A417 Missing Link

Representations received regarding A417 Missing Link

The list below includes all those who registered to put their case on A417 Missing Link and their relevant representations.

SourceRepresentation - click on an item to see more details
Non-Statutory Organisations
Cheltenham & Tewkesbury Cycling Campaign
"That the three signed crossings provided for PROW 77, 78, 80, 125 and 126 with Dog Lane and 91, 84 with Dog Lane and 127 (via A417 footway), and 86 with the A417 footway and 127 exist and are currently in use, and that: One good crossing be provided, in mitigation of the three listed above that will be closed, between the foot of the escarpment and the Bentham underpass, to link Dog Lane/new link replacing the A417 footway to the North and the new PMA replacing and reconnecting sections of PROW 74/77/126/84 to the South."
Members of the Public/Businesses
Bushry Basheer
"The A417 missing link is going to be a very damaging road cutting through an area of outstanding beauty. It will also increase emissions by just under a million tonnes. As a result of the government not taking climate change seriously enough, road planners can effectivley ignore climate change. For the love of this planet, or if not this planet, for your future children and grandchildren, don't let damaging projects like these go ahead just so a few capitalists can get wealthy in the short term."
Members of the Public/Businesses
Jonathan Baker
"I fully support the scheme. I like that the dialling up a steep escarpment of the Cotswolds will be fitting into the landscape. The principal of green bridges will unite severed wildlife and fuana on both sides of the dual carriageway. I also like the proposed stone walls and repurposing the old road. This scheme has similar environmental benefits as the Stonehenge Tunnel scheme and already exists at Hindhead. This road will fill the small gap between the M4 and the M5 in Gloucestershire."
Members of the Public/Businesses
Martin McDowell
"As an experienced geotechnical engineer who has worked on a range of highways schemes in a professional capacity, I intend to make submissions on aspects of the scheme that appear technically deficient or potentially dangerous, comment on the environmental impacts posed by the scheme - including those of a geological nature - and provide an overview of the path taken to get to the current development proposal and whether alternative improvements have been missed."
Members of the Public/Businesses
Helen Brittain
"I plan to support the application as a resident who lives on the existing route of the road"
Members of the Public/Businesses
Stephen Mendel
"My family own [redacted] which will be decimated by the proposed A417 road scheme. I represent the family and my father Mr John Mendel who owns [redacted]. Whilst we do not support the proposed route due to the impact on the Cotswold countryside and due to the impact on our farm and lives we do recognise that a solution to the "missing link" is desperately needed. We have already been significantly impacted, both financially & mentally by the significant challenges we have had since the scheme was proposed in 2018. We were weeks away from exchanging on the sale of the farm house at [redacted] as my elderly parents could no longer safely live in the house due to their age & ailments. As soon as the proposed road scheme was announced the property sale collapsed and the property has remained empty and unsalable ever since - we have been working with Highways England on Discretionary Purchase applications since then and I have had to fund the purchase of my father's retirement flat until a solution to the farm house sale can be agreed. Our representation re the planning application is for two reasons: (1) Some of our farm land proposed to be acquired is not for the construction of the road itself but has been earmarked as "environmental offset". This land grab further decimates the farm and is not a requirement to enable the road as designed to be delivered. It is also taking land which is already in a Natural England environmental scheme and claiming it as new environmental offset. We have been forced to include this land in the Discretionary Purchase negotiations for the house sale even though it is not required to deliver the route and is not land we wish to sell. (2) Despite requests during the consultation periods and in e-mails to HE and their representatives we were NOT consulted or told about changes to rights of ways over the property. A new BOAT (byway open to all traffic) has been created in agreement with Gloucestershire County Council and the Horse Riding, Walking and Cycling Technical Group, which includes the Ramblers Association and the British Horse Society BUT the decisions were made without any input or discussion with ourselves and we were not told of or shown the new plans until after the decision had been made. We thus had no ability to challenge or offer views on the plans during consultation. These plans for a new BOAT are claimed to link to an existing motorised track - this does not show on property deeds or any current or historic maps and we have not been provided with any proof that there is an existing motorised track. Additionally the proposed new BOAT runs meters from an existing public right of way walking route and no consideration has been given to combine the routes. We contest the safety of the proposed BOAT, we reject its need and challenge the additional land it will take which is also land included on the HEFER register (Historic Environment Farm Environment Record) which was NOT taken into consideration by Highways England. Whilst we have no objection to walkers, ramblers and horse riders we do object to adding a motorised track across historic countryside and the encouragement of 4x4 off-road drivers, quad bikes and cross bikes which further damage the countryside and cause upset to walkers and horse riders. The route then joins main roads and is an added safety concern. We ask for a full review of these 2 points and challenge the need & impact of the new proposed BOAT. Thank you."
