Request to Attend Hearings and make Representations 17.1 The NFU wishes to request to make oral representations at the issue specific, draft DCO and compulsory acquisition hearings which may be held if necessary. The NFU will be working closely with the agents that represent the NFU members affected. Louise Staples Senior Rural Surveyor"
Members of the Public/Businesses
Peter Scott
"A428 Black Cat to Caxton Gibbet Road Improvement scheme Planning Inspectorate Reference: TR010044 My representation is as follows and contains the following points: Firstly, that the proposed development would contribute significant Carbon emissions (these have been estimated at 3 Million Tons of CO2 from vehicle emissions alone. Additional CO2e emissions from soil disturbance and other sources need consideration. These CO2 and CO2e emissions need consideration against a range of relevant national policies including the UK's target for Net Zero Carbon Emissions by 2050. This development is entirely inconsistent with such legislation. Secondly, there is also a risk of significant biodiversity impacts from the proposed development and these impacts must be considered against relevant national policies and local biodiversity priorities. Thirdly, the proposed development would add significant air pollution risks to those living near to the proposed development. There are a growing number of relevant policies which seek to address this, given the growing data on deaths from air pollution which, in the UK are approximately 40 000 premature deaths/year and the UK has recently had a landmark case linking air pollution with the death of a child."
Members of the Public/Businesses
Richard Hawker
"I am very concerned that this project is in direct contravention of the government's stated policy aim of encouraging modal shift to public transport, and away from a car-based transport system. The building of this road, which I use on occasion (before lockdown) to visit my relations in Birmingham and Reading seems unnecessary anyway, as it is of an adequate standard for the traffic. I am also concerned that the building and operation of the road will inevitably increase carbon emissions, again in contravention of the government's stated aim of carbon reduction. Alternatives of improving rail (passenger and freight) and bus services could be looked at in greater detail."
Members of the Public/Businesses
Bletsoes on behalf of Richard Infield
"We represent the interests of Richard Infield in his capacity as tenant under an Agricultural Holdings Act 1986 Tenancy and partner of the farming partnership, W A Infield & Sons. Mr Infield occupies land that is directly affected by the Scheme, some of which lie within the proposed Order Limits. On behalf of Mr Infield, we are instructed to make outline representations. Representations are made without prejudice to making further objections/representations for different reasons, or to amplify these representations. We have reviewed the plans included within the Developer’s application insofar as they relate to our clients’ and these representations are based upon the information contained therein. The aforementioned plans do not provide sufficient detail to ascertain the full impact on my client’s requisite interest. We would therefore like to formally record our principal concerns, based upon the information that is available. Our client does not wish to be put in a position whereby when it comes to the ‘detailed design stage’, he is told that design issues raised should have been dealt with earlier on in the Scheme and it is too late. The Developer cannot say that they will deal with matters in dispute at a later stage. These issues should either be dealt with during the application process or determined by the Planning Inspectorate. We submitted representations to the supplementary consultation held in July 2020. To date, we have not received a formal response. Our client wishes to make clear his principle concerns: Post Scheme Access: At present, an isolated parcel of land off the Barford Road benefits from two access points from the Barford Road. During previous consultation with the Developer, we requested detailed design information concerning the proposed accesses to assess whether access will be equally commodious. From the information available, it would appear that the northern-most access will be stopped up; it is not clear how the southern-most access will be affected. In recent discussions with the Developer, our client has had verbal assurance from the Developer and their representatives that the southern-most access will not be affected, and my client has relied upon that assurance. In terms of the northern-most access, we note that new access is being provided to serve land owned by my client’s landlord and occupied by a third party, [Redacted]. It would be pragmatic for this access to be shared providing access to my client and [Redacted] in their capacity as tenants. My client, [Redacted] and the Landlord’s Agent have agreed the principle of a shared access. The Developer has confirmed they