M25 junction 10/A3 Wisley interchange improvement

Representations received regarding M25 junction 10/A3 Wisley interchange improvement

The list below includes all those who registered to put their case on M25 junction 10/A3 Wisley interchange improvement and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Helen Jefferies
"I have two principal concerns which are in part inter-related. In my opinion insufficient attention has been paid to the traffic on local roads specifically Ockham Road North and Portsmouth Road Ripley. I understand that these roads are under the jurisdiction of Surrey County Council but the majority of traffic is either exiting the A3 or joining the A3 at Ockham park. My second concern relates to Air Quality and the impact of the additional vehicles on the A3 north of Ockham Park and the impact on the Thames Basin Heath Special Protection Area. Case law prevents projects which add to pollution and it also prevents counting improvements in emissions before the emissions have improved. Secondly, the impact of the routing of the 1,000,000 cars which visit the RHS at Wisley annually, 600,000 of which are likely to use Portsmouth Road Ripley to access the A3 South - air quality monitors on this road already show readings in excess of legal limits and I do not understand how this project helps us to meet AQ standards in any shape or form"
Members of the Public/Businesses
John Andrews
"It is important in my view that tail backs from the Wisley interchange junction of the A3/M25 are reduced at all times other entry to the next road is blocked. Long joining lanes would assist in this on all four carriageways with the strongest incentives to prevent rather than merely exhort drivers to remain on the joining lane until it ends Additionally tail backs caused by the traffic control lights on the roundabout need careful timing to optimise flow of traffic - the current rather lengthy periods seem to me to reduce overall traffic flow rates due to slow response times from drivers."
Members of the Public/Businesses
Lawrence David Simmons
"The project for the upgrading of Junction 10 of the M25 and the A3 is based on highly flawed premises. First, the principle of road expansion with a view to traffic capacity increase has been proven to be self- defeating over the decades. As new highways have been built, they have attracted and encouraged growth in traffic and car ownership. The M25 itself is carrying volumes far in excess of its initially projected levels. To attempt to cater for traffic is tail chasing that will inevitably result in even larger congestion events. People will generally tend to opt to use new and improved roads in the belief that these will facilitate journeys and reduce travel times. The net effect is that as the public pursue these options en-masse, they create the very problem the projects were intended to reconcile in the first instance. The aim should be to encourage people to choose sustainable means of movement such as rail, local bus and cycling. Secondly, the new scheme will destroy even more as yet undeveloped green belt land with all the ecological, environmental and scenic disbenefits that will result. More vehicle sourced pollution will be generated and this in turn will exacerbate current low-level air quality problems. Noise levels will also be increased to the detriment of those in earshot and wildlife. To pursue a scheme leading to the worsening of pollution on this scale is in direct conflict with Government aims on air quality improvement. Thirdly, the traffic levels on the M25 have been levelling off over the past decade and only the recent artificially created jams caused by the unjustified frequently imposed lower speed limits between junctions 9 and 16 and in particular between junctions 10 and 11 have given the impression that levels have risen. The smart motorway system has been abused to somehow justify the proposed scheme therefore on the basis of falsely created congestion. Fourthly, the expense of this scheme cannot be justified when budgets are tight and road safety initiative spending must surely take priority. In addition, pothole infilling, surface quality improvement, drainage improvement, safe streets, charging point proliferation and sponsorship of electric vehicle take-up would surely represent tax payers’ money far better spent. I thereby call upon the inspector to reject this ill-conceived scheme. Yours sincerely L D Simmons BA(Hons) MRTPI [redacted]"
Members of the Public/Businesses
Alan Watts
"I use the junction regularly travelling from the A3 northbound to the M25 eastbound, and regularly encounter delays back onto the main A3 carriageway which is dangerous. Likewise in the reverse direction the queue often stretches for a mile on the M25."
Members of the Public/Businesses
Sue Towner
"I want to ensure that all of RHS Wisley is safeguarded"
Members of the Public/Businesses
Laurence Greaves
"I totally support the proposed improvement to the M25 Junction 10 / A3 Wisley Interchange and the associated works to the surrounding road system"
Members of the Public/Businesses
Lord Michael Murphy
"I live quite close to this proposed new intersection. I am very concerned that we already have very high levels of air pollution in our village and this proposal will increase the amount of traffic pollution in the area. It will also increase the pollution to Wisley Gardens a world famous botanical site. I am concerned that this prosal together with other local proposals will greatly increase traffic which is already in gridlock at peak hours."
Members of the Public/Businesses
Neil Aust
"The junction is not the issue and we should not be looking to provide increased road capacity at the time we have called a climate emergency or while we cannot afford to maintain the existing road network, especially when all it will achieve is getting cars to the next jam faster. Instead of major changes, spend a fraction of the money on better signage, improved traffic lights, carriageway overhead electronic direction and more ongoing monitoring, capture, training and, in extreme cases, prosecution of poor driving on, off and around motorway junctions."
Members of the Public/Businesses
Ove Arup and Partners Limited on behalf of Extra MSA Cobham Limited
"Extra are an established developer, owner and operator of Motorway Service Areas across England. Cobham Services is located between junctions 9 and 10 of the M25, located near Downside, Surrey. The site was opened in 2012 and has recently been extended to provide additional HGV parking to address longstanding capacity requirements. Cobham Services is one of the busiest and most popular Motorway Service Areas in the UK, performing a vital road user safety and welfare function. It is important to the safe operation of the Motorway network in the south-east of England that operations at Cobham services are not impaired or reduced by the DCO scheme. While Extra are generally supportive of the Wisley Interchange Improvement scheme, the publication of the DCO documents has highlighted impacts for Cobham Services which we consider must be addressed by the Applicant. 1. Advanced Direction Signs There is an existing 1.5mile advanced direction sign for Cobham Services located on the eastbound carriageway verge immediately east of Junction 10 near marker post M25/B/71.8. This sign was installed in 2012 and is subject to a Traffic Signs Agreement between Highways England and Extra. It is important to note that this sign is not a typical traffic sign as the installation and ongoing maintenance is funded by Extra through a commuted lump sum. On review of Sheet 13 of the scheme engineering drawings it is not clear what action is proposed to relocate or replace this sign. We consider that appropriate arrangements should be agreed between Extra and the Applicant to ensure that the sign is replaced by the scheme. 2. Works in vicinity of Cobham Services The DCO boundary for the scheme extends along the M25 as far east as Bookham Road underbridge, however the scheme engineering drawings do not extend to this distance. The DCO boundary incorporates each of the merge and diverge connections between the Service Area and the M25. It is therefore unclear what activities will take place in close proximity to Cobham Services and to understand the consequent impact on the operation of the Service Area. We consider that the Applicant should disclose the full extent of the construction work around Cobham Services and justify the extent of the DCO boundary. 3. Construction impact on operation of Cobham Services While we understand that temporary traffic management measures will be required to safely deliver the DCO scheme, it will be important for the safety and welfare of the travelling public that full operation of Cobham Services is maintained throughout the duration of the construction works. The applicant should share details of the proposed traffic management around Cobham Services, temporary signing of the Service Area and any closures anticipated as part of the scheme. An agreed communication and engagement plan should be developed between the Applicant and Extra MSA Cobham Limited. Extra would welcome the opportunity to enter into a dialogue with Highways England on these matters."
Members of the Public/Businesses
Harry Eve
"I have many years experience of using the Ockham roundabout, Junction 10, Painshill roundabout and the access to and from Wisley Lane and I responded to the previous consultations. I have concerns about the impact of the current proposal on the local road network – including the operation of the Ockham Park interchange roundabout and the likely flows generated on other roads. These concerns include the impact of the proposed signalling on the various arms of the Ockham Park roundabout and details regarding safety of NMU crossings. I have concerns about the impact on biodiversity. I have concerns about the impact on air quality. I have concerns about the assumptions made with regard to the Guildford Local Plan. Having read through the transport assessment I have requested some information (e.g. missing details) and clarification from Highways England to help inform my response to the planning application."
Members of the Public/Businesses
Duncan MacBryde
"I am aware of the project and have no real issues with the scheme. Ultimately long term I think it will benefit anyone using the junction. My only concern is the impact it has on my land during the project and after. I am always happy to discuss anything in person that will affect my property."