Non-Statutory Organisations
response has attachments
Gateley Hamer on behalf of National Star Foundation
"This representation has been produced on behalf of National Star Foundation (NS). NS is broadly supportive of the proposed Highways England (HE) A417 Missing Link scheme, however, there are a number of issues which still need to be addressed where, despite engagement with Highways England and its representatives, NS have not been given satisfactory assurances Equality Impact Assessment (EqIA) A EqIA has been produced by ARUP for HE, however, it has not taken the work of NS, its services and its service users (with protected characteristics) into account. No contact was made with the charity or its service users by the report’s authors in the drafting of the report and it is clear from the report that it does not address any of NS’s unique circumstances. Traffic NS have been informed that traffic levels will increase on the Leckhampton Hill, A436 and A417 during and post construction. NS requirements for unimpeded access to the Ullenwood site for its staff, students, service users, suppliers and emergency vehicles must be fully considered as part of the Construction Traffic Management Plan (CTMP) for the scheme. NS seeks and must have assurances from HE ahead of the contract award that the CTMP will be developed in conjunction with an appointed contractor to ensure the contractor is aware of the NS’s unique requirements and the critical importance of ensuring ease of access. Failure to adequately address this issue could lead to placements being unsustainable, students and service users being deprived access to their provision and staffing levels not being met. Noise and Air Quality The HE/ARUP project team have not yet confirmed that there would be no adverse impact on NS due to scheme noise and air quality. NS is home to students with sensitive issues. NS is concerned that the campus sits in a natural valley north east of the main works and could suffer adversely due to the works. There are concerns that the prevailing south westerly wind could funnel noise and pollution down the valley towards the college and impact on the users of its residential and day student accommodation, recreational access to its grounds and income generation from its glamping site. Disabled Access to Scheme Enhancements NS have previously discussed with Michael Goddard the potential for creating a route from NS to Crickley Hill without a vehicle. NS is still awaiting comments or commitments from HE. Land take and land Interest HE have now confirmed that there will not be a need for a permanent drainage easement across the remaining land (which NS was strongly opposed to) after the proposed land take. There are however ongoing discussions regarding a temporary easement proposed during the construction works. HE have failed to provide any reasoning for the temporary easement or provide any assessment of how the water will be dealt with at the outfall of the temporary drainage in the middle of the charity’s site at the golf course car park."
Other Statutory Consultees
response has attachments
Natural England
"I have been asked in my role as Wildlife Adviser for Natural England to comment on the bat and badger mitigation and compensation provided as well as the surveys carried out."
Other Statutory Consultees
The Coal Authority
"Further to the notification received from Highways England of 22 July 2021, I have checked the location plan against the information held by the Coal Authority and can confirm that the area lies outside of the defined coalfield. Accordingly, the Coal Authority has no specific comments / observations to make on this project. In the spirit of efficiency of resources and proportionality, it will not be necessary for you to consult the Coal Authority at any future stages of the scheme. This letter can be used as evidence for the legal and procedural consultation requirements. Please do not hesitate to contact me if you would like to discuss this matter further."
Members of the Public/Businesses
David Allen John Field
"Drainage Pipeline – since the original plans it has been agreed at numerous meetings that there are better options for all parties to use HE land as much as possible along the South side and only access our land on the furthest West side for minimal impact. West Boundary – In 1990s when the 1st development of A417 was carried out, HE wrongly took our land and we require this land to be returned to us and restored to its original state – HE have confirmed the land is ours in previous meetings Layby – HE has confirmed that this is not a compulsory requirement, and we feel that the proposal will be of detriment to our home and cause security issues for us. HE owns land next to ours that could be used. HE do not need to compulsory purchase our land and put our home at risk and blemish what is now a beautiful green open space. Security – The boundary of our property on the South aspect is an issue that is yet to be resolved as we are only meters from what is the current A417 Planting – in 1990s when planting was done for the original scheme it was not done as agreed in meetings with David’s now deceased father. It has never been maintained and the tree growth has taken over our property and encased us with giant trees, such that we no longer have a view or outlook. The South side has now had some work after many years of asking HE to take responsibility, but further work is outstanding. They have agreed verbally that they have failed in the care of this area. Map Ref 845/1 – Our bottom ground has an access slab; HE wants to compulsory purchase this slab but in doing so we lose total control over our access to our field. Under our current ownership we have control over access to the livestock in the field, but if HE owns the slab, we lose control over access and parking. This has already been an issue in the area and will only get worse if we do not have the power over our own access to the livestock. It is not necessary for HE to own this land. Communication – This has not been forthcoming as the project has developed. Particularly the lack of Minutes if Meetings to confirm representations made. On numerous communications these have been requested dating back to end if 2018 and we have been told this will be sorted out, but to date we have still not received copies of numerous meetings."
Members of the Public/Businesses
Patricia Drury
"This road will cut through two SSSIs, three archaeological sites, and the area of outstanding natural beauty. It will add almost 1 million tonnes of carbon to the atmosphere."
Members of the Public/Businesses
Rhianna Drury
"This road will contribute almost a million tonnes of additional carbon. It's going to cut through and irreversibly damage two Sssis and archaeological sites."
Members of the Public/Businesses
John Franklin
"The application is inappropriate at a time when all countries must strive to reduce CO2 for the sake of maintaining a world that is still liveable for ourselves, our children and grandchildren. The application would generate considerable CO2 during construction, lead to higher average traffic speeds (which increase CO2 emissions) and result in induced traffic that would further exacerbate the difficulty of meeting our climate commitments to reduce CO2. The Government's Committee on Climate Change calls for a reduction in traffic, not an increase, as do most experts. The application will do the opposite. I also object to the considerable destruction of the natural environment in an area of Outstanding Natural Beauty. The money committed to this scheme could be much better used to promote sustainable travel."
Members of the Public/Businesses
Emma Catherine Mary Bullard
"This proposed road will increase carbon emissions. We should stop all road building to tackle the climate emergency, as well as reducing emissions from transport by reducing vehicle mileage. Switching to electric vehicles will not be sufficient. Carbon is still emittied from the manufacture of electric vehicles and from electricity supply which is not fully decarbonised. In addition this proposed road will damage the natural environment and historical features. We are dealing with an ecological as well as a climate emergency and sites that are important for biodiversity, especially SSSIs, shoud be protected."