are willing to adjusting their proposals to include a shared access, and my client has relied upon that statement. Access during Construction: As well as at Ouse Farm, Tempsford, my client farms land located near to surrounding villages. He relies heavily on the A1, Blackcat Roundabout and connecting local roads; this use is intensified at certain times of year, such as silaging and harvesting. The construction of the Scheme will disrupt the A1, Blackcat Roundabout and connecting local roads. The Developer has confirmed that where possible the Scheme will be constructed ‘offline’ to avoid road closures but accept that closures are inevitable. Our client requires the Developer to avoid road closures where possible in order to help lessen the impact of the Scheme. In addition, our client requires the Developer to communicate any planned road closures well in advance of the closure date to allow alternative arrangements to be made. Safety: During previous consultation, our client raised concerns relating to the safety of the Barford Road after alterations have been made as part of the Scheme. In summary, his principle concern relate to the proposal to straighten the alignment of Barford Rad and flatten its contours, which our client believes will allow motorists to travel faster thus increasing the risk of accidents, especially between road users and slow-moving agricultural equipment entering and exiting fields. Our client has requested a reduction in the speed limit from 60mph, perhaps to 40 or 50 mph, and traffic calming measures, such as on-road markings, road signs highlighting the presence of agriculture traffic, and crash barriers on the bend near to the gas and water works. Based on the information available, we note that our client’s request for a reduced speed limit has not been implemented. Furthermore, there is no information available concerning traffic calming measures. Accommodation Works: Accommodation Works: Our client has on numerous occasions reiterated the need for accommodation works. Our client requires further details concerning the proposed accommodation works to ascertain the full impact on his interest. As a minimum, our client requires commodious access, post scheme land drainage, and fencing & hedging of boundaries to help mitigate the detrimental affect of this Scheme."
Other Statutory Consultees
BNP Paribas Real Estate on behalf of Royal Mail Group
"Royal Mail does not have an in principle objection to this proposed road scheme but is seeking to secure mitigations to protect its road based operations during the construction phase. Under section 35 of the Postal Services Act 2011 (the “Act”), Royal Mail has been designated by Ofcom as a provider of the Universal Postal Service. Royal Mail is the only such provider in the United Kingdom. The Act provides that Ofcom’s primary regulatory duty is to secure the provision of the Universal Postal Service. Ofcom discharges this duty by imposing regulatory conditions on Royal Mail, requiring it to provide the Universal Postal Service. The Act includes a set of minimum standards for Universal Service Providers, which Ofcom must secure. The conditions imposed by Ofcom reflect those standards. Royal Mail is under some of the highest specification performance obligations for quality of service in Europe. Its performance of the Universal Service Provider obligations is in the public interest and should not be affected detrimentally by any statutorily authorised project. Royal Mail’s postal sorting and delivery operations rely heavily on road communications. Royal Mail’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. Royal Mail is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on Royal Mail’s operations, its ability to meet the Universal Service Obligation and comply with the regulatory regime for postal services thereby presenting a significant risk to Royal Mail’s business. Royal Mail has four Delivery Offices within 10 miles of this road scheme at Sandy, St Neots, St Ives and Huntingdon. The scheme has potential to present risk of construction phase impact / delays to Royal Mail’s road based operations on the surrounding road network. Every day, in exercising its statutory duties Royal Mail vehicles use all the main roads that may be impacted by any additional traffic arising / delays during construction of this scheme. Any periods of road disruption / closure, night or day, have the potential to impact operations. Royal Mail does not wish to stop or delay this scheme from being constructed. However, Royal Mail does wish to ensure the protection of its future ability to provide an efficient mail sorting and delivering service. In order to do this, Royal Mail requests that: 1. the DCO includes specific requirements that during the construction phase Royal Mail is consulted by Highways England or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and on the content of the final CTMP, and 2. the final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary as identified above). Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed."