Local Authorities
Royal Borough of Kingston upon Thames
"I refer to the letter submitted by this authority to Highways England in December 2018 regarding the M25 Junction 10/A3 Wisley Interchange Improvement, Targeted Consultation: Kingston supports the principle of the proposals put forward for the improvement of Junction 10 and associated changes that have subsequently been made to the scheme design. We recognise that this intersection has become very busy with the need to reduce conflicts and associated accident risk. In particular we support the scheme on the grounds of improved safety with the aim of reducing collision frequency and severity and also minimising the impacts on the surrounding road network. The smoothing of traffic flows at the junction and slip roads and associated reduction in stopping and starting should improve the current situation. It is pleasing to see that certain aspects of the scheme have, where possible, been reduced in scale to minimise the overall land take and associated environmental impacts (for example those identified as Map References 12, 14, 15 and 17 on pages 7/8 of the HE consultation booklet). It is also preferable to see, where practical, improvements being achieved through better management and/or improvement of existing infrastructure in preference to large scale new infrastructure projects. We recognise the need to support economic growth in the area and the associated additional trips that will inevitably be generated. However, we also strongly support the concept of progressing sustainable travel options where possible (which we understand are being promoted by Surrey County Council as the highway authority) to provide a choice of travel options and encourage travel by these modes thereby helping to reduce the scale of the necessary highway improvements and associated environmental impacts. Indeed local settlements such as Wisley are currently poorly served by public transport and therefore rely heavily on car based travel. A3 improvements in Kingston The primary interest to Kingston is that the progression of this work should pave the way to securing follow on improvements to the A3 trunk road, in particular the section to the north east of the Junction 10 intersection (inside the M25). There are two key intersections in our borough at Hook and Tolworth (both are roundabouts) which are of interest as they require upgrading to both address the existing pressures and accommodate the new development proposed in the area. This is of particular importance in terms of meeting the demanding housing targets set for our area and also progressing the concept of an opportunity area in Kingston (as identified in the new London Plan) which will support further (enhanced) urban growth. Initial partnership working has already taken place with Transport for London and other key partners to progress outline designs for the Tolworth intersection which will support the development being brought forward over the next few years (for example by Lidl and Meyer Homes). However, following recent discussions with Transport for London, we understand that input by Highways England to the A3 Hook intersection improvement has been put on hold pending the outcome of this piece of work on the M25 Junction 10. We are therefore keen to see the Junction 10 improvements progressed at the earliest opportunity to enable work on the Hook intersection to recommence enabling further easing of current issues and the unlocking of development potential in the area. It is important to note that the development capacity of the Tolworth area cannot be realised without these improvements as the network is already at capacity. Two schemes (one for the new Lidl National HQ and the other for 950 homes) are supported by a contribution to the funding of the Tolworth roundabout to enable them to happen, and any further development would need to be accompanied by the improvements to the Hook roundabout. It is crucial that the lack of transport infrastructure does not hold up delivery of homes and jobs. Sustainable Transport Modes We strongly support measures (including those proposed in the changes) to assist non motorised forms of transport which will enhance the experience for the more vulnerable road users and encourage more people to choose these modes of travel in preference to motorised travel (for example the proposed improvement of the existing pedestrian crossing facilities). However, we consider it would have been helpful if the consultation material had clearly identified existing and new facilities on separate plans, for example the proposed new cycle routes. Local Traffic Issues We are supportive of most of the proposals to stop-up side road accesses and associated measures to re-route traffic with new connections. Additionally, speed management of A3 southbound traffic at this location will be an important consideration, consequently we would be interested to see details of proposed speed limits and any associated enforcement measures. Regarding the loss of some of the existing lay-bys, we would like reassurance from Highways England that they are satisfied there are sufficient alternative facilities in the area. Additionally, the Ockham junction requires a slip road onto the A3 southbound otherwise traffic (including heavy goods vehicles) from the RHS heading southbound will either travel via Ripley village or head north and U-turn via J10, with neither of these options being particularly desirable. From Kingston’s perspective, the one potential concern over the highway improvement scheme is regarding the dedicated slip road which delivers traffic from the M25 onto the A3 northbound (and other capacity improvements proposed at Junction 10) which is likely to speed up delivery of traffic onto the A3 heading towards Kingston. Immediately to the south west of Kingston borough boundary is the point at which the number of lanes on the A3 reduces from 3 to 2, the lane widths reduce and the speed limit decreases to 50mph (due to the urban nature of the area). Traffic also feeds into the A3 eastbound from Esher (A309) at this location. We wouldn't want accident risk to increase in our area (or anywhere else) as a result. However, we do acknowledge that an A3 improvement scheme has been implemented at this location (Kingston borough boundary) in recent years including the realignment of the road and installation of new speed cameras in an attempt to improve safety and ensure that traffic obeys the 50mph speed limit. Hence it is recognised that these concerns may have already (in part) been designed out, however, there are still significant and frequent delays at this location during peak times. Further Impacts Children from the Royal Borough of Kingston currently enjoy access to the facilities at the Heyswood Campsite used by the Girl Guides. The proposed route of the access road would dissect and split the facilities apart. We would support this element of the proposals being reviewed to see if a better solution could be found. We hope you are able to accommodate our observations in your final design, however, if you have any queries regarding this response, please do not hesitate to contact me."
Members of the Public/Businesses
West Surrey Badger Group
"[Redacted] We would like some insight into how a protected species will be mitigated and protected. We would like the opportunity to see the badger survey and report."
Members of the Public/Businesses
Karuna Lawrence
"As a resident of Painshill House I am concerned that the proposed widening of the slip road from Painshill roundabout to the A3 will impact on my ability to access my property at busy times of the day. Also that security of the fields below my property will be compromised by unauthorised use once the access road is opened up."
Members of the Public/Businesses
Mark Towson
"1. Safety Severe traffic congestion on the Painshill roundabout, particularly during the morning and evening rush hours, already presents a significant safety risk to Painshill residents driving in and out of the estate through the main gates which open onto the roundabout. The current proposal for the Access Road will make that problem far worse due to the increased volume of traffic using the roundabout resulting from the widening of the A3 and the construction of the Access Road near to the roundabout, plus the fact that nothing is being done to substantially reduce the build up of traffic backing onto the roundabout from the A245 Seven Hills Road. 2. Security The Access Road would render redundant all security systems operated by day and night across Painshill Park and Painshill Estate leading to uncontrolled access by vehicles and pedestrians. Security is already a concern for the Park and Estate with recent incidents involving groups of Travellers who set up camp within the Park. The current proposal would further compromise the Park's chargeable entry policy causing a loss of revenue. 3. Pollution The increased volume of traffic associated with the A3 widening and the Access Road is expected to increase further the high levels of air pollution and noise pollution experienced by residents some of whom are elderly or have health problems, particularly during the two year construction phase. 4. Heritage, Conservation and the Environment Painshill Park and Painshill Estate have unique landscapes and buildings of considerable historical, architectural and environmental importance. The widening of the A3 and current proposals for the Access Road would damage Grade 1 listed fields and Grade 2 listed houses closest to the A3. It would also damage the local eco- system which is home to a diverse variety of wildlife including bats, badgers, dormice, deer, adders and bees. 5. Human Rights of Residents The right to a family/private life and enjoyment of property enshrined in European legislation is relevant in this context. We believe that the current proposals would violate the rights of approximately 30 people who live on the Painshill Estate. It also appears that in the consultation process to date the rights of Painshill residents have been assigned a much lower priority than those of non-residents. 6. Impact on Property Values The current proposals will lead to substantial compensation claims by the 12 households on the Painshill Estate for the "blight" caused by the construction work including loss of market value of the properties. 7. Better Options Exist We believe that better options exist that avoid the problems highlighted above. For example, siting the Access Road further past the Gothic Tower towards Pointers Road."
Members of the Public/Businesses
Regena Coult
"I am interested in conservation and I've been volunteering as a toad warden for the Surrey Amphibian and Reptile Group (SARG) for several years and more recently, as a toad warden coordinator. I also conduct natterjack toad surveys under licence for the Amphibian and Reptile Conservation (ARC) Trust. I have a passion for amphibians and see the devastation that is caused every year through road deaths. Since part of this project is to work on Old Lane, which is an existing toad crossing, could this be an opportunity to build a toad tunnel? Old Lane is a fast road and dangerous for toad wardens to patrol at night. Many toads get killed there every year. If an amphibian tunnel was built there, this would mean a net gain for biodiversity. If you could build something to save amphibians' lives on that road for the long term it would be wonderful. Many thanks. --------------------------------------- In addition to what I wrote before. I'm concerned about the routing of the new access road to Wisley. This not only results in the loss of habitat, it also causes fragmentation of habitats. Amphibians already get killed on Old Lane. This new dissection will inevitably become an additional death trap for hundreds of them. What measures are taken to stop these deaths? There needs to be a net gain for biodiversity, how can this be achieved in view of these expected losses? In other areas where amphibians are required to cross busy roads to get from their breeding ponds to their summer habitats they have all but disappeared. Why can the new road not be routed along the RHS gardens where the impact would be much smaller? I also understand that there are plans to build a green bridge across the A3. This is very welcome. Many thanks for your consideration."
Members of the Public/Businesses
Robert J. Brown
"I am opposed to the Highways agency Scheme as detailed on their drawing TRO10030?APP/2.8 Rev 0 for the following reasons. a) The junction from the 3 dwellings ,New Farm Close Farm and the Guides Camp is too near to Painshill Roundabout and located on the slip road to Junction M25 Jctn10, and will cause a hazard with vehicles deceleration backing up the Painshill Roundabout. b) The new road in Painshill Park adjacent to the A3 to give access to the A3 has no fencing and will let in travellers and other undesirable personnel into Painshill Park and the adjacent residences. In addition there will be ioncrease4d noise level from the felling of trees in [Redacted] Christmas tree wood exposing the Painshill Residents directly to A3 traffic. c) The previous Bridge option previously approved by Painshill Residents Association dealt with the above problems and I do not know why this has been changed without proper consultation with Painshill Residences. d) I consider that this Scheme as detailed on the above drawing has brought a blight to Painshill Residences lowering the house price due to the traffic disruption during the construction phase. I my opinion the safety of the existing M25 Junction could have been improved by proper signage and warning notices rather than waste the taxpayers Money , causing multiple traffic hazards and confusion whilst the works take place. Please re- look at this scheme particularly the design around Painshill Roundabout and challenge the Scheme and its absolute necessity as a whole . Eur Ing Robert J. Brown Bsc(Eng) , F.I.C.E, M.Inst H.E, M. A.S.C.E"
Members of the Public/Businesses
Fiona Towson
"1. Safety Severe traffic congestion on the Painshill roundabout, particularly during the morning and evening rush hours, already presents a significant safety risk to Painshill residents driving in and out of the estate through the main gates which open onto the roundabout. The current proposal for the Access Road will make that problem far worse due to the increased volume of traffic using the roundabout resulting from the widening of the A3 and the construction of the Access Road near to the roundabout, plus the fact that nothing is being done to substantially reduce the build up of traffic backing onto the roundabout from the A245 Seven Hills Road. 2. Security The Access Road would render redundant all security systems operated by day and night across Painshill Park and Painshill Estate leading to uncontrolled access by vehicles and pedestrians. Security is already a concern for the Park and Estate with recent incidents involving groups of Travellers who set up camp within the Park. The current proposal would further compromise the Park's chargeable entry policy causing a loss of revenue. 3. Pollution The increased volume of traffic associated with the A3 widening and the Access Road is expected to increase further the high levels of air pollution and noise pollution experienced by residents some of whom are elderly or have health problems, particularly during the two year construction phase. 4. Heritage, Conservation and the Environment Painshill Park and Painshill Estate have unique landscapes and buildings of considerable historical, architectural and environmental importance. The widening of the A3 and current proposals for the Access Road would damage Grade 1 listed fields and Grade 2 listed houses closest to the A3. It would also damage the local eco- system which is home to a diverse variety of wildlife including bats, badgers, dormice, deer, adders and bees. 5. Human Rights of Residents The right to a family/private life and enjoyment of property enshrined in European legislation is relevant in this context. We believe that the current proposals would violate the rights of approximately 30 people who live on the Painshill Estate. It also appears that in the consultation process to date the rights of Painshill residents have been assigned a much lower priority than those of non-residents. 6. Impact on Property Values The current proposals will lead to substantial compensation claims by the 12 households on the Painshill Estate for the "blight" caused by the construction work including loss of market value of the properties. 7. Better Options Exist We believe that better options exist that avoid the problems highlighted above. For example, siting the Access Road further past the Gothic Tower towards Pointers Road."
