Somerset County Council
"Somerset County Council and South Somerset District Council - Joint Council Relevant Representation – 19th October 2018
Planning Act 2008 – Section 102
A303 Sparkford to Ilchester Dualling Scheme
PINS Reference: - TR010036
The proposed dualling of the A303 between Sparkford and Ilchester is within the administrative boundaries of South Somerset District Council and Somerset County Council and therefore the ‘Councils’ are host authorities and statutory consultees in the Development Consent Order (DCO) process.
This relevant representation reiterates the Councils’ support for the dualling scheme. However, the Councils wish to ensure that the development does not result in unacceptable impacts on the residents, businesses and environment of the affected local area. We have therefore taken the opportunity to highlight issues that should be considered by the Planning Inspectorate at the Examination.
The Councils note that the scheme submitted is still only at preliminary design stage, and whilst advanced, is not finalised. On this basis, further localised impacts or issues may emerge and these will be presented to the Examining Authority as further information comes forward. There therefore continues to be a considerable volume of work that remains to be done and it is essential that the Councils have adequate resources provided to perform their functions. The Councils are disappointed that negotiations for a Planning Performance Agreement were unsuccessful which has limited their capacity and ability to fully assess the submitted DCO within the timeframes available. A detailed assessment of the scheme by the Councils is therefore ongoing. The Councils also have concerns in the context of having a fair chance to put their case and ensuring an adequate examination of the issues.
The comments listed below are intended as a summary, which will be further developed and detailed within the emerging Written Representations, Local Impact Report and Statements of Common Ground.
Impact on the Local Highway Network
The Councils have previously advised the applicant during the pre-application stage that a Transport Assessment should be prepared to confirm that the proposed layout is appropriate in traffic terms. It is understood that this has not been prepared but the applicant has prepared and submitted a CoMMA Report and Transport Report which includes technical modelling data.
Review of the modelling data has shown that the scheme is likely to increase traffic through the communities of West Camel and Sparkford. Whilst this is understood from review of the technical data, it is unclear why the impacts on these local areas, which could be more wide-ranging than just increased traffic and include for example impact on cultural heritage or ecology, are not described in detail within the Environmental Statement (ES) Chapters and we consider that there may be residual impacts which may need to be mitigated. We note that communities have raised concerns about increased traffic and we understand that the applicant is willing to make funds available to address this in West Camel; Sparkford is still being considered. Traffic calming measures and other mitigation measures should therefore be explored and considered through the DCO process with any additional impacts of this considered, and a mechanism established to secure this mitigation.
The Local Impact Area does not appear to include the locations of West Camel, Queen Camel or Podimore Roundabout. We originally recommended to Highways England that a “wider sphere of influence may be required to capture the wider scheme impacts…..” it would appear that this hasn’t been taken into account and therefore it appears that a significant amount of scheme impact has not be included within the report.
In addition, the CoMMA report includes operational traffic assessments of the proposed junctions but the assessment has shown potential issues around the junction of Sparkford High Street - The Avenue and Podimore Roundabout. In the absence of an explanation of these issues as part of the ES it is suggested that the applicant provides their view on the impacts and comment on whether the impact warrants appropriate mitigation.
SCC as the Local Highway Authority (LHA) have been working with the applicant’s designer since January 2018, providing comments on technical submissions related to new local road provision; provision for non-motorised users; signage and road markings; structures; construction proposals; drainage; and street lighting. In addition, matters relating to maintenance provision and extents of responsibility; regulatory measures on local roads; and de-trunking works have also been discussed, but again are at an early stage of agreement.
The technical elements do still require agreement through developed detailed design; however it is noted that the detailed designs are not yet programmed to be progressed until appointment of a further designer and potentially after conclusion of the examination. SCC considers that the outstanding issues are capable of being resolved, however, SCC will require provision within the wording of the DCO for the LHA to approve the remaining detailed design elements and agreement for the associated fees associated with this. At present it is considered that such a commitment is not yet contained within the DCO.
For those sections which fall to the responsibility of the LHA under DCO de-trunking procedures, it is normal practice for the LHA to be compensated by Highways England for the additional maintenance burden the roads will present to the Council. The compensatory arrangements have not yet been agreed including the end uses of all redundant sections of the A303 route.
Public Rights of Way
The information in the various documents and Draft DCO where shown in detail, is generally an accurate portrayal of the recorded public rights of way. Some of the more schematic figures of the whole application area would appear to have minor errors, but not sufficient to be of concern.
The LHA does have some concerns in relation to the methodology for assessing the usage of the network; by not covering full daylight hours, nor weekend days, the results of non-motorised user surveys is not considered entirely representative of the actual use.