Local Authorities
South Cambridgeshire District Council
"A428 Relevant Representations Cambridgeshire County Council (CCC), Huntingdonshire District Council (HDC) and South Cambridgeshire District Council (SCDC) are reviewing the A428 Black Cat to Caxton Gibbet Development Consent Order Application (the Application) and believe that discussion, further information, and changes to the Application will be required in the areas set out below. This is based on the current understanding of the information and may be altered, added to or amended as the review continues and discussion with Highways England begins. These are the combined representations of CCC, HDC and SCDC. Note: CCC is submitting this response in advance of a Committee resolution but will be considering at the next Highways and Transport Committee. Biodiversity • There are concerns about the robustness of the baseline survey data. The Councils are seeking firm commitment to biodiversity net gain from an agreed baseline and measured using established methodology. • The assessment of net gain and the total has not used standard methodology • Changes to the proposed species mix and habitats in some areas may be required. • Mitigation for impact to other habitats such as arable field margins needs to be discussed and agreed • The Environmental Masterplan needs to be updated. It is currently incomplete, doesn’t reflect general works arrangement and doesn’t maximise biodiversity opportunities • CCC requirements from other disciplines (e.g. requirement for underpasses / works to the local roads) will need to be incorporated into the ecological assessment • The borrow pit remediation should be reconsidered to improve biodiversity • Further consideration of the impact on Hen Brook and Wintringham Brook is required in terms of biodiversity and water quality. • Some of the assessments of ecological impact do not present robust evidence to justify the predicted impact. Landscape • HE’s commitment to timing of planting, and maintenance regime needs to be clarified • Changes to some planting mixes and species may be necessary. • Some areas (St Neots, Caxton-Toseland) are likely to need more landscape mitigation proposals. • Limited connections are provided between some habitats (specifically near Hen Brook) and should be improved • Hedgerows are not considered in the application and this is potentially a significant issue • The borrow pit remediation should be reconsidered from a landscape perspective • An agricultural mitigation strategy should be provided to clarify the removal and reinstatement of agricultural grade land Noise • Commitment to hours of operation of works, and monitoring during construction and operation is required • Commitment to officer input and control during construction is required • Cambourne West receptors have not been assessed • Commitment to detailed local management plans required for specific areas is required • Insufficient reasons have been given for the decision to discount mitigation at the eastern end of the scheme. Further explanation must be given and discussed with the Councils. Commitment is required for works not to start until certain conditions are met (i.e. affected properties insulated or residents relocated) Air Quality • The Summary report has been reviewed and currently it is not expected to be a significant issue, unless there are changes to the Transport Assessment • Commitment to officer input and control during construction required Contaminated Land • Summary report reviewed, unlikely to be a material issue but commitment and further detail on approach to backfilling borrow pits required Cultural Heritage • Requirement for the joint authorities’ archaeology brief to be fully integrated into the application • Officers require agreement and approval of areas of the excavation strategy affected by an over-simplification of evaluation evidence • Commitment that temporary works will not affect archaeological excavation areas • Changes needed on applicant’s objectives and methods for archaeological investigation and post excavation assessment • Inconsistency of approach within the proposed scheme at specific areas e.g. land adjacent to Wintringham Scheduled Ancient Monument needs adjustment for clarification • Consideration within the application of archaeology at affected watercourses required, key areas likely to be Hen Brook and Wintringham Brook • Changes to the DCO application needed , to include mapping the archaeological investigation and protection areas on the General Arrangement drawings • Engagement with CCC Museums Liaison Officer required for the Public Archaeology and Community Engagement Strategy • Commitment to skills development and training in the area of cultural heritage Minerals and Waste • Insufficient detail exists on the borrow pits to meaningfully assess the proposals and impacts that will arise from them, including cumulative impacts and implications for wider specialisms such as cultural heritage. • Clarity required on the restoration and biodiversity net gain benefits from the borrow pits • Borrow pits have not been considered in cumulative assessment which is a potentially significant concern. • The works and associated haul routes etc. need to be controlled properly from the