Members of the Public/Businesses
Paul Tiller
"I live in [Redacted] close to the Painshill Junction of the A245 and the A3 and will be affected by the planned works. I am not sure I fully understand the implications of the project on the enjoyment of my property hence my interest."
Members of the Public/Businesses
Peter J E Trew
"Concerns about: 1. Traffic conditions approaching and on the Painshill Roundabout, arising out of increased traffic and present planned location of the new access off the A3 to three properties adjoining Painshill Park. Does this location comply with deceleration guidelines and should it be further from the Painshill roundabout? 2. Security within Painshill Park and the Painshill Residential Estate during construction of the new road works. 3. Increase in noise level and pollution from increased traffic. 4. Justification for the proposed roadworks. Has this been established by an adequate cost benefit analysis?"
Members of the Public/Businesses
Painshill Residents Association
"The residents of the Painshill estate, are concerned that we will be negatively impacted by increased noise and pollution levels due to increased traffic on the A3. We are also concerned for our safety - that increased traffic on Painshill roundabout due to the wider A3 will make access to our properties even more difficult and dangerous at busy times of day. In addition we are concerned that the proposed access road from the slip road from the onto the A3 compromises the security of our properties. The immediate vicinity has seen a number of destructive traveller-incursions in recent months, and the new road will open up access to the fields adjoining the Painshill estate to unauthorised visitors to whom a locked gate will present no barrier. We will be submitting a fuller description of our concerns in early October 2019."
Members of the Public/Businesses
Peter Gelardi
"This is taking a very expensive hammer to crack a small nut. Two lane filters taking traffic from the A3 onto the M25 (from north and south) which flow directly onto the motorway but by-pass the roundabout/lights would solve the traffic backup issues at this junction for at least ten year and cost about 10% of the cost of your proposed solution."
Members of the Public/Businesses
Painshill Park Trust
"The Hon. Charles Hamilton created Painshill Landscape Garden in the mid-eighteenth century. At the time Painshill was recognised as one of the foremost examples of the only art form in which England has led the world. Visitors came from many countries and included royalty and two future American presidents. After 1939 it suffered thirty years of neglect and vandalism. By 1970 most of the historic buildings had collapsed or disappeared and the landscape was largely covered by scrub. Over the last 35 years Painshill Park Trust, supported by many millions of pounds of public and charitable money, has restored the landscape and buildings. Painshill is once again recognised as a national treasure. It is a Grade 1 listed landscape garden and is one of the very few that has survived largely intact for over 250 years. In late 2017 Highways England published their proposals for changes to Junction 10 of the M25. Their plans were based on information about Painshill that was more than forty years out of date, before the restoration had begun, and would have seriously damaged the landscape. Collaborative discussions with Highways England and their consultants, Atkins, throughout 2018 eventually resulted in satisfactory proposals which minimised damage to Painshill. Throughout these discussions, the Trust received constant assurances that its access onto the A3 at the western end of the park would either be retained or replaced by a separate access track. Most recently at a meeting held on November 15th 2018 it was minuted that “assurances were given that the Trust will be able to use the access road for emergency purposes and for service vehicles working at the western end of the park”. This is crucial because increasing numbers of visitors are using the western end of the park and the final stage of the restoration programme will be concentrating on it. The only alternative access is the route through the staff entrance. It is controlled by speed bumps to protect pedestrians and has a number of gates to be opened. In a recent trial it took a fire tender 15 minutes to reach the Gothic Tower using this route on a day when visitor numbers were light. The Gothic Tower is currently used as a café for visitors but has been used as a residence in the past and is likely to be so again. It has five storeys served by one circular staircase. At a recent meeting with Highways England it was stated that there was no technical reason why the access route could not be extended by 400 meters to the Painshill entrance and that the main reason for not including it in the DCO submission was that time had run out. Last year 120,000 people visited Painshill. This year visitor numbers have increased by about 20% and the Trust has a short-term target to attract 150,000 visitors each year. Visitor safety and the needs of the restoration programme emphasise the importance of a separate access at the west end of the park."
Members of the Public/Businesses
Diana Varbanescu
"Historic landscape, heritage Painshill House and Painshill Estate have been Grade II* listed. The house was built in the landscape garden (mid 18th century) as the creator C. Hamilton had intended: as an integral part to a timeless landscape garden. The gardens of the original house survive largely intact and this proposed development will impact the current status. Painshill Park has been awarded multiple medals for the restoration work. The restoration started with the local council having to buy the fragmented plots of land and recreate the original landscape garden. Restoration grants were awarded to enable the recreation of this unique landscape garden by recovering 158 acres of the original 200+ acres. The proposed development is a significant step back that will undo a great part of this work (and granted investment). Taking large parts of land running past the Gothic Tower will destroy a high number of trees from the ancient woodlands. Safety Traffic congestion on the Painshill roundabout is not addressed, the proposed development will only aggravate the current situation (generating more traffic in a congested area). Security Painshill Park and Painshill Estate residents’ security will severely be affected Pollution The increased volume of traffic associated with the A3 widening and the Access Road is expected to increase further the high levels of air pollution and noise pollution experienced by residents and visitors to the park. Losing trees from the ancient woodland (natural sound barrier) will further impact the remaining park and estate. Human Rights of Residents The right to a family/private life and enjoyment of property enshrined in European legislation is relevant in this context. We believe that the current proposals would violate the rights of approximately 30 people who live on the Painshill Estate. It also appears that in the consultation process to date the rights of Painshill residents have been assigned a much lower priority vs. impact. Impact on Property Values The current proposals will lead to substantial compensation claims by the 12 households on the Painshill Estate for the “blight” caused by the construction work including loss of market value of the properties. Better Options Exist I believe that better options exist to avoid the problems highlighted above."
Members of the Public/Businesses
Diana Varbanescu on behalf of Gustav Mauer
"Historic landscape, heritage Painshill House and Painshill Estate have been awarded Grade II* listed status. The house was built in the landscape garden (mid 18th century) as the creator C. Hamilton had intended: as an integral part to a timeless landscape. While the gardens of the original house survive largely intact today (British Listed Buildings mention), the proposed development will impact the current status. Painshill Park (Grade I listed) has been awarded multiple medals for the restoration work. The restoration started with the local council having to buy fragmented plots of land to recreate the original landscape garden. Restoration grants were awarded to enable the recreation of this unique park (158 acres were recovered of the original 200+ acres). The proposed development is a significant step back that will undo a great part of this work (and granted investment). Safety Traffic congestion on the Painshill roundabout is not addressed, the proposed development will only aggravate the current situation (generating more traffic in an already congested area). Security Painshill Park and Painshill Estate residents’ security will severely be affected by the proposed changes Pollution The increased volume of traffic associated with the A3 widening and the Access Road is expected to increase further the high levels of air and noise pollution experienced by residents and visitors to the park. Losing trees from the ancient woodland (natural barrier) will further impact the remaining park and estate. Human Rights of Residents The right to a family/private life and enjoyment of property enshrined in European legislation is relevant in this context. We believe that the current proposals would violate the rights of approximately 30 people who live on the Painshill Estate. It also appears that in the consultation process to date the rights of Painshill residents have been assigned a much lower priority vs. impact. Impact on Property Values The current proposals will lead to substantial compensation claims by the 12 households on the Painshill Estate for the “blight” caused by the construction work including loss of market value of the properties. Better Options Exist I believe that better options exist to avoid the problems highlighted above."
