The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.
A428 Black Cat to Caxton Gibbet Road Improvement scheme
Received 10 June 2021
From 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”