outset. Changes to drafting and Requirements needed Flooding and Drainage • Lead Local Flooding Authorities (LLFA) are responding jointly to the application, noting that the Environment Agency’s concerns are largely addressed • Protective Provisions for CCC as Lead Local Flood Authority are required • The dis-application of s23 of the Land Drainage Act 1991 has not been agreed • CCC noted as maintaining ponds and outfalls although this hasn’t been discussed and isn’t agreed • Preference for the design to include reed planting instead of treatment plants • Design for watercourses and ponds needs early engagement as soon as possible • There is a need to discuss and agree how much work will be using LLFA consenting routes • Further consideration of the impact on Hen Brook and Wintringham Brook is required in terms of biodiversity and water quality • Further evidence is needed to demonstrate there are no downstream flooding issues at Wintringham Brook • Flood modelling impact on neighbouring communities needs to be updated and reviewed if changes are made to the scheme Climate Change • The authorities have concerns about the carbon and climate change impact of the project • Impact of induced traffic potentially significant • Clarity needed on conflicts within the documents (i.e. are EV in assessment) • Impacts on neighbouring communities were raised in scoping but are not covered in the application • 6th Carbon Budget and its assessment within the DCO application requires clarification and discussion • The cumulative impact and relationship of the project with EastWestRail / other projects require clarification and discussion NMU and Rights of Way • Significant detailed design, routing, and procedural issues to discuss and resolve • There is currently insufficient support for NMUs. The applicant needs to set out further consideration of the relevant policy requirements regarding supporting NMUsincluding Government Guidelines, the Cambridgeshire and Peterborough Local Transport Plan and Local Plan policies, which require new development to contribute to an enhanced transport network that supports an increasing proportion of journeys being undertaken by sustainable travel modes and seeks an proposal affecting a PROW or other formal NMU route to protect and enhance it. • Changes to DCO proposals are required • Some NMU provision is proposed to be downgraded, this hasn’t been agreed • Comments in work packages have not been addressed • Generally, connectivity to local communities is poor • There are unnecessary gaps in continuous route provision Traffic Modelling • Some routing in the base and forecast year models isn’t realistic, insufficient information has been supplied to the transport authority to enable it to be checked • Strategic model flows have been used to build the local junction models but these flows haven’t been validated for this purpose • Impacts of the scheme on particular areas of the local road network are of concern and need to be understood in more detail (specifically St Neots, Girton Interchange, Coton, others) • Construction traffic flows need to be understood in more detail to assess impacts on local communities and the highway asset Cycling • LTN 1/20 compliance required for any asset to be maintained by, or handed over to CCC. A compliant route is required between Cambourne and St Neots • Provision for users seems to be sub-standard with a lack of segregation and gaps in provision (for example at Eltisley) • Crossings are not acceptable, specifically at A1198 where a grade separated crossing would meet LTN 1/20 guidance and an underpass for cyclists and pedestrians could also be used as a bat crossing. • Eltisley Link North roundabout needs to facilitate cyclists who wish to continue north up the B1040 with a suitable transition from off to on road and be designed to slow traffic speeds. • Lack of crossing facility on the old A428 between Abbotsley Rd and the proposed footway/cycle track on Toseland Rd • The proposed footway/cycle track on the proposed bridge on Toseland Rd needs to allow for cyclists continuing north with a suitable transition from off to on road • Lack of safe crossing facilities at New Cambridge Rd junction where the proposed footway/cycle track crosses the slip roads. The proposed bridge on the B1046 should have provision for cyclists and pedestrians to facilitate a future segregated route between the villages and St. Neots. • Some provision for cyclists (Toseland Road) has been removed from the application Highway Design • An enforceable commitment from the applicant to Vision Zero is required • Approval In Principle for highway design including Standards not yet agreed • The submitted plans do not take account of the County Council’s requirements regarding Local Road Highway Design Principles. As such the proposals include unnecessary Departures of Standard for carriageway widths/cross sections. The principles to be applied in the design and construction of the Scheme’s local roads within Cambridgeshire are as follows: -Consistent application of MCDHW standards and specifications -Full compliance with standards wherever possible, but departures from standard are not justified for carriageway width/cross section -The methods of highway drainage should be considered at