Members of the Public/Businesses
response has attachments
Richard Max & Co LLP on behalf of Royal Horticultural Society
"To follow. At present I am registering on behalf of my client. ------------------------------------- Please see attached"
Members of the Public/Businesses
The Gardens Trust
"Development Consent Order M25/A3 Wisley Interchange Planning Inspectorate Ref. TR010030 Representation on behalf of the Gardens Trust and their member organisation the Surrey Gardens Trust • Acknowledge the design changes that have been made to reduce the physical and other impacts on the Registered Parks and Gardens sites at RHS Wisley and Painshill Park (especially in relation to the Gothic Tower). • Note the positive discussions that have taken place with RHS and Painshill Park Trust. • Note the Statements of Significance for the two sites and broadly concur with their conclusions. • Accept that the Register area of Painshill Park to the north of and outside the Painshill Park Trust ownership is of a lesser overall significance. • Note that the proposals affecting this lengthy area alongside the A3 have been carefully considered and subject to change. • Note that the assimilation of the new boundaries with structures and landscaping will be the subject of further detailed consideration with land owners as part of purchase procedures and in final construction details. • Note that the topsoil storage area within the Painshill Park Register area will be restored to pre-existing condition. • Strongly support the Painshill Park Trust in their requirement for a replacement access at the western end of their ownership for both emergency and land management purposes. Note that this was provided for in earlier proposals without significant impact on the Register area. Yours sincerely, Margie Hoffnung Conservation Officer"
Local Authorities
Surrey Heath Borough Council
"Dear Planning Inspectorate Thank you for inviting Surrey Heath Borough Council to comment on the proposal for the M25 junction 10/A3 Wisley interchange improvement. The proposal is some distance from the Borough boundary. We note that the scheme includes re-provision of heathland, habitat creation and compensation land. I can confirm that this authority does not wish to raise any objections to the proposal. Kind regards, Planning Policy and Conservation Surrey Heath Borough Council Knoll Road Camberley GU15 3HD www.surreyheath.gov.uk Great Place • Great Community • Great Future"
Members of the Public/Businesses
Elm Corner Residents Group
"I make representations on behalf of owners and residents of all sixteen Elm Corner properties, Wilderness Cottage, and of land at The Wilderness, regarding Highways England’s application for a Development Consent Order in respect of changes to the M25 Junction 10/A3 Wisley Interchange (‘the Order’). I write in the capacity of leading the residents working group in respect of these works, with the knowledge and backing of all sixteen properties on Elm Corner, Wilderness Cottage, land at The Wilderness who collectively and unanimously share the concerns raised here. I am also the freehold owner and occupier of [Redacted] which will be affected by the proposed works. The proposed works include stopping up the sole vehicular access to sixteen Elm Corner properties, and building a new access road past Wilderness Cottage and The Wilderness.. Our concerns include but are not limited to: • Safety of the proposed junction between ‘new’ Elm Lane and Old Lane • Exacerbation of lewd and antisocial behaviour on ‘old’ Elm Lane (concerns shared by SCC and SWT) o Inclusion of old Elm Lane in the DCO boundary was urged by residents so it could be returned to nature and thereby dissuade such behaviour in this unlit dead end. HE instead propose to keep it open for occasional maintenance access to drainage attenuation ponds • Noise, light and air pollution during the construction phase, and completed scheme. This pollution will be exacerbated by: o Construction phase: night works and construction compound location on the former Wisley Airfield adjacent to Orchard Cottage, Blenheim Cottage and Meadows, with works vehicles passing and turning by the other properties, and o Final scheme: environmental mitigation including 4 hectares of clearance and 7.3 hectares intense selective thinning in the narrow section of woodland between Elm Corner and the A3 with no detail provided on mitigation • Loss of habitat for dormice and other protected species located in sites proposed for construction • Disparity in design detail between information in documents and information provided by project team • Widening of a section of Elm Lane which does not require it • Continuity of vehicular access to properties at all times with minimal disruption to residents • A new elevated section of road over the A3 is not the most appropriate design solution due to the impacts on nearby residents and the SPA, where surveys show dormice and other rare and protected species are detected. Alternative design solutions are available which will reduce the impact and these should be explored further • We request engagement with residents regarding remedial accommodation works and reinstatement of boundary features following the acquisition of land, including the owner having the requisite level of input and control over building materials, timing of works, revised boundary treatments/features, etc. • We request engagement with residents regarding mitigation for air, noise and light during the construction phase and final scheme • We request that Highways England should work with property owners and residents to ensure that the necessary commitments are entered into in advance of the appointment of contractors and commencement of the works I hereby request that all residents of Elm Corner are registered as Interested Parties collectively as the ‘Elm Corner Residents Group’, so that we may contribute in the examination process regarding the Order. Households may also register individually as interested parties notwithstanding our group registration. The above summarises our concerns in respect of Highways England’s proposals and we reserve the right to add to these representations through formal written representations or attendance at the hearing and the presentation of oral evidence. [Redacted]"
Other Statutory Consultees
response has attachments
Natural England
"Natural England's response to the DCO application by Highways England ref TR010030 is attached. Graham Steven Lead Advisor Natural England"
Members of the Public/Businesses
Chasemore Farm
"As an equine veterinarian living [Redacted] and working [Redacted] within 1km of the M25 adjacent to Junction 10, I represent a large Thoroughbred owner-breeder, Chasemore Farm, a producer of young horses and a significant local employer. The business is contiguous with the M25, and experiences significant (and steadily increasing) noise pollution due to the inferior concrete road surface on this section and the lack of sound barriers. Sound levels on the farm frequently exceed 75 decibels which is a chronic stressor for young equine athletes, and deters potential clients. Our submission will petition to ensure that interchange improvements maximise the reduction of noise pollution, in the form of: - The installation of acoustic barriers on both sides of the M25 and A3 where improvements are being made - Improved road surface to reduce 'road rumble'"
Members of the Public/Businesses
Molly James
"I commute on this route every day and am fully supportive of the plans and would like to be kept up to date with its progress."
Members of the Public/Businesses
response has attachments
Tim Harrold
"See attached document dated 30th August 2019"
Other Statutory Consultees
Affinity Water Limited
"Affinity water Limted are the potable water utility for the area covered by this application • Approx. 4.8Km of a single 6” PVC-U tapering to a 4”CI single distribution main will be affected. • This section of main also supplies several outlying villages, farms and businesses via 4 separate connections and there are also 5 motorway crossings suppling small clusters of properties. • It is a single point of failure should a burst or interruption to supply occur on this main affecting all above. • Distribution mains are laid to a depth and location as per our design guidance to ensure safe access and future maintenance. Any changes to depth and access must be sign off by Affinity Water. • Excavating near our water network must be approved in advance with RAMS and other method statements and backed up with internal review and guidance from our Hydraulic Modelling team. Sign-off would need to be approved by Control Ops, local Ops and WQ. • Guidance to working near our apparatus will also need to be adhered to. Guidance notes are found on Affinity Water Limited's website . Please see : [Redacted]"
Members of the Public/Businesses
Christopher Haley
"This representation is made in a personal capacity as a local resident who has lived in the area for 40 years. The principal submissions that I intend to make concern: First, the need to respect and preserve the rare bell-barrow and tumuli immediately to the West of the interchange. This is especially important given the developing understanding of the pre-history of the area, such as the significant Bronze Age 'Ockham Hoard', unearthed 6 years ago, which points to an important Bronze Age presence here. Second, the need to preserve as much of Ockham Heath and Wisley Common as possible, for the enjoyment of walkers and horse-riders. The area is a popular location, as well as an important site for wildlife."
Parish Councils
Ockham Parish Council
"Ockham Parish Council, who represent the hamlets which make up Ockham register as an Interested Party. As Ockham Parish Council we have been representing the interests of residents for over 120 years. Our areas of concern include, but are not limited to, the following: • Air quality – during construction and beyond • Noise pollution – during construction and beyond • Light pollution – during construction and beyond • The two construction compounds within Ockham – mitigating noise, disruption, dust, light pollution, traffic delays. Ensuring safety to both road users and pedestrians and equestrian • Preservation of Conservation areas at Ockham Mill and Church End which will be disrupted by site traffic and those trying to avoid the construction work and then ongoing protection of these areas into the future • Loss of Ancient Woodland at Elm Lane and around new Cockcrow Bridge – how this can be mitigated as 16.3 Chapter 17 summary states No mitigation to be taken due to irreplaceable nature of ancient trees • Loss of habitats and protected species during the works. • Contamination of both land and water within TBHSPA • Relocation of areas of TBHSPA. • Disturbance to aquatic species in Bolder Mere and Stratford Brook • Detailed design for access from Old Lane to A3 and Old Lane and new Elm Lane • Redesign of Ockham Bites carpark. We request that a consideration of the design is to support the prevention of antisocial behaviour • Water overrun into Bolder Mere and Stratford Brook. • Preservation of archaeological remains discovered during the construction period • Preservation of heritage landmarks during the construction period • Preservation of Ockham Village Green • Seeking solutions that satisfy homeowners within Ockham whose properties will be affected by the works – such as Orchard Cottage and others within Elm Corner • We remain convinced that the road bridge to RHS Wisley is not the best access solution. We request that the Inspector engages with us during the Examination period to discuss our concerns and that we continue to be consulted during the build up to the construction period as well as during the works programme."
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: With respect to Registration of Interest documentation, we are reassured that earlier comments raised by us on 11 January 2018, 21 March 2018 and 12 December 2018 have been addressed. In addition, we acknowledge that the Environmental Statement (ES) has not identified any issues which could significantly affect public health. PHE is satisfied with the methodology used to undertake the environmental assessment. On the basis of the documentation as reviewed we have no additional comments to make at this stage and can confirm that we have chosen NOT to register an interest with the Planning Inspectorate on this occasion. Please do not hesitate to contact us if you have any questions or concerns."
Members of the Public/Businesses
Helen Jefferies on behalf of Wisley Action Group
"The Wisley Action Group makes the following representation which it will expand upon in due course: We have three principal objections to the scheme's environmental impact on the Thames Basin Heath Special Protection Area and on the local residents of Ripley, Ockham, the Horsleys and surrounding villages and hamlets. We also do not consider that the traffic modelling is robust or that it reflects the actual day-to-day experience of local road users Air quality As part of our evidence base for the planning appeal promoting the development of the former Wisley airfield which was dismissed by the Secretary of State in June 2018 we established that the air quality in the SPA on the eastern side of the A3 was already in excess of the legal limit. Since that time a number of EU judgements have been issued which support our expert's argument that additional vehicle traffic will have a negative impact on the SPA which cannot be ignored. Further, case law means that any improvements in technology which may improve car emissions cannot be taken into account for modelling purposes. The project's aim is to improve the capacity of the junction meaning more cars and more pollution which will impact both air quality and nitrogen deposition on the SPA. We are particularly concerned that the applicant relies on evidence used by the developer of the former Wisley airfield, much of which was found to be lacking at the planning appeal. Furthermore, the proposed routing of visitor traffic leaving the RHS, particularly those heading south, will impact the already close to the limit air quality in Ripley High Street. We estimate this to be 600,000 vehicles per year - the current alternative is to add 7km to their journey and change direction at J10. Ecology We do not believe that the impact on the habitats of protected species including those in the SPA has been properly taken into account. Impact on Stratford Brook Impact on Stratford Brook - we do not believe that the impact on Stratford Brook has been properly taken into account. Traffic modelling It is clear to locals that the impact of the changes to the Ockham Park roundabout have not been properly taken into account including but not limited to: - lengthy queues on Ockham Road North in the am and pm peak exacerbated by pm peak traffic from RHS Wisley and slow-moving waste tankers from Thames Water in Wisley Lane and the proposed 5000 vehicles exiting the former Wisley airfield development - lengthy queues in Ripley High St exacerbated by new traffic rerouting from Wisley Lane and RHS visitors -local roads are not suitable for construction traffic at all as evidenced by the damage done during the Jury Farm waste application in Ripley Lane and the ongoing HGV movement associated with the waste application at the Drift. Local roads are not wide enough. We do not accept that the projected small improvement in the transit time for J10 amounts to IROPI."