In general the analysis of the impact of the development is a fair portrayal with one particular exception in relation to public bridleway Y 30/28. The LHA has concerns in relation to the impact of the stopping up of the connection of Y30/28 with the A303. The current proposal from the applicant is provision of a route east to the nearest new vehicular overbridge.
The applicant, in line with the National Policy Statement for National Networks, is expected to take appropriate mitigation measures to address adverse effects on public rights of way. The LHA considers that the proposed mitigation, whilst beneficial to the overall network is not the most appropriate. The length of the alternative route proposed by the applicant is c.5.2km for walkers, cyclists and equestrians. If instead the alternative was over Y 30/UN (now labelled Y 30/31), this length would be reduced to c.1.5km. This is a considerable difference in length and convenience.
In addition to the recorded network of Public Rights of Way, there are potentially unrecorded rights that may exist which the development will interfere with. Given the potential impact of the scheme it is considered that the possible outcomes of current applications to modify the Definitive Map and Statement would necessitate a mechanism to be included within the DCO which safeguards the provision of such rights in the future if and when they are confirmed.
Impact on Air Quality
Having reviewed all the information provided with this application, we are satisfied that the baseline information and assessment methods used in respect of air quality modelling is satisfactory. Whilst there appears to be no significant changes to air quality from the proposed scheme itself and as such, no mitigation measures have been proposed, there are two areas of concern to the Council, West Camel and Sparkford High Street where it is predicted the scheme will result in significantly increased traffic movements which may have an adverse effect on air quality. Further investigation is needed to ensure these areas will not exceed air quality limits and to determine whether appropriate mitigation measures are necessary.
Impact on Noise and Vibration
Having reviewed the information provided, we are satisfied that the baseline information in respect of noise and vibration is satisfactory, the assessment methods used are appropriate and the presentation of the results clearly demonstrate the likely effects the proposed scheme will have during construction and when in operation.
It is expected and understood that Best Practice Measures will be implemented during construction to mitigate the adverse effects of noise and vibration. Approval is to be obtained from the District Council through the Section 61 process which will ensure any mitigation identified will have no residual significant impacts. It is noted that there are 2 properties that will be significantly affected by operational noise once the scheme is open to traffic, however, the mitigation embedded in the scheme design and secondary double glazing for the 2 properties will be sufficient to mitigate the effects of the operational noise.
We however have concerns about the proposed scheme causing significant increases in traffic on Sparkford High Street and West Camel and the subsequent increase in noise as a result of this.
Impact on Cultural Heritage
The scheme is within an area of high historic and cultural value and whilst the assessment has been undertaken in accordance with the Design Manual for Roads and Bridges (DMRB), which is the accepted methodology for infrastructure projects, and sets out a logical sequence for assessment and review, the assessment for some assets is queried.
The increased traffic in West Camel and Sparkford may require mitigation. Any traffic calming measures that are required as a direct outcome of the dualling works should be included in the DCO and their effects on Conservation Areas and associated cultural heritage assessed. Such measures should assess the impact on the character and appearance of a conservation area or setting of a listed building and impact of traffic-induced vibration on the structural integrity of historic buildings and structures. Given that the traffic modelling for the scheme indicates an increase in HGV traffic as a direct outcome of the dualling works, it is recommended that traffic-induced vibration on historic buildings and structures, and increased traffic loads on Camel Bridge are assessed.
Whilst mitigation measures are outlined with the application, additional mitigation is required, details of which will be outlined in the Written Representations and Local Impact Report.
Impact on Archaeology
The data does not currently include the full suite of field investigations required to assess the significance or impacts of heritage assets. The applicant has carried out a geophysical survey of the scheme and is currently engaged in trial trenching. The applicant’s archaeological consultants have been in contact with the South West Heritage Trust (SWHT) and Written Schemes of Investigation for the survey and trial trenching have been agreed. The geophysical survey has indicated archaeological potential across areas of the scheme. The SWHT is engaged in monitoring of the trial trenching (in conjunction with HE where appropriate) and this is progressing well.
It is understood that the results of the fieldwork will be submitted during the application process and so it is envisaged that all required information will be available prior to any determination.
The documents that have been submitted are accepted as meeting the requirements of the initial phase of the assessment. The later submission of the geophysical survey and trial trenching will enable a mitigation strategy to be designed. At present it is not possible to comment fully on the ES Chapter and issues associated with the impacts on archaeology.
Impact on Landscape
The methodology for establishing the landscape and visual baseline in the ES is comprehensive and clearly sets out the study area, designated sites, landscape character and its sensitivity to change, and the visual baseline and its sensitivity to change. The assessment has been undertaken in accordance with the DMRB, Interim Advice Note 135/10 Landscape and Visual Effects Assessments (replacing parts of the DMRB) and the Landscape Institute Guidelines for Landscape & Visual Impact Assessments. The DMRB is the accepted methodology for infrastructure projects and the Landscape Institute guidance is a long-established industry tool.