the preliminary design stage -Holistic design approach is required to avoid unnecessary maintenance risk/cost to the County Council • A lighting strategy is not in place and will be required to secure acceptable lighting design for both the new assets and those on the sections to be detrunked. • Commitment to the principle that no street lighting assets should be older than 2 years old at the point of handover whether on new or detrunked sections is required. • Detrunking and Assets requires extensive discussion • Boundaries need to be defined, including the land to be handed over. In principle, CCC will not accept land that is not required for highways purposes. • Changes to DCO drafting required to ensure appropriate protective provisions in relation to asset handover of local road network, NMU routes, and RoW • Detrunking process as set out is unacceptable and requires changes to the drafting of the DCO to follow a process agreed with the Highway Authority. De-trunked roads should not be handed over to the Highway Authority until they are at a reasonable standard agreed with the Highway Authority. • In particular the DCO should require either Protective Provisions with regard to Highway matters, or entry into an agreement as to handover of new and de-trunked roads. The agreed Handover Plan and Legal Agreement to be required under the DCO • Numbering of detrunked roads needs to be included within the application Highway Network Impact • Impact on network from construction traffic and re-routing needs to be understood and how any adverse impacts will be mitigated • Proposals in the DCO relating to Traffic Manager responsibilities are unacceptable and will require redrafting to allow for an agreed process • Permitted construction network routes need to be revised and the restrictions clarified • Effective ways of measuring and managing temporary traffic diversions need to be secured • More information required on the construction programme and timings for closures Digital Connectivity • The Councils request that the opportunity is taken as part of this major investment to install a fibre backbone along the route to enable connectivity along the corridor Other Matters • There has been no discussion to date of Development Consent Obligations • There is no provision or discussion of a legal agreement or Protective Provisions covering Highway matters although this has been requested • There has been no discussion to date of the detail of drafting in the DCO • There has been limited discussion to date of matters for the Statement of Common Ground • Finally agreement in principle is required in the following areas, followed by agreement and execution of a detailed legal agreement as part of the DCO as referred to above and specifically covering: -Commuted sums -Remedial maintenance of local highway assets impacted by the project -Adoption of assets -Funding to cover resource costs in the development of the scheme and ongoing matters via a Planning Performance Agreement or other mechanism -Commitment to minimise cost pressure on the Cambridgeshire Local Authorities"
Other Statutory Consultees
Shakespeare Martineau on behalf of South Staffordshire Water plc
"This registration is submitted on behalf of South Staffs Water plc (“SSW”), a water undertaker appointed under the Water Act 1989, with statutory duties to carry out water supply functions throughout its appointed area, including the area where the works are proposed to be carried out under the development consent order, if confirmed. SSW operates assets that are located in close proximity to the proposed works. Whilst SSW does not object in principle to the Scheme it reserves its ability to object if there is a risk to its assets or operations. The scheme affects major trunk mains serving thousands of people in the local populations in the West of Cambridge. All of the apparatus is strategic with no alternative means of serving the local areas if there is a loss of supply due to the scheme. It is essential that these assets remain in continuous operation in order to ensure the provision of water supplies to household and non-household customers. Initial discussions have been held with the applicant and initial designs provided but if the Scheme changes, further changes to the proposed diversions may be required. In addition any works required to be carried out to SSW’s assets must be planned and implemented to avoid the risk of supply interruption or damage to the integrity of the water network. Further, the current drafting of the protective provisions of the draft Development Consent Order ("DCO") are not satisfactory to SSW and amongst other points of concern they impose a requirement on SSW to remove redundant apparatus which SSW would normally cap and abandon. To remove such apparatus would impose significant costs on SSW. Removal of the redundant apparatus is only one of several issues that SSW have with the protective provisions. SSW therefore objects to the draft DCO unless and until such time as an approved programme and methodology of works can be agreed. In addition, SSW’s objection will remain unless SSW’s concerns with the protective provisions are addressed to their satisfaction, whether by amends to them or a supplemental agreement is reached."