Members of the Public/Businesses
Woodland Trust
"As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. We own over 1,000 sites across the UK, covering around 24,000 hectares (59,000 acres) and we have 500,000 members and supporters. The Trust is concerned about the direct loss of 0.4ha from two ancient woods and the impacts on 11 veteran trees, two of which are proposed to be removed. Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since 1600AD. Ancient woodland takes centuries to develop and evolve, creating vital links between plants, animals and soils – a habitat for many of the UK's most important and threatened fauna and flora species. Therefore it cannot be re-created and cannot afford to be lost. Natural England’s standing advice on veteran trees states that they “can be individual trees or groups of trees within wood pastures, historic parkland, hedgerows, orchards, parks or other areas. They are often found outside ancient woodlands. They are irreplaceable habitats with some or all of the following characteristics… A veteran tree may not be very old, but it has decay features, such as branch death and hollowing. These features contribute to its biodiversity, cultural and heritage value.” The National Planning Policy Framework, paragraph 175 states: “When determining planning applications, local planning authorities should apply the following principles: c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons58 and a suitable compensation strategy exists”. Paragraph 5.32 of the National Policy Statement for National Networks also contains wording related to the protection of ancient woodland and veteran trees, stating: “The Secretary of State should not grant development consent for any development that would result in the loss or deterioration of irreplaceable habitats including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the national need for and benefits of the development, in that location, clearly outweigh the loss.” While the Trust acknowledges that the applicants are proposing measures to compensate for the loss of ancient woodland, including translocation of ancient woodland soil and bringing existing areas of ancient woodland into management, we consider that these measures can only be considered compensation and cannot make up for the loss of irreplaceable ancient woodland. The same applies in the case of veteran trees. In order to avoid impact, veteran trees must be afforded appropriate protection in line with Natural England’s standing advice, with buffer zones of 15 times the diameter of the tree or 5 metres beyond the canopy if that is greater. In summary, the Trust is opposed to the proposed scheme on the basis of impacts to ancient woodland and veteran trees and as such we consider that this scheme in its current form contravenes national planning policies due to the loss of irreplaceable habitats."
Local Authorities
Elmbridge Borough Council
"Elmbridge Borough Council, while being supportive of the aims of the M25/J10 project (reduce congestion/help traffic flow/improve safety), also strives to mitigate the impacts of the project within Elmbridge Borough. The Council appreciates the submitted DCO scheme will change, as detailed designs are completed, therefore, the views of the Council may also evolve. The summary of current comments/concerns are outlined below: Traffic: The Council will look to Surrey County Council (SCC) as the Local Highway Authority to provide detailed comments on traffic issues (e.g. modelling/capacity/mitigation/road safety/scheme design/etc.). The Council has concerns about the increased traffic pressure on the local road networks during project construction and once implemented as the Council anticipates removing the right turn from Seven Hills Road towards Brookland will result in local traffic diverting through Weybridge. The Council desires that within funding secured, the repair and/or resurfacing of the local road networks impacted, during construction and through diverted traffic routes created by the project, be included and works completed. Land Interests: The Council is a landowner of multiple sites which will be impacted by the proposed works. One property is partially within the DCO boundary, Painshill Park, which is currently leased to Painshill Park Trust. The main concern for the Council as a landowner, is the removal of a vehicular access and exit point from the A3 to our property. This is located near the second countdown marker on the south bound exit slip road. The DCO application has not included any alternative provision. Rectification of the physical loss is reliant upon recourse to private treaty to acquire replacement rights. Subsequently, the potential for the Council as landowner (jointly with its Tenant, Painshill Park Trust) to be subject to ransom is increased. This is directly as a result of the limited extent of the boundary for the DCO. Non-motorised User (NMU) Routes: The Council supports the improvements to the NMU provision to create a safe, secure and segregated alternative travel options for residents, and will look to SCC to comment on the maintenance and layout suitability for the routes. Environmental: Much of the impacted natural area (SPA/common land/open spaces) within the scheme is under the management of SCC, and the Council looks to SCC to provide detailed comments on layout, design and maintenance. The Council have concern about our area of Ancient Woodland and TPO trees impacted by the scheme, and that these be conserved during construction as per British Standard practices. Also, where replacement planting is taking place (trees/shrubs/grasses) there should be an improvement on what is being replaced. The potential impact of the construction and scheme including noise, air quality, and pollution is a concern for the local area, including listed areas. Upon completion, the management of many items within Elmbridge Borough will fall to SCC, and we support them to secure funding for monitoring/maintenance. The Council will continue to engage with HE to achieve the best results for Elmbridge Borough. More detailed comments will be provided throughout later DCO stages (e.g. Local Impact Report)."
Members of the Public/Businesses
Emily Inge
"My husband and I are the freehold owners and occupiers of [Redacted] which will be affected by the proposed works.. The proposed works include stopping up the sole vehicular access to our property, and building a new access road. Our concerns include but are not limited to: • Safety of the junction between ‘new’ Elm Lane and Old Lane • Exacerbation of lewd and antisocial behaviour on ‘old’ Elm Lane (concerns shared by SCC and SWT) o Inclusion of old Elm Lane in the DCO boundary was urged by residents so it could be returned to nature and thereby dissuade such behaviour in this unlit dead end. HE instead propose to keep it open for occasional maintenance access to drainage attenuation ponds • Noise, light and air pollution during the construction phase, and completed scheme. This pollution will be exacerbated by: o Construction phase: night works and construction compound location on the former Wisley Airfield adjacent to Orchard Cottage, Blenheim Cottage and Meadows with works vehicles passing and turning by properties, and o Final scheme: environmental mitigation including 4 hectares of clearance and 7.3 hectares intense selective thinning in the narrow section of woodland between Elm Corner and the A3 with no detail provided on mitigation • Loss of habitat for dormice and other protected species located in sites proposed for construction • Disparity in design detail between information in documents and information provided by project team • Widening of a section of Elm Lane which does not require it • Continuity of vehicular access to properties at all times with minimal disruption to residents • A new elevated section of road over the A3 is not the most appropriate design solution due to the impacts on nearby residents and the SPA, where surveys show dormice and other rare and protected species are detected. Alternative design solutions are available which will reduce the impact and these should be explored further • We request engagement with residents regarding remedial accommodation works and reinstatement of boundary features following the acquisition of land, including the owner having the requisite level of input and control over building materials, timing of works, revised boundary treatments/features, etc. • We request engagement with residents or making available information regarding mitigation for air, noise and light during the construction phase and final scheme • We request that Highways England should work with property owners and residents to ensure that the necessary commitments are entered into in advance of the appointment of contractors and commencement of the works I hereby request to be registered as an Interested Party, so that we may contribute in the examination process regarding the Order. The above summarises our concerns in respect of Highways England’s proposals and we reserve the right to add to these representations through formal written representations or attendance at the hearing and the presentation of oral evidence."
Members of the Public/Businesses
Guildford Residents Associations
"We welcome the the proposed changes to M25 J10 and the A3. The scheme will increase capacity and make the network safer. Our concern is the the effect of traffic on local roads in Wisley and Ripley in particular. The results of the traffic have led to the conclusion (in 7.4 Traffic Assessment Report) that conditions in Ripley, at Ockham Park junction and on Wisley Lane will be satisfactory. The analysis of journey times is welcome. However, the peak visitor days at RHS Wisley lead to high volumes of traffic trying to access and leave the site, which currently can cause queuing to and from Wisley Lane. The planned growth at the Wisley airfield site and at Burnt Common, and the other sites in Send will increase volumes on local roads, including Ockham Roundabout and in Ripley. While we note the remarks about rerouting via the A245 Byfleet Road and M25 J11, we main concerned about the risk of capacity issues arising on routes linking to the A3."
Members of the Public/Businesses
Iceni Projects on behalf of London Strategic Land
"Iceni Projects have been instructed to register an interest in relation to the above application on behalf of our client, London Strategic Land (LSL). LSL are in the process of submitting a planning application for a residential development at a site adjacent to the A3 at Send Marsh near Ripley, approximately 5km from the junction between the A3 and M25. Any representations submitted on behalf of our clients are anticipated to focus on the potential traffic impacts on the local road network as a result of the construction works associated with the junction improvements. We would like to be kept informed of the progress of the project and may wish to make further representations at a later stage of the examination."