Parish Councils
Julian Lavington on behalf of Cowley and Birdlip Parish Council
"The Parish Council has been campaigning for 30 years for a solution to the 'Missing Link', being the legacy left by the original bypass to the village of Birdlip that opened in the late 1980's. The village of Birdlip is the settlement that is most impacted by the current route of the A417. It has been plagued with rat running traffic that use the B4070 as a 'cut through' due to the congestion of traffic on the A417. Many Birdlip villagers have also been impacted directly or indirectly by the frequent accidents, deaths and casualties that are a consequence of the accident blackspot. The Parish Council supports the repurposing of the A417 and the creation of what will become known as the “Air Balloon Way’. This aspect of the scheme has already been supported by the Parish Council in previous consultations and the ability to create a public amenity for walkers, cyclists and horse riders received much support from parishioners in the previous Highways England public consultation. The Parish Council does note, however that there is opposition by some parishioners to the scheme who feel that the area should be re-wilded. Therefore, should following this consultation, Highways England decide not to re-purpose the A417 or remove or delay this aspect of the project due to financial pressures, the Parish Council would prefer the route to be returned to farm land rather than being left as a redundant carriageway as this could result in rat-running or anti-social behaviour. The Parish Council is mindful that the new Air Balloon Way is likely to be a popular local amenity and therefore requests that careful consideration is given to all the other public rights of way that will need to be used to access the new Air Balloon Way to ensure that they are suitable to accommodate the inevitable increased use and the project needs to make funds available to improve the adjacent footpaths and stiles outside of the red-line boundary as necessary. The Parish Council would like to be involved in discussions as to the future plans for the maintenance and administration of the Air Balloon Way, the proposed new parking facilities and the increased use of the public rights of way in general. Many parishioners, particularly those living in Birdlip, support the scheme as for many decades they have suffered from the anti-social sexual behaviour which is centred on Barrow Wake but also frequently spills over into the village itself and near to the village school. The Parish Council believes that the rerouting of the B47070 as proposed will discourage this behaviour as the Barrow Wake view point will be less remote from the main road and that the proximity to the repurposed A417 will encourage families and walkers to use the view point and reclaim this historic area to be used for the purpose it has always been intended. Finally the scheme needs to consider its impact on the connecting roads which are outside the 'red line' boundary. For example the speed of traffic that uses the B4070 is excessive and is a hazard to local residents and the village school in Birdlip. The Parish Council is keen that legacy issued such as these are considered as part of the scheme."
Members of the Public/Businesses
Julian Lavington
"My wife and I own and reside in [redacted] We strongly support the 'Missing Link' proposal and the repurposing of the existing A417. However we believe that the repurposing of the A417 needs to dress a legacy issue with regard to drainage and changes in ground water that have impacted our property when the single carriage way cuttings and embankments were constructed in the 1980's for the line of the A417 adjoiningn our property. Prior to the construction of the original 'Birdlip Bypass' ground water that drained from the high ground at the top of Parsons Pitch surfaced at a communal fresh water spring on our property. This spring appears on maps from the 19th century and we have a covenant to allow access to our neighbours to obtain water. During the construction of the original A417 the land was regraded and woodland was removed to construct cuttings and embankments. The result of the above is that the historical spring has dried up and the course of the ground water has changed. The current position is that we now have to continuously pump ground water away from our property to protect our cottage. Also many areas of our lawn and back garden becomes water logged in the winter months or during period of heavy or consistent rain. We request that during the works to repurpose the existing route of the A417 and to create the new Air Balloon Way that work is carried out to correct the situation described above perhaps by installing addtional land drainage."
Members of the Public/Businesses
Stephen Prowse
"I think Alok needs to have a word with Grant and the the extra 40M+ negative carbon impact RIS2 will have. “The world urgently needs a clear and unambiguous commitment to the 1.5 degree goal of the Paris Agreement from all G20 nations”, António Guterres The UN chief reminded that science indicates that to meet that ‘ambitious, yet achievable goal’, the world must achieve carbon neutrality before 2050 and cut dangerous greenhouse gas emissions by 45 % by 2030 from 2010 levels. “But we are way off track”, he warned. Highways England guilty of Ecoside pushing ahead with RIS2 without full environmental impact studies."
Other Statutory Consultees
Forestry Commission
"I represent the Forestry Commission and wish to ensure that we are informed at all stages of this development as it is immediately adjacent to designated Ancient Woodland and the site contains trees which are to be felled which may potentially be considered Veteran Trees. We are the non-statutory consultee for proposals which affect Ancient Woodland and Veteran Trees. We would also express an opinion on the plans for compensatory tree planning to ensure that it is compliant with the UK Forest Standard, appropriate and shown to provide adequate net biodiversity gain"
Members of the Public/Businesses
Plainview Planning Ltd
"Issues that we wish to comment on: Economic benefit to Cirencester (Economic / Social impact) Dust suppression during construction (Social / Environmental impact) Length of construction programme (Social impact) Construction over-run contingencies (Social impact) Ensure no downtime to gigaclear network (Social impact)"
Other Statutory Consultees
response has attachments
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. PHE notes that we have replied to earlier consultations as listed below and this response should be read in conjunction with that earlier correspondence: Request for Scoping Opinion: 16th May 2019 Response to Section 42 Consultation: 6th November 2019 Supplementary Statutory Consultation: 12th November 2020 PHE has 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
response has attachments
Converse Law on behalf of Mr David Allen John Field
"There has been significant discussions with Highways England. HE are aware we support the basic principle of the Scheme. However Highways England have failed to put in writing their proposals to mitigate the impact on us despite promising much. They have also refused to let us have minutes of our meetings and we are frightened that they will renege on promises. If they don't write it down did they say it? Representations have been made in relation to 1. The alignment of the Pipeline adjacent to the Western Boundary 2. The return of land taken by Highways England in the early 1990's against a representation they would return it (it has not been returned) and the cutting back of the trees on the Western Boundary. 3. The offer of a small area of land which Gloucester County Council do not want to maintain 4. The Location of the layby to the South of our land. This is NOT compulsory and it has been promised that this would be looked at again as the layby could be put further up the road on Highway England/Gloucestershire County Council land 5. The extent specification and nature of the boundary following the works on the south side of our land 6 The obligation that all future planting will be kept below 3 metres - as was promised (and this promise was never fulfilled) in the early 1990's when the road was put in. 7. The Triangle of Land to the east has been offered to us on a pre-emptive basis but far better would be to put the layby (clause 4 above) there. The access to our Bottom Ground is to be maintained The biggest issue is the verbal promises made not followed through despite promises of investigations/minutes and meetings. This form does not allow us to upload our detailed summary. Can you e-mail acknowledgement and we will lodge the summary with our reply."