Members of the Public/Businesses
The British Horse Society
"The BHS wishes to record its OBJECTION to the Development Consent Order as submitted because of the failure to include opportunities for equestrians which we believe has occurred due to the lack of consultation with equestrians unlike the consultation with cyclists. We would like to have the opportunity to explain our views to the Inspector due to the failure to accommodate the needs of equestrians contrary to National and Local Policies. For example : • The failure to provide for equestrian usage of the new bridge over the A421 at Roxton compounds an omission made when the A421 was built. The Society accepts that this current bridge is rarely used by horses because local riders consider it to be too dangerous. But there is a demand for it to be equestrian safe in order to create some riding circuits in an area has a shortage of bridleways. Further, the bridge will be used by a significantly higher number of HGVs than is currently the case making the need to segregate horses from the carriageway even greater. The Society considers it wholly unacceptable, and contrary to policy, that the proposed cycleway is not a bridleway in order to protect the safety of horse riders. • Caxton Gibbet roundabout. Needs safe and segregated NMU access for all users including equestrians. Failure to provide this facility will be disadvantage equestrians in perpetuity from accessing any A428 NMU provision. Opportunities to link to the new peripheral bridleway at Cambourne West have been ignored. • Bridleway 74/6 - could be provided no must be included in the project • New foot cycleway Cambourne to St. Ives – needs to be NMU • Minutes of NMU Meetings with CCC. Need for new NMU path alongside de trunked A428 was recorded as was path alongside new A428 • 4.4 NMU data survey – no equestrian activity bears no reflection on suppressed demand where facilities are inadequate. Huge changes since 2017 • 2.21.2 Data from Jacobs survey in no way captures the suppressed demand from all three users arising from the lack of facilities. How was this information captured? Massive changes in demand since lockdown. Building for the future not the past. • 2.15.1 Equality Act – females not mentioned. • Wintringham. The proposals made in the WCHAR only provide for cycling and walking whereas the existing footpaths are all to be upgraded to bridleways. This information was provided by the BHS but clearly has been ignored. • Constant reference throughout the document for the need to provide shared cycling and pedestrian access which is contrary to the Cambridgeshire and Peterborough Local Transport Plan requirement for Active Travel provision i.e. pedestrians, cyclists and equestrians. • The provision of NMU access is not a ‘nicety’ ‘if money allows’ but of high importance in terms of health and wellbeing. Any route should be designed to be safe, enjoyable and welcoming to use for all NMU’s and not simply something squeezed on to the edge of the carriageway. Identification of funds and their source should be part of the Planning Inspectorate approval."
Non-Statutory Organisations
Transport Action Network
"Transport Action Network (TAN) Transport Action network would like to formally object to the A428 Black Cat to Caxton Gibbet road scheme on the following grounds 1) The proposed scheme would have a significant impact on climate change as the scheme would lead to an increase in emissions of over 3.5 million tonnes of carbon dioxide. This makes the A428 the third largest emitting scheme out of the 50 schemes in the second Roads Investment Strategy and at a time of climate emergency this will make meeting the UK’s target of a 78% reduction in emissions by 2035 even more challenging than it already is. We are also concerned that not all carbon emissions have been included in this calculation. 2) The significance of the purported economic benefits when assessed at a national level. 3) The impact on the landscape and biodiversity due to the substantial footprint of the road. 4) The air and noise pollution it will create along the route and in the wider area due to the extra traffic it will generate 5) The quality of the active travel infrastructure and the failure to improve the facilities on the existing A428, particularly the roundabout to the south of St Neots. 6) The failure to make the existing A428 safer by lowering the speed limit so that it could be used, either on carriageway or adjacent to it, to create a long distance cycle route connecting St Neots to Cambourne and Cambridge. Given the flattish landscape in this area and prevalence of cycling, especially at the Cambridge end, this seems a serious omission as it could have been an opportunity to reduce road traffic and carbon emissions, particularly with the growing community at Cambourne."