Members of the Public/Businesses
Mrs Amy Barklam
"I write to make a representation in respect of Highway England’s application for a Development Consent Order in respect of improvements to the M25 Junction 10/A3 Wisley Interchange (‘the Order’). I write in the capacity of being the freehold owner and occupier of [Redacted] (‘the Property’), which will be affected by the proposed works. If consented, the proposed works will provide for changes in the access arrangements to the Property. At present, the property is accessed via Elm Lane, an adopted public highway which is accessed via a junction with the A3 (Eastbound carriageway). The proposed works will provide for the eastern section of Elm Lane to be ‘stopped up’, resulting in access to the Property from the A3 not being possible. An alternative access is proposed by Highways England through the construction of a new road to replace the existing section of track (not navigable by most vehicles) which connects Elm Lane and Old Lane to the west. These works will necessitate the widening of the existing road and track, the creation of turning heads and the realignment of existing private access off Elm Lane, all of which requires the acquisition of land. Part of the Property is proposed to be acquired to facilitate these works. Whilst there has been some engagement with Highways England as to the nature of the works, these discussions have not provided the necessary level of assurance that the works will be undertaken in a fashion that: (i) maintains vehicular access to the Property at all times and minimises disruption (including noise and light pollution) to residents; (ii) minimises the amount of land to be acquired; (iii) ensures that the works required to the private accesses of properties is properly managed, with the owner having the requisite level of input and control over building materials, timing of works, revised boundary treatments/features, etc.; (iv) addresses the reinstatement of boundary features following the acquisition of land; and (v) addresses concerns of antisocial behaviour that could arise at the turning head/new end of the road. Highways England should work with property owners and residents to ensure that the necessary commitments are entered into in advance of the appointment of contractors and commencement of the works. I also hold concerns that the proposed works to create a new elevated section of road over the A3 is not the most appropriate design solution due to the increased impacts on nearby residents from noise pollution. Alternative design solutions are available which will reduce the impact on the Property and other residents at Elm Corner and these should be explored further. If this design is to be progressed, Highways England need to detail how the impacts of noise and other negative impacts such as air and light pollution on Elm Corner properties will be mitigated. I hereby request that I am registered as an Interested Party so that I can contribute in the examination process regarding the Order. The above summarises my concerns in respect of Highways England’s proposals and I reserve the right to add to these representations through formal written representations or attendance at the hearing and the presentation of oral evidence. Yours sincerely, Amy Barklam"
Members of the Public/Businesses
Mrs Deborah Gillan
"I am writing as a Painshill householder within close proximity of the planned access road, leading off the slip road from the Painshill roundabout onto the A3. As such we are extremely concerned on several grounds: 1. Loss of woodland, currently reducing noise pollution and protection from the pylon. Also providing habitat for local species: badger, deer, bats etc 2. Security threat to Painshill residents and the Park 3. Road hazard where the access road is too close to Painshill roundabout and causing further congestion, with traffic slowing to allow access. This would cause a back up of traffic onto the roundabout and make entry and exit for Painshill residents even more dangerous and difficult than it is currently. 4. Devaluation of grade 2 listed properties and the environment surrounding the Park. Yours sincerely Deborah Gillan"
Members of the Public/Businesses
Mrs Helen Cowell
"I write as the freeholder of a property in [Redacted] My concerns are 1. Regarding the destruction of many hectares of the Thames Basin Heaths Special Protection Area (TBHSPA) following the increase in size of Junction 10 and the widening of the A3 both northbound and southbound. The area of Wisley and Ockham commons is a very nature sensitive area. The areas of 'new' SPA designated land are in small pockets and not one contiguous large area that could be designated. An area of land does exist that could be designated as such, but this has been overlooked by Highways England in their proposals. 2. The proposal by Highways England for the large road bridge over the A3 as the entrance to RHS Wisley Gardens is unnecessary as there is sufficient unused scrub land within the current central reservation to enable an access road to be built on the north side of the A3, thereby saving £millions of pounds on the project. In addition the large road bridge proposed by Highways England cuts through ancient woodland, further adding to the environmental excesses of this project. 3. In the Environmental Statement Chapters 1-4 there are plans for enhancement work to the area of land between Bolder Mere and Elm Corner which involves the removal and thinning of much of the trees in this area. This will severely impact noise and light pollution in the hamlet of Elm Corner and there has been absolutely no consultation on this plan with any of the 16 householders in this road. I hereby request that I am registered as an Interested Party so that I can contribute in the examination process regarding the Order. The above summarises my concerns in respect of Highways England’s proposals and I reserve the right to add to these representations through formal written representations or attendance at the hearing and the presentation of oral evidence. Mrs Helen Cowell [Redacted] 05/09/2019"
Other Statutory Consultees
National Grid
"Dear Sir/Madam REPRESENTATION BY NATIONAL GRID ELECTRICITY TRANSMISSION PLC (“NGET”) TO THE M25 junction 10/A3 Wisley interchange improvement DCO (“THE PROJECT”) NGET wishes to make a relevant representation to the Project DCO in order to protect its position in relation to infrastructure and land which is within or in close proximity to the proposed Order limits. NGET’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. The documentation and plans submitted for the above proposed scheme are being reviewed in relation to impacts on NGET’s existing apparatus and land interests located within this area, and NGET may require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET will liaise with the Promoter in this regard. NGET assets which have been identified as being within or within close proximity to the proposed Order limits are: OVER HEAD LINE ZM Route 275kV - CHESSINGTON - WEST WEYBRIDGE ZM021/ZM022/ZM023/ZM024/ZM025 – Clearances of ZM021-022 (across A3 and new access road), ZM022-023 (across new access road into gas compound), ZM023-024 (across new access road Bellmouth and A3). As a responsible statutory undertaker, NGET’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. NGET reserves the right to make further representations as part of the examination process but in the meantime will negotiate with the promoter with a view to reaching a satisfactory agreement. I hope the above information is useful. If you require any further information please do not hesitate to contact me. Yours sincerely Spencer Jefferies Development Liaison Officer, Land and Acquisitions."
Other Statutory Consultees
BNP Paribas Real Estate on behalf of Royal Mail Group Ltd
"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. The proposed M25 Junction 10/A3 Wisley Interchange Improvements will, once constructed, reduce congestion which will have benefits for Royal Mail operational traffic movements. However, Royal Mail is concerned about the potential for disruption to its operations during the construction phase. Royal Mail’s has nine operational properties within approximately 10 miles of the proposed DCO boundary, the nearest being Cobham Delivery Office 1 High Street, Cobham KT11 3E which is 2.4 miles distant. The M25 and A3 are strategically important distribution routes for Royal Mail operational traffic. Any periods of road disruption/closure, night or day, have the potential to impact operations. Also, in exercising its statutory duties Royal Mail vehicles use on a daily basis all of the local roads that may potentially be affected by additional traffic arising from the construction of the proposed junction improvements. Royal Mail therefore wishes to ensure the protection of its future ability to provide an efficient mail sorting and delivery service to the public in accordance with its statutory obligations which may be adversely affected by the construction of this proposed scheme. In order to address the above concerns Royal Mail requests that: 1. The DCO includes requirements that Royal Mail will pre-consulted by Highways England or its contractors on any proposed road closures/ diversions/ alternative access arrangements, hours of working and the content of the final Construction Traffic Management Plan. 2. The final Construction Traffic Management Plan includes provision for a mechanism to inform major road users about works affecting the local network (with particular regard to Royal Mail’s distribution facilities in the area surrounding the DCO application boundary)."
Members of the Public/Businesses
Savills on behalf of Wisley Property Investments Limited
"This Relevant Representation is made by Wisley Property Investments Limited (WPIL) as owner of the former Wisley airfield to the east of Ockham interchange. The airfield is identified as the majority part of a strategic development site in policy/ allocation A35 of the Guildford Borough Local Plan: Strategy and Sites adopted in April 2019, for approximately 2,000 homes, further specialist housing and employment, retail, school, community facilities and open space with the primary road access to the site from the A3 Ockham interchange. The signalisation and improvement of Ockham interchange is proposed in the draft DCO application which also proposes works on WPIL’s land, including permanent diversion of Wisley Lane through the site, and a temporary large topsoil storage/ temporary construction compound. The airfield site plots included in the draft DCO Book of Reference are as follows: Permanent Rights & Temporary Powers – Plots 1/40, 1/18a Temporary Powers - Plots 2/1, 2/1a, 2/1b, 2/3, 2/5a, 2/5c Permanent Acquisition – 1/18, 1/22, 2/5b . Although the DCO works are supported in principle by WPIL, the proposed works have the potential to compromise and/or delay the development of the site (subject to both the site securing planning consent and the DCO being made). As such, WPIL requires that a legal agreement is entered into to ensure that the interface between the DCO works and the site are appropriately managed. The legal agreement should also provide for provision of the compulsory acquisition powers sought by Highways England (HE) in the draft DCO, over WPIL land. As per government guidance, compulsory acquisition powers should only be granted as a last resort, and WPIL is encouraged that HE has confirmed their willingness to enter into an early agreement to secure the rights included in the draft DCO (as per a letter dated 17th June 2019 from Jonathan Wade, HE Project Manager). However, until such an agreement is entered into, WPIL objects to the compulsory acquisition of its land, and requests to reserve the right to provide further written representations throughout the Examination, and to appear at any Compulsory Acquisition hearings as may be required, to provide verbal evidence. In parallel with the legal agreement, a Statement of Common Ground (SoCG) with Highways England will be negotiated, on the basis that the DCO will support the delivery of allocation A35. Issues to be covered within the legal agreement or Statement of Common Ground include: - 1. The need for detailed information on HE’s traffic modelling methodology and outputs, so that the implications for strategic developments such as Wisley airfield and the local road network can be understood by WPIL and others. 2. Proposed arrangements for securing site access to the allocation A35 from the proposed Wisley Lane, including provision for an appropriate site access with appropriate traffic conditions (such as speed restriction) on the proposed Wisley Lane, and DCO Requirements or planning obligations if the DCO is made. 3. The relationship between HE’s biodiversity strategy (including proposed SPA related matters and onsite works) and that for the Wisley airfield development to ensure alignment, enabling the successful delivery of both the DCO scheme and Allocation A35. Matters include: - a. Allocation A35 will be enabled through over 50 ha of Suitable Alternative Natural Greenspace (SANG), a significant proportion of which may be to the area north of the airfield and adjoining the DCO temporary works area, and to the south at Stratford Brook. b. HE’s Landscape and Ecology Management and Monitoring Plan (APP.6.5, ES appendix 7.20) overlaps with parts of the proposed SANG but lacks detail including tree loss in those areas. c. HE’s proposals on existing trees and landscape on and near to Wisley airfield including for example Wisley Lane diversion and a new diversion to Elm Lane that will affect several trees and areas of scrub that have not been assessed in the landscape chapter of HE’s Environmental Statement (APP.6.3 chapter 9). d. Species permeability of the diverted Wisley Lane, and appropriate mitigations for any impact on the SNCI, and on Reptiles / Amphibians and other species. e. Detailed proposals for the proposed works to Stratford Brook and their future management. f. Proposed nitrogen deposition impact on the SPA. 4. Appropriate extent of access, rights and temporary and permanent land transfer to enable proper delivery of the DCO scheme and it’s early stage components in a manner compatible with the delivery of allocation A35 and the Local Plan housing trajectory. WPIL may submit evidence on any of the above matters and may wish to comment on other matters in the light of third party evidence that comes forward during the course of the examination."