Non-Statutory Organisations
British Horse Society
"I am representing the British Horse Society as Access Field Officer for the South West. My remit is for access issues for equestrians. I have filled out the form and would like the BHS to be included to argue concerns for equestrian access. Where the BHS is in agreement is covered in the Statement of Common Ground, which I added my name as a signatory on behalf of the BHS. Where I am in disagreement – or should I say, where I believe greater account of access issues need to be made are in the area of bridleway Coberley 10 and the road linking back from the Air Balloon roundabout towards the Leckhampton Hill road past the Star College where there needs to be additional consideration for equestrians. In addition there are issues around Shab Hill which need resolving which have been previously raised by both the BHS and Ralph Hampton."
Members of the Public/Businesses
Chris Mather
"I still believe just widening the current route is more cost effective to the environment. In the long term vehicles will be electric or H2 anyway. If this section were just to follow the current route with widening, removal of the roundabouts and some smoothing of bends, and was limited to 40, 50 (or 60 mph) because of the remaining acuteness of the bends…this would still enable flow - and the precedent is already set in several places in the country where we have permanent low level speed restrictions in place on motorways/dual carriageways. Spend the money INSTEAD on getting vehicles non pollutant or indeed getting vehicles OFF the road. This is an excessive amount of money - that could be better spent- for little ultimate gain to noise or air pollution (WE ARE GOING to be ELECTRIC or H2 anyway!) and at the same time so DAMAGING to such AONB. The whole plan is cumbersome and unnecessarily complicated. Just widen and improve and accept a slightly lesser outcome!"
Members of the Public/Businesses
Mr L D Griffin
"As a resident of Cowley and although I have noted that some worthwhile changes have already been made to mitigate my concerns as it stands now, I nevertheless still need to be kept informed and to voice my opinion on what still appears to be an unfolding situation yet to be finalised, even to the extent of the re- routing of the Link in the first place. I don't consider the Link to be the finished article or the done thing and as such need to voice my opinion."
Members of the Public/Businesses
Cerys Mather
"I OBJECT with Route 30 because it is the most expensive option with little gain from cheaper and less disruptive options (to the landscape, villages and villagers). Route 30 will result in irrevrisble damage and disruption to local villages/villagers, roads, wildlife and businesses. Route 30 will result in devastation to our AONB and just as the Cotswolds has been earmarked for elevation to National Park status! NPPF makes it clear the Government’s commitment to protecting AONB’s and that “planning permission should be refused for major developments in these designated areas.....". Other PREFERRED route options, such as route 12, following the existing route of the A417, would do much less damage to the environment and communities. Preferred option, route 12, with reduced speed limits to 50 mph would also be good for the environment (NB lorries would be limited to less than 50mph on this stretch due to the severe inclines involved (either up or down!). Preferred option, route 12, would also improve safety, help journey times (maybe to a lesser extent), reduce rat-running, but have a huge impact on preserving our wildlife, landscape & footpaths. It will also impact on pollution (bearing in mind the Nation is going electric or hydrogen). Given COVID (new working ‘from home’), Brexit and proposed changes to the speed limit on the existing A417, the proposed route research is now OUT OF DATE and must be revisited to reflect current times and future times ie electric and hydrogen vehicles."