The assessment for the likely effects is challenged for a number of visual receptors and requires reassessment. A number of measures and additional information are recommended to the landscape design to improve the impact on the scheme on the landscape its appreciation from visual receptors. These will be detailed in the Written Representations and Local Impact Report.
Impact on Biodiversity
The information presented is generally accurate but there are some omissions and these have been raised at Highways England Technical Working Groups and officers are working to progress matters. Any outstanding matters will be raised in the Local Impact Report.
Approximately 91 hectares of habitat clearance would be undertaken as part of the proposed scheme, 77.4 hectares would be temporarily damaged and 13.7 hectares permanently removed. Whilst overall it is suggested that there would be a net gain in biodiversity, this is unclear and requires evidencing using the use of metrics.
The loss of hedgerows and woodland is concerning. The replanting and replacement of mature trees on a 1 for 1 basis is insufficient and new planting should be on a 3 for 1 basis which would allow for natural losses. An appropriate ecological management plan will need to be in place to ensure that all the re-created habitats are managed to the intended habitat and for the duration of the scheme.
Of particular concern is the hedgerow east of Canegore Corner, no mitigation measures are proposed to counteract the effect of the proposed road construction on bats or other species, or for proposed species crossing the new A303 once operational. It is recommended that a “green bridge” be considered here and underpasses elsewhere as the opportunity exits.
The ecologist welcomes further dialogue to fully understand the various assessments of species and the extent and nature of the proposed mitigation, enhancement and monitoring and the mechanisms for securing it. Further survey work will be required prior to construction and the ecologist welcomes input.
Impact on People and Communities
Only light touch proposals regarding construction methodology and traffic management have been submitted to date. The Councils will therefore look to ensure that a mechanism is included within the wording of the DCO to secure an approved construction traffic management plan.
The Council has previously raised concerns over the absence of an approved signage strategy and potential implications of less direct access to Fleet Air Arm Museum and RNAS Yeovilton. The impact of the design of Hazelgrove Junction upon the viability of local businesses is also of concern and should be mitigated where possible.
The defined Local Impact Area for businesses is restrictive and does not allow impacts on various route-reliant businesses and visitor attractions to be taken into account. A number of small businesses and tourist attractions such as Haynes International Motor Museum, Hadspen House (Emily Estate to open spring 2019), Hauser and Wirth and Fleet Air Arm Museum are outside this tightly drawn area. Consideration should be given of the impact on the wider business community.
The effective management of traffic and good signage, especially during the construction phase of the proposed route will be essential, to ensure that businesses and communities are not negatively impacted. Funding to promote these businesses during the construction phase where it may be more difficult to access the facilities is necessary. The message should be clear that “South Somerset is still open for business”.
Road closures are included within outline proposals. However, only outline details have been received to date. Whilst it is suggested that the majority of closures be overnight, the potential impacts on residents and the business community will need to be considered. This further re-enforces the need to ensure that there is appropriate provision within the DCO drafting to include a commitment for detailed measures to be agreed with the Local Highway Authority and Local Planning Authority, especially given that Yeovil Refresh includes highways improvements that may come forward during the construction period.
Geology, Assets and Waste
The Councils are satisfied with the approach, assessment methodology, identified likely effects and proposed mitigation measures presented by the developer in the documents reviewed. We do, however, have a number of observations on the baseline data presented in Chapter 10 of the Environmental Statement and the proposed Site Waste Management Plan which link to waste generation in Somerset; latest data for landfill capacity in Somerset, including inert landfill; and, the operational status of Somerset waste sites, but we do not consider these affect the overall outcome of the assessment. Detail relating to these points will be further outlined within the Local Impact Report and Statement of Common Ground.
Lead Local Flood Authority
It is assumed that all the relevant CCTV surveys of drainage assets, as detailed in the DCO, have been undertaken as well as condition and extent surveys. It is understood that the ground investigations were being undertaken at the time of writing the Flood Risk Assessment and drainage strategies, but these should be used to inform the strategies. There will be a need to provide more detail of the various drainage features, ponds and structures as the proposals progress, including cross sections, levels and structures. These details should include any temporary or phased arrangements necessary for the construction of the scheme; including how and when these will be brought forward and become operational.
It is hoped that the comments above are helpful to the Examining Authority in informing their initial assessment of principal issues for examination. As outlined above, the continued review of the application material will enable the Councils to provide greater detail and explanation in their Local Impact Report.