Members of the Public/Businesses
Young Family
"In addition to the Elm Corner, Ockham group DCO response, we write in the capacity of being joint freehold owners and occupiers of [Redacted] property which will be affected by the proposed works. If consented, the proposed works will involve changes to the access arrangements to the Property. Presently, the property is accessed via Elm Lane, an adopted public highway which is accessed via a junction with the A3 (Westbound carriageway). Elm Lane in turn provides access to Elm Corner. The proposed works will require that the western section of Elm Lane to be ‘stopped up’, with no access to the Property from the A3 trunk road. Alternative access is proposed by Highways England through the construction of a new road to replace the existing BOAT 525 byway, currently unsuitable to most vehicles, that connects Elm Lane and Old Lane to the east. This will require the widening of the existing road and track, creation of turning heads, stopping up of Elm Lane and realignment of existing private access off Elm Lane, which requires the acquisition of land. Part of the Property is proposed to be acquired to facilitate these works. Whilst there has been some engagement with Highways England as to the nature of the works, these discussions have not provided the necessary level of assurance that the works will be undertake in a fashion that: (i) maintains vehicular access to the Property at all times and minimises disruption to residents; (ii) minimises the amount of land to be acquired; (iii) ensures that the works required to the private accesses of properties is properly managed with the owner having the requisite level of input and control over building materials, timing of works, revised boundary treatments/features, etc.; and (iv) addresses the reinstatement of boundary features following the acquisition of land. Highways England should work with property owners and residents to ensure that the extent of works and necessary commitments are entered into in advance of the appointment of contractors and commencement of the works. We hereby request that we are registered as an Interested Party so that we can contribute in the examination process regarding the Order. The above summarises our concerns in respect of Highways England’s proposals and we reserve the right to add to these representations through formal written representations or attendance at the hearing and the presentation of oral evidence."
Members of the Public/Businesses
Cobham Conservation & Heritage Trust
"1. Generally, it is of concern that there is insufficient planning gain from the proposals. 2. There is concern that Highways England are only responsible for the Strategic Road Network and not the Local Road Network (which here becomes the responsibility of Surrey Highways as part of Surrey County Council). Easing of traffic through Junction 10 is likely to increase traffic generally and, with that, waiting time on local roads. Accordingly, Surrey County Council need to be given more financial support, 3. There are other locations along the A3 that need upgrading. There is insufficient consideration of the Guildford Local Plan and of strategic sites put forward in that and of the junctions on the A3 at Burnt Common and in the Guildford area. 4 There is concern about directions given to RHS Wisley traffic and the effect of that and of traffic that may be generated from any proposed development on the Former Wisley Airfield which require adequate controls and/or south facing slip roads at the Ockham Park roundabout to relieve Ripley from an increase in traffic. 5. There is concern that the Highways England proposals on Painshill Park, our local Grade 1 listed 18th century landscape garden, will have land taken very close to the Gothic Tower and that there are trees of historical and horticultural significance together with associated flora and fauna. 6. There is local concern that any expansion of Junction 10 raises the prospect of significant increases in light, air and noise pollution. These will impact local communities and on land that is SPA (in the Thames Basin Heath Special Protection Area), SSSI and common land on Ockham and Wisley Commons and on flora and fauna there. Cobham (which has an AQMA) is in the path of the prevailing south westerly wind. 7. For the purpose of ensuring conservation of the flora and fauna for the area, there is concern that replacement land is not comparable to the land lost and that sufficient quiet road surfaces are not being provided on both the M25 and the A3. 8. There is concern that the Highways England proposals have insufficient provision to accommodate public transport. 9. There is concern that there is not sufficient provision for use by equestrians, cyclists and walkers (NMUs), particularly during the period of the work being carried out. There is a lack of detail about how conflict between NMUs and vehicles will be avoided at some bridges and other locations."
Other Statutory Consultees
response has attachments
Environment Agency
"We have today (26 July 2019) e-mailed our representation to the project e-mail address: [email protected]. ------------------------------ Please see attached"
Members of the Public/Businesses
Tim Hancock Associates on behalf of Euro Garages
"Ref: M25 Junction 10/A3 Interchange Improvement Scheme (TR010030) Dears Sir Euro Garages Limited and Associated Companies – EG Cobham, Portsmouth Road, Cobham, Surrey, KT11 1EL – M25 Junction 10/A3 Wisley Interchange Improvement Scheme I confirm that I am instructed on behalf of Euro Garages Limited and associated companies, which hold the freehold interest in the former San Domenico site at Portsmouth Road, Cobham, Surrey, KT11 1EL. This property would be seriously adversely affected in the event that the proposed improvement of the M25 Junction 10/A3 Wisley Interchange is implemented. I have previously made representations on the proposed scheme to Highways England by way of letter dated 23rd of March 2018. This letter expresses the same concerns. My client controls this strategic roadside service area site which enjoys direct access from the eastbound carriageway of the A3 trunk road. The site represents one of a very limited number of such strategic locations on the feeder roads to the M25 orbital motorway and comprises a Starbucks Coffee drive-thru unit which adequately provides rest and refreshment to passing traffic on the A3. The current access arrangements allow all passing traffic to readily and conveniently access the facilities with limited diversions. In the absence of the proposed scheme, the property would have further development potential to provide comprehensive facilities at this location for the motorists and HGV drivers at this location. It is understood that in the opinion of the promoting authority, the road proposals as presently formulated would require the closure of the existing direct vehicular access to the property from the A3 trunk road. In commercial terms, the loss of this access would not be mitigated by the provision of any alternative access created via the local road network. Consequently, as proposed the scheme would render the property unviable as a roadside location to provide motorists’ facilities. This would be the case even with the provision of advance warning signs on the trunk road as the route to access the facilities would require a significant detour and be inconvenient to prospective customers. I should be grateful if this letter could be accepted as a representation against the proposals on the basis that the justification for the scheme and the justification for the closure of my client’s access has not been demonstrated. My client reserves the right to submit further representations against the proposals. I would be grateful if you would kindly acknowledge receipt of these representations. Yours sincerely Tim Hancock"
Members of the Public/Businesses
Guiseppina O'Brien
"After the original 13 proposals were reduced down to the two bridge proposals in summer 2018, Pains Hill residents have not been part of the consultation process and yet during that time the new access point onto the slip road was put forward as the favoured proposal. The earlier proposal of a bridge over the A3 is fundamentally a better alternative on the grounds of security and safety in that it is potentially dangerous to have an entrance to a new access road off the slip road so close to the Pains Hill roundabout.In the alternative, there are other proposals that have been dismissed that would have had less adverse effects on the Pains Hill Grade 1 landscape. The proposed scheme negates the security of the Pains Hill estate and the security and the economic viability of Pains Hill Park."
Other Statutory Consultees
response has attachments
Historic England
"Representation submitted by email to [email protected] on 6 September 2019 at 15.24pm. -------------------------------------- Please see attached"
Members of the Public/Businesses
Lesley Lloyd-Eley
"The Pains Hill roundabout will be adversely impacted by the proposal to cite the entrance to the access road for the three properties. The entrance is cited too close to the roundabout and insufficient warning will be given to a vehicle going down the slip road that vehicles may be emerging at a considerably slower speed than people drive on the slip road. Alternatively, that vehicles will need to break swiftly to enter the access road at a point where many vehicles will be accelerating to join the faster A3. The security of both Pains Hill Park and Pains Hill residents will be affected. Security of Pains Hill residents afforded by electronic gates will be nullified by access to the estate from the new access road coming off the slip road. Not only might the security of the Park be affected but it could undermine the economy of the Park by people avoiding the entrance fees. The proposed bridge across the A3, in 2018, which was put forward as the favoured of the 13 proposals, had a significantly lower impact on the Pains Hill community. It was communicated as the best approach to the new 3 property access road until we were consulted this year regarding the latest scheme to acquire our neighbour's field and come much closer to our 12 properties with the attendant consequences relating to health, noise, security, economics and safety."