Parish Councils
Coberley Parish Council
"Coberley Parish Council (CPC) supports the proposed scheme as the optimum solution to provide the A417 Missing Link between Brockworth bypass and Cowley roundabout. CPC does however, have a number of concerns which require resolution. The proposed new Ullenwood Junction A436 roundabout Management of traffic flow and volumes at this roundabout: Concerns that congestion, back-up and hazards will continue at this new roundabout, affecting both the A436 in a westerly direction and the Leckhampton Hill Road, in a south-westerly direction. Although the roundabout will be free of the through-traffic on the A417, it will still be subject to the considerable, and growing, daily commuter traffic to/from Cheltenham and to/from Oxford/London direction. Flow from the A417 exit road into this roundabout is likely to be travelling faster, and more uninterrupted, than at present and hence, more hazardous to the traffic entering the roundabout from Leckhampton Hill Road CPC requests that a detailed study be carried out on projected traffic volumes and flows at the roundabout and that mitigating solutions are designed in. Proposed installation of attenuation tanks around the Ullenwood Junction raises concerns at visual impact on the landscape of the area. Also concern regarding potential flooding near this new roundabout, due to water flowing down the new link road from the Shab Hill Junction. Confirmation required that these attenuation tanks will mitigate any such problems. Leckhampton Hill Road (Believe this is now classified as C/377) a small country road, not designed to cope with the heavy commuter traffic which it currently experiences. (It includes hazardous cross roads with Ullenwood Manor Road and Greenway Lane, access to the popular Crickley Hill Country Park, a 27-dwelling property development at Ullenwood Court. Where this road enters the urban area of Cheltenham on Leckhampton Road, there is a busy junction with Old Bath Road, a new housing development at Leckhampton Views, two busy roundabouts at the Church Road/Charlton Lane and Norwood Inn. The whole route is lined with residential properties, with car parking on both sides of the road. It is not suitable for current, let alone, increased commuter traffic. A436 Likely increased speeds on the A436, due to freer flowing traffic, will create greater hazards for dwellings, other premises and the Cowley/Ullenwood crossroads on the A436. CPC requests that the current speed limit of 50 mph is reduced to 40 mph, particularly between east of Oxford Cottages and the new Ullenwood Junction roundabout. Ullenwood/Cowley cross roads on A436. Already a dangerous junction with poor visibility, there will be increased hazard, due to increased speeds and increase in traffic volumes over long term. With the proposed enhancement of the walking, cycling and horse-riding (WCH) facilities as part of the overall scheme, CPC envisages that there will be increased WCH traffic crossing the A436 at this crossroads. Measures must be put in place to slow traffic at this crossroads and to ensure safe crossing for WCH traffic and for motorised traffic either crossing or turning onto the A436. (reduced speed limit, traffic light control or a roundabout). CPC requests that thorough investigation of this crossroads junction is carried out and appropriate mitigating solutions implemented. Noise Pollution Concern about potential noise (and air) pollution due to the new road being nearer to the villages of Coberley, Cowley and Ullenwood. CPC requests that full studies are carried out on potential noise and air quality impact and that Highways England sets out proposals to mitigate noise pollution through the topography of the scheme (cuttings), road surfacing, landscaping (substantial tree-planting)."
Members of the Public/Businesses
Denys Mather
"I OBJECT with Route 30 because it is excessively expensive solution that produces minimal benefit for road users and huge irreparable disruption and damage to the landscape, villages and villagers. Route 30 will result in irreparable damage and disruption to local villages/villagers, roads, wildlife and businesses. Route 30 will result in irreversible devastation to our AONB. Other PREFERRED route options, such as route 12, following the existing route of the A417, would do much less damage to the environment and communities. Preferred option, route 12, with 50mph speed limits would be good for the environment and offer minimal disruption because lorries would, in any case, be unable to go above 50mph on this stretch due to the severe inclines. Preferred option, route 12, with widening, also improves safety, reduces rat-running, but will be better at preserving wildlife, landscape & public footpaths. It will also impact on pollution (bearing in mind the Nation is going electric or hydrogen). Given COVID (new working practises), Brexit and proposed changes to the speed limit on the existing A417, the proposed route research is now OUT OF DATE and must be revisited to reflect current times."
Members of the Public/Businesses
Meg Mather
"I OBJECT with Route 30 because it does not serve the best interests of our community or environment. Route 30 is an excessively expensive solution that produces only marginal gains for road users and maximum disruption to the landscape, villages and villagers. Route 30 will result in construction traffic that will cause irreparable damage and disruption to local villages/villagers, roads, wildlife and businesses. Route 30 will result in irreversible devastation to our AONB and just as the Cotswolds has been earmarked for elevation to National Park status! The National Planning Policy Framework (NPPF) makes it clear the Government’s commitment to protecting AONB’s and that “planning permission should be refused for major developments in these designated areas except in exceptional circumstances.” (Paragraph 176 & 177). Other PREFERRED route options, such as route 12, following the existing route of the A417, would do much less damage to the environment and our community. Preferred option, route 12, with reduced speed limits to 50 mph would be good for the environment and offer minimal disruption because lorries would, in any case, be unable to go above 50mph on this stretch due to the severe inclines involved (either going up or down!). Note: Heads of the Valleys Road construction reduced speed limit to 50mph from a previously agreed 70mph was advantageous for the environment [redacted] Preferred option, route 12, compared to option 30, would likewise improve safety, improve journey times (maybe to a slightly lesser extent), reduce rat-running through villages, but have a much greater impact on preserving our wildlife, our landscape & our treasured public footpaths, whilst having a similar impact on pollution (bearing in mind the Nation is going electric or hydrogen – potentially before this project ever gets fully completed!). Given COVID (new working practises eg ‘from home’), Brexit and proposed changes to the speed limit on the existing A417, the proposed route research is now OUT OF DATE and must be revisited to reflect current times. How much consideration has been given to vehicles going to electric or Hydrogen."
Local Authorities
Councillor Julia Judd
"I am particularly keen to be updated on progress on all aspects, including the Designated Funds. It is imperative that the South Gloucestershire/Cotswold representative of the Environment Agency is included as the disastrous flooding in Cirencester in late December 2020 was fed by water courses via the River Dunt which is fed from aquifers below ground from Seven Springs at Andoversford."
Parish Councils
Daglingworth Parish Council
"Daglingworth village abuts the A417 where it meets the Daglingworth Quarry junction. The Parish Council has already made representations during the design process and we are somewhat surprised that we have to revisit them for this procedure. However we are concerned about increased traffic on the A417 which will arise when the road is changed around Birdlip. The village suffer s from using our roads as a rat run from Stroud Road to A417 and the Council asked Highways England to carry out a traffic study to see how this rat running could be curtailed. We have received no feedback from this request. The Parish Council is also concerned that noise from the existing concrete road surface will increase to the detriment of those properties nearest the road as a result of increased traffic. We would want to see this section of road resurfaced with a more suitable material. The Parish Council is also concerned about surface water run off from the A417 which comes down Dowers Lanes into the village"
Members of the Public/Businesses
Sue Beynon
"Route 30 does not serve the best interests of the local community and the wider environment. The National planning policy framework (NPPF) refers to the government having a clear commitment to protecting ANOB’s and that “planning permission should be refused for major developments in these designated areas except in exceptional circumstances. Other route options would do much less damage to the environment such as route 12 which largely follows the line of the existing road. Construction traffic for the current proposed route will cause damage and disruption to our villagers, roads, wildlife and businesses"
Members of the Public/Businesses
Stuart Drysdale
"I am worried about the noise pollution affecting my home and others, in Cowley-and that effective mitigation will be minimised to reduce costs. It would appear that the preferred route 30 has crept closer to Cowley in this iteration. This may minimise ground work, but keeping it in a straighter line from the Cowley junction to stab hill i.e. further west and therefore lower on the side of the hill, would give more protection to the village from noise pollution exacerbated by the SWesterly prevailing wind. Excess spoil could always be used as a bund on the Cowley side of the new road with added benefit. Alternative 2 A436 link is preferred. Option 3 breaks through virgin AONB land -exposing the diverse wildlife (especially large mammals) to disruption of habitat and ongoing road hazard (as compared to alternative 2-which keeps the expanded road system in close proximity and minimises impact of parcelling up the countryside into road bound islands. Option 2 also links up directly with the well used Leckhampton Road."
Non-Statutory Organisations
Council for British Archaeology
"The Council for British Archaeology was founded in 1947. Its role is to champion public appreciation and understating of all aspects of archaeology and the historic environment, both terrestrial and maritime, and their contribution to national and local culture spanning all periods. Our membership is comprised of individuals and organisations that reflect the full range of academic, cultural, professional public and private bodies, engaged with archaeology and conservation of the historic environment at national regional and local levels. We made representations on this scheme in 2019 and 2020 and our principal concern remains the setting of Crickley Hill, a scheduled monument of national importance and its contribution to Cotswolds Area of Outstanding National Beauty. The scheme lies wholly within the Cotswolds National Landscape (AONB), and the contribution that the historic environment and cultural heritage make to the Areas’ natural beauty is a key consideration. We have the following concerns regarding its effects on parts of the historic environment: • The effects on the setting of heritage assets, again both in terms of harm and benefits of what is proposed, and missed opportunities for enhancement; • The effects of changes to the historic character of the area and how it is experienced and appreciated, not only both in terms of harm and benefits of what is proposed, but also missed opportunities to better achieve the statutory duty to have regard to enhancing the natural beauty of the Area of Outstanding Natural Beauty; • The effects on non-visible features in the landscape but are a fundamental resource for understanding and appreciating the history and development of the Area and past societies’ role in shaping it and how the natural resources of the area helped to shape those societies; • The effects that impinge on intangible aspects of the areas heritage, such as cultural associations, traditions, commemorative associations etc., that contribute to the value that people place on the historic character of the area or specific heritage assets. In our view the minimum requirements for a major infrastructure scheme in a National Landscape to be ‘landscape?led’ must treat landscape in this context as encompassing ‘natural beauty’ and archaeology, heritage and the historic environment. Our representation will state that in our opinion the current proposals fail to address adequately this key landscape impact and that the proposed landscape mitigation falls short of what is required to adequately retain the setting of Crickley Hill and the wider landscape importance of the AONB."
Members of the Public/Businesses
Edward Hollingworth
"I object to the present proposed route. 1. It is far to close to Cowley causing excessive noise and ugliness when it could be positioned more towards Birdlip which would not be to the detriment of Birdlip. 2. It will take too much land in this AONB. 3. Running the road nearer to the existing road would be cheaper. 4. A sharper bend at the Air Balloon would be acceptable with a 50 mph speed limit. 5.The proposed junction at the Air balloon roundabout is far too complicated. 6. An even better route would be to follow the existing road with a bridge over Nettleton Bottom and a gradual 50 mph bend at the Air Balloon."
Members of the Public/Businesses
Howard Mudd
"I do not believe that this is a “ landscape led scheme.” It will certainly not conserve and enhance the special character of the Cotswolds AONB as claimed . This option has been ill conceived and unsupported by the majority of the local community and important stakeholders such as the National Trust and Gloucestershire Wildlife Association. Whilst improvements do need to be made to the existing A417, Option 30 was never the best option as this will result in widespread destruction of an AONB ( soon to have National Park status). The damage to the landscape and the ecosystem it supports will be incalculable. It will also blight the area with noise, air and light pollution. This runs contrary to the Government's pledge to tackle climate change by reducing carbon emissions by 68% by 2030 and 78% by 2035. Option 12 , which would utilise the existing road , could achieve the desired aim of improving the flow of the A417 without the destruction of the AONB and the damage to the environment. I do not believe the newly proposed small tweaks will come anywhere close to mitigating the destruction and damage to the environment or address any of these key concerns. The proposed Cowley junction will enable traffic to come into the village via a long single, impassable lane. How is it proposed to ensure that it can be used by village inhabitants only? I would prefer no access from the A417 by this route as there are several other safer routes in and out of Cowley village. I am concerned about traffic, noise and air pollution throughout the construction period. How will this actually be controlled?"
Members of the Public/Businesses
Linda Turner
"The proposed route cuts through a huge area of an AONB, destroying the centuries old ecosystem and all the plant life and wildlife it supports. I believe with the impact of climate change we need to preserve our fragile environment not destroy it. This proposal will definitely not “enhance the environment.’ We need to invest in better public transport which is particularly poor in this area rather than encouraging reliance on travelling by car which is responsible for most of our air pollution. It will also cause significant noise pollution to the local community. This option was not supported at any stage by the local community or organisations such as The National Trust and Gloucestershire Wildlife Assoc. the preferred option was a tunnel, the second, option 12 was to widen the existing A417 which would be more cost effective and prevent the widespread damage to the environment. I understand that this option was discounted by the Highways Authority as it would entail a drop of speed on the Air Balloon corner. This lower speed for a very short section would actually improve the levels of air pollution. “The Welsh Government has announced that all new road building projects in Wales would be shelved and re-evaluated due to concerns about the environment.” A 50mph limit on a new £336m stretch of the A465 dual carriageway is to be imposed. Locally, the Cowley junction is to be “residents only” . This road through Cowley woods is a very long single track with no passing places. How will this be enforced in practice? I would propose removing this junction completely. There are only 3 properties on this lane and they can have access through the village."
Members of the Public/Businesses
Knight Frank on behalf of Mrs Alison Besterman
"A417 Missing Link Development Consent Order Representations Submitted by Knight Frank LLP on behalf of Mrs Alison Besterman [redacted] 1. Introduction [redacted] is a mixed arable and livestock farm (sheep) extending to 1,033.5 acres. The estate is in a ring fence with the existing A417 forming the southerly and westerly boundary of the holding. The estate includes over 100 acres of woodland. The topography has supported a shooting enterprise. The property has a main farmhouse, nine other residential properties and substantial agricultural buildings for arable and livestock production. All of the buildings and houses are centred on the hamlet of Stockwell. The property is owned and farmed by Mrs Alison Besterman. The proposed Scheme bisects the property from north to south leaving approximately one third of the farm, the houses and all of the buildings to the west (between the new road and the existing A417) with two thirds of the land severed to the east of the proposed road. The impact on the overall estate is devastating. Mrs Besterman is opposed to the proposed scheme on the basis that it is considered that the Route is not the best and most cost effective solution to the “missing link”. 2. The Route The preferred route (Option 30) ("the Route") is damaging to both [redacted], the AONB and wider environment. It is considered that Option12, following the current A417 line is much less damaging than the proposed Route. 3. Effect on the AONB It is considered that the project is damaging to the AONB protected landscape and that there are less damaging designs and routes which would better protect the overall landscape. 4. Weather effects It is considered that the Route is vulnerable to extreme weather conditions, such as fog and snow, and that the proposal may well be a danger to users in such conditions. 5. Stopping up of the Cowley Wood Lane The stopping up of Cowley Wood lane and its replacement with a public right of way is unnecessary and detrimental to [redacted] for two reasons; a. the removal of vehicular rights on the highway will increase the traffic on the Stockwell Lane from Cowley, damaging the hamlet of Stockwell and b. public highway [redacted] is used by the farm as access north/south. The closure of the highway to traffic will be detrimental to the farming business. 6. Parking on the former A417 The proposal to site a car park at the junction of the Stockwell Lane and the existing A417 is unnecessary as part of the scheme. It risks being appropriated for anti-social use. It is considered that all parking provided as part of the scheme should be located within the improve facilities at Barrow Wake. 7. Matters affecting [redacted] a. Removal of trees on the Stockwell Lane It is considered that the removal of 6 trees forming part of the avenue to the East of Stockwell is excessive and reduces the amenity of the Stockwell hamlet. The re-routed Stockwell lane should be designed to retain as many avenue trees as possible. b. Excessive land take The Scheme includes significant areas of agricultural land, for which there appears no reason. In particular: i) A strip of land south of Hardings Barn (ref 6/5f), ii) land between footpath 22 and the road cutting (ref 5/6d), iii) Land south west of the Stockwell Bridge (ref 5/3ae and 6/5d), iv) Land to the North West of the Stockwell Bridge (5/3ae), v) Land South East of Shab Hill Junction (ref 4/2p), vi) Land south of the Shah Hill lane (ref3/15a) The land take through [redacted] should be kept to a minimum. c. Effect on the Farming The position of the road takes a significant amount of land out of agricultural use close to the buildings. This land is important to the sheep enterprise, particularly at lambing. The separation of the buildings from the main area of the holding will have a detrimental effect on the ability to run the agricultural enterprises. d. Use of the farmyard as an access route for Highways England A permanent right of access is sought by Highways England through the farmyard ostensibly to access the Stockwell overbridge and balancing pond. This route is unacceptable as it limits the ability to use the yards and buildings. There are alternatives for Highways England from either Nettleton Bottom or the Cowley Lane junction which should be used in preference to imposing rights in the farmyard. e. Public Rights of way There are a number of changes to the rights of way network on [redacted]. There is concern over the following; i) the reclassification of footpath 22 to a restricted byway ii) the reclassification of footpath 21 to a bridleway iii) the diversion of restricted byway 26, when this route could follow the new Stockwell lane iv) The new link between the Shab Hill lane and the former A417 near the Barrow Wake underpass, which could be achieved on highway land without land acquisition. 8. Compensation arrangements Without prejudice to the objections above the parties are seeking to agree a position relating to a number of points above as well as a land acquisition and compensation agreement. 9. Reservations Mrs Besterman reserves the position to submit further information, issues and objections as part of the DCO process. Tim Broomhead MRICS FAAV Partner Knight Frank LLP UNIT 7 The Old Estate Yard, East Hendred Wantage OX12 8BE 27 August 2021"
Members of the Public/Businesses
Jonathan Higgs
"I wish to object to the building of the A417 ‘Missing Link’ on the grounds that no road extension should be built, that if it is built that it should be as close to the line of the current road as is possible, and that if it is built, along any route, that far more evidence is provided that the existing villages along the route will not suffer construction period traffic during the construction phase. Labelling the road ‘the missing link’ presupposes that its construction is inevitable. It isn’t. The Road should not be built at all The cost of the road is indefensible at any time, but never more so than in the period where there are so many competing demands for scarce resources as we recover from the pandemic. Housing, education, and health and national priorities, not road construction. If we are going to be spending money on our national infrastructure then spend it repairing existing roads, or in improving public transport. Road construction is counter to the national drive to reduce carbon emissions. All the evidence shows that increasing road construction increases car usage. Diesel car sales won’t be banned until 2030, and those that on the road in 2030 will stay on the road for another 10-15 years. That’s another 25 years of increased carbon emissions as a direct result of this road’s construction. The Government’s own National Planning Policy Framework Commits to protecting ANOB’s and gives assurances that ‘planning permission should be refused for major developments in these designated areas except in exceptional circumstances. The traffic situation on the A417 does not constitute exceptional circumstances. The problems that do exist on the A417 have been created by the construction of other roads over the years that have hastened more traffic onto this part of the A417. Building another road here, simply hastens the traffic onto the next bottleneck that will then be labelled ‘the missing link’. Each new piece of road simply creates the next problem. The Road should follow Route Option 12 The current proposed route (Option 30) will create significant environmental damage in the Cotswold Area of Outstanding Natural Beauty. It diverges massively from the existing route through the AONB. Populations of wild deer, hares, and a variety of flora will be irrecoverably damaged needlessly. Keeping as far as possible to the existing line of the A417 will reduce this impact. The advantages of Option 30 given by the published materials are not advantages of Option 30. Many, if not all, could equally apply to Option 12 and the Highways Department has failed to evidence why Option 30 is preferable. Surrounding villages cannot cope with construction traffic The Highways Department has failed to provide robust evidence as to how villages neighbouring the construction site will be protected from construction and general overflow traffic during the construction period. Our village of Cowley has narrow country lanes and damage to property and Health and Safety risk to residents and the general public who regularly walk the lanes will be massively increased during the construction period. The highways Department will be directly responsible for this."
Members of the Public/Businesses
Fisher German LLP on behalf of Alexander & Angell Ltd
"This representation is written on behalf of Alexander & Angell Ltd, Court Farm, Bentham Lane, Witcombe, Gloucestershire GL3 4UD, the freehold owner of the land with plot numbers 1/1, 1/1a, 1/3, 1/15, 1/15a and 1/16 in the above-mentioned Development Consent Order. This letter constitutes a formal objection to the application for a Compulsory Purchase Order over the land referred to above. Over the course of two years, we have been meeting with representatives of Highways England to discuss the design proposals and tried to reach a position of mutual agreement as to the works. These discussions have generally been frustrating for our clients as key points provided to us have been contradicted at subsequent meetings and requests for amendments to the scheme to deal with our clients’ concerns have not been addressed at subsequent meetings, new areas of concern being added to instead. As example of this, my clients’ were initially advised that whilst the land was to be used for a compound, such would not prevent the land being reinstated to good quality arable land, as it currently is, at the end of the scheme. Having subsequently designated part of the land for drainage pond and bunds, we were advised that such was due to it not being possible to restore the land to good quality arable land. When the pond was first drawn, it sat in the middle of the land. It was requested the pond be moved to the furthest corner but we were advised that this was not possible due to the lie of the land; subsequently the pond was moved due to local authority request for such. Later still, the land was designated for long term environmental mitigation as replacement calcareous grassland. Despite, after much chasing, receiving Highways’ paper on such on 16th August, our queries as to the why good quality agricultural land should be put to such use have not been adequately answered. Our clients’ grounds for objection are as follows; 1. We believe that Highways’ consultation with the landowner has, in this case as with others on this project, been defective. Highways appear to have undertaken a ‘box ticking’ exercise as to consulting with landowners rather than entering into meaningful discussions with them. 2. We do not object to the use of the land for a temporary compound but we object to the assumption that the land be incapable of reinstatement to productive arable use. Such appears to have guided Highways’ view as to this land being suitable for designating for environmental and drainage mitigation measures. Such is contrary to Government guidance on protection of productive agricultural land. 3. The use of the land as replacement calcareous grassland follows the above assumptions as to the land being available for such measures but the lay of the land is flat and does not follow the hilly nature of the land that Highways are trying to replace. Highways have stated that the Wildlife Trust’s Nature Recovery Map shows the land as being appropriate as lower priority for open habitat or woodland. In actual fact, barring a very small area to the east of the land, which is shown as ‘Wood, Low Priority’, all of the land is outside of the Wildlife Trusts designated areas. 4. An area of land nearest the road is shown as being required as a bat corridor. Whilst we do not object to such a designation, we believe that the width of such has been influenced by Highways’ assumption that the land will be available for mitigation measures and that such should be reduced to the minimum. The above objections have been raised directly with Highways England on previous occasions and have not been taken into account in the drafting of the Development Consent Order. In light of the above, we ask please that Highways be directed to meet the costs of objecting to the scheme. We reserve the right to amend these grounds and to raise further objections, should that prove necessary in due course."
Members of the Public/Businesses
Caroline Miller
"I have