Local Authorities
response has attachments
Surrey County Council
"SURREY COUNTY COUNCIL - RELEVANT REPRESENTATION SEPTEMBER 2019 M25 JUNCTION 10/A3 WISLEY INTERCHANGE Planning Act 2008 – Section 102 PINS Reference: - TR010030 1 EXECUTIVE SUMMARY 1.1 The proposed scheme is within the administrative boundary of Surrey County Council and so the County Council is a host authority and statutory consultee in the Development Consent Order (DCO) process. 1.2 This Relevant Representation reiterates the County Council’s support for the principle of the scheme. We wish, however, to ensure that the development does not result in unacceptable impacts on the residents, businesses and environment of the affected local area or in additional maintenance/management liabilities to meet Highways England’s stated key objective to “Minimise impacts on the surrounding Local Road Network.” We have therefore taken the opportunity to highlight issues to be considered by the Examining Authority. 1.3 This response takes into account the County Council’s statutory responsibilities and functions and is intended as a summary which will be further developed and detailed within the Written Representations, Local Impact Report and Statement of Common Ground. It is understood the submitted DCO scheme will change, as detailed designs are completed and as such the County Council views may also evolve. We require provision within the wording of the DCO for the County Council to approve the remaining detailed design elements and agreement of associated fees associated with this from Highways England as at present it is considered that such a commitment is not yet contained within the DCO. 1.4 The majority of these comments have been previously made by the County Council in its response to each of Highways England’s consultations (the Statutory consultation and the two Non Statutory targeted consultations) as such we would ask that our response letters (dated 23rd March 2018, 13th December 2018 and the 7th May 2019) are taken into account in our representations. The County Council have also submitted detailed comments on Volume 3.1 Draft Development Consent Order (on 20th May 2019) to Highways England. 1.5 In a number of cases technical information has only been made available at the date of the publication of the DCO and so the County Council have made additional comments where possible. 1.6 At the time of drafting this Relevant Representation the County Council’s main areas of concern and position are as follows: 1 Impact on the Local Road Network (LRN) • Transport Assessment concerns - data provided and associated impacts • LRN areas affected by the scheme - in particular re-routed traffic through Ripley, Bridge End, Martyr’s Green and the lack of mitigation. Request Highways England confirm approval in principal for Burntcommon north facing slip roads, confirm feasibility for Ockham Roundabout south facing slip roads and fund a comprehensive mitigation package in Ripley. • Heavy Goods Vehicles (HGV) - loss of existing HGV parking and impacts on the LRN • Drainage & Structures – concerns on adoption, commuted sums and maintenance access • Request for Variable Message signs to improve interaction between SRN and LRN • How the wider community will be engaged on the final scheme upon DCO completion • That Protective Provisions for Local Highway Authorities are included either in the main DCO or a commitment given by Highways England to enter into a separate agreement 2 Impact on Non-Motorised Users (NMU), Public Transport and Public Rights of Way (PROW) • The proposed parallel NMU route should be maintained by Highways England as it is a replacement for the current NMU route adjacent to the A3 and the current legal right to cycle on the A3 which Highways England are removing under the proposed scheme • Concern regarding the proposed surface treatment of the NMU routes. • The need for further measures/funding to compensate for removal of the A3 bus stops 3 Impact on Road Safety • Speed Limits – the County Council agree with the proposals except for Elm Lane • Road Safety Audit (RSA) – the County Council considers the current RSA to be too limited as it does not cover all of the affected LRN • Traffic Regulation Orders (TRO’s) – that all TRO’s required as part of the scheme (e.g. speed limits, banned movements, rights of way) are advertised and made by Highways England 4 Impact on Surrey County Council’s financial position • Adoption of new/proposed scheme components – there are elements of the scheme that the County Council is not prepared to adopt. • Commuted Sums – Highways England has not, to date, committed to provide commuted sums (via a separate agreement) to cover the maintenance burden that would fall on the County Council for additional infrastructure. • Funding to cover County Council costs – Highways England has not followed through with their initial offer to enter into a Planning Performance Agreement to meet the County Councils staff costs in respect of input to the development of the scheme 5 Impact on Surrey Land Interests • Concern that Highways England has not to date concluded historic exchange land from the original M25 (1979 & 1982 CPOs) which is ongoing with the County Council • That Highways England set out as early as possible their financial offer in respect of land acquisition and compensation in respect of the County Council’s retained land which is adversely impacted/blighted. 6 Impact on Landscape, Environment, Biodiversity and Archaeology • Highways England has shared a draft SPA Management, Landscape & Ecology Management, Outline Construction Environmental Management Plans and programme of archaeological investigatory works but, until these are finalised, the County Council cannot confirm its agreement • Specific concerns to be addressed regarding the Green Bridge 7 Impact on Lead Local Flood Authority • The County Council has submitted comments on Protective Provisions for Watercourses / Drainage Authorities it wishes to see incorporated 8 Impact on Waste Authority • Concerns on distribution of material consumption and waste generation, source of construction materials, materials and waste capacity assumptions, facilities to deal with excavated hazardous waste and the need to refer to the January 2019 Submission of the Draft Surrey Waste Local Plan. 9 Impacts during construction • Concerns regarding impacts to the LRN during construction including fatigue on the existing LRN as a result of traffic diversions with no Highways England commitment to provide funding to mitigate these impacts and maintenance burden. A copy of the County Council's full Relevant Representation has been sent to [email protected] and the County Council would ask that this is read in conjunction with the above executive summary. ---------------------------- Please see attached"
Members of the Public/Businesses
Surrey Wildlife Trust
"The Surrey Wildlife Trust manages much of the protected land in the Ockham & Wisley Commons SSSI/part of the Thames Basin Heaths SPA surrounding M25 J10, on behalf of the landowners Surrey County Council. We have been engaged as a major stakeholder by Highways England and their consultants Atkins ltd throughout the consultation period leading up to the application for DCO. We have corresponded formally in response to the several consultation phases to date on the options for the scheme. We trust that PINS has been provided with copies of these responses. A summary of our final position is as follows. We recognise and understand the justification for the M25 J10/A3 Interchange Improvement Scheme. We regret as inevitable the short-term ecological impacts during construction and immediate operation of the scheme, but support the avoidance, mitigation and compensation strategy that has been developed in close consultation with ourselves to address these impacts and that can be expected to eventually result in long-term net gains for the biodiversity of the protected site. This agreed strategy must be implemented in its entirety, and our wholehearted support is further predicated on the observation of the recommendations of the separate feasibility study undertaken by Atkins advising on the preferred, desirable specification of the proposed green bridge to replace the existing Cockcrow bridge over the A3. As such, this bridge must incorporate a ‘green’ element at an absolute minimum width of 25 metres to ensure its effectiveness. In our considered opinion 10m will fail to achieve this."
Members of the Public/Businesses
The Georgian Group
"Dear Sir/Madam The Georgian Group has been made aware of the recent adjustments that Highways England has made to their scheme involving the A3 and Painshill Park Trust. Painshill Park is grade I statutorily listed, putting it amongst the most valuable landscapes in England. The park was designed and arranged by the Hon Charles Hamilton between 1738 and 1773. On the completion of the park in 1773, Hamilton was forced to sell Painshill, and what followed was a series of separate ownerships and a decline in the laid out vision of Charles Hamilton. This decline lead to the purchasing of the land after effective campaigning work by the Friends of Painshill, the Garden History Society and the Georgian Group. Following this important moment in the history of Painshill, the Painshill Park Trust was set up, tasked with the aim of returning the park to its former glory. A task that has been achieved to great success, helped by public and private grants, once again securing its national importance. The Georgian Group has been vocal, along with other parties, in the consultations surrounding the development of this project, culminating in Highways England previously making sensible and essential adjustments to the planned routes. Bearing this in mind, it is unfortunate to be made aware, that not all of these adjustments are to be taken forward in the official plans published by Highways England. The necessity of access onto the A3 at the west end of the park has been highlighted by the Painshill Park Trust and includes the safety of visitors to the grade I park, along with enabling vital restoration works to be carried out. The reasoning behind not ensuring that adequate access is supplied to the grounds, which was that ‘time had run out’ does not amount to ‘clear and convincing justification’. An aspect highlighted within the NPPF paragraph 194, where it states, ‘Any harm to, or loss of, the significance of a designated heritage asset, should require clear and convincing justification’. Going forward, the Group would like to see the amendments originally made by Highways England brought to fruition in their plans for Painshill Park and the surrounding area. Over the past year, the park has seen a 20% increase in visitors, which can be linked to the vital work undertaken by the Painshill Park Trust. Ensuring the necessary changes are made to the Highways England development would secure the future of one of the finest landscapes in England and allow further work to be undertaken on the grounds. Yours Sincerely, Edward Waller"
Members of the Public/Businesses
The Royal Society for the Protection of Birds
"The Royal Society for the Protection of Birds (the RSPB) has a long-standing involvement in the protection of lowland heathland and its key bird species (Dartford warbler, nightjar, and woodlark) in the south of England. This has included involvement in development cases around the area that was designated as the Thames Basin Heaths Special Protection Area (the SPA) in 2005. Since the designation of the SPA the RSPB has had extensive involvement in the establishment of the Thames Basin Heaths Delivery Framework and Strategic Access Management and Monitoring Scheme, which were designed and implemented to ensure the effective protection of the SPA from the impacts of housing development. The RSPB’s primary concern with the M25 junction 10/A3 Wisley interchange scheme (the scheme) is with its potential impacts on the SPA. As proposed, the scheme involves a direct land take from the SPA of 5.9 ha permanently and 8.6 ha temporarily. During the pre-application phase, the RSPB has been involved in detailed constructive discussions with Highways England and its consultants to ensure that the impact upon the SPA arising from the scheme is minimised. As a consequence of these discussions modifications to the scheme mean that the land take has been reduced. The RSPB continues to discuss the package of compensation measures proposed by Highways England to ensure that it will fully address the adverse effects of this scheme. To be effective it is essential that there can be confidence in both the ecological effectiveness and the legal and financial security of delivery of the compensation measures as well as their long-term maintenance to ensure that they continue to function in perpetuity. The RSPB is carefully considering the draft Development Consent Order, the Habitats Regulations Assessment, the Outline Construction Environmental Management Plan (the Outline CEMP) and other scheme documents to ensure that these provide the certainty that we seek. The RSPB notes that various of the scheme documents (e.g. the Outline CEMP) are described as ‘living’ documents that will develop during the course of the Examination. Consequently, we wish to have the opportunity to scrutinise these documents as they develop to ensure that at the end of the Examination that the final compensation package gives us the necessary confidence that it will be ecologically, legally and financially effective. This will ensure the overall coherence of the Natura 2000 network is protected and reflect the requirements of The Conservation of Habitats and Species Regulations 2017 (as amended) (the Habitats Regulations). In addition to the compensation measures, the RSPB has also been in discussion with Highways England over its proposed package of enhancement measures, set out in various scheme documents. The RSPB will also with to scrutinise these measures during the Examination to ensure that we have confidence in the ecological, legal and financial effectiveness of the final package of enhancement measures. In addition to the package of enhancement and compensation measures submitted to the Examination the RSPB may wish to comment upon the arguments being advanced by Highways England to justify this damaging development under Regulation 64 of the Habitats Regulations."
Local Authorities
Waverley Borough Council
"I am writing in response to the application to the Secretary of State for a Development Consent Order in respect of the proposed M25 junction 10/A3 Wisley interchange improvement scheme. On behalf of Waverley Borough Council I would like to make the following comments: The A3 trunk road and to a certain extent the M25 and M3 motorways are the key strategic roads connecting Waverley Borough to the wider region and beyond. Therefore, our interest with regards to plan making relates to the M25 to Solent (A3 and M3) and the London Orbital and M23 to Gatwick route strategies. The Waverley Borough Local Plan Part 1: Strategic Policies and Sites was formally adopted by Waverley Borough Council at its meeting on 20 February 2018. The Plan supports the delivery of at least 11,210 additional homes in Waverley in the period 2013 to 2032 (an average of 590 homes a year). The importance of this improvement scheme to Waverley Borough is recognised by its inclusion in our Infrastructure Delivery Plan. The Council does not have any comments to make on the potential environmental issues associated with the proposed route as these issues are outside of the borough. However, the Council would request that any assessment work for the junction improvements takes account of the amount of growth required in the Waverley Local Plan to ensure that the economic benefits of the growth are fully realised in terms of future residents having access to jobs and other facilities including the proposed third runway at Heathrow Airport."
Local Authorities
response has attachments
Guildford Borough Council
"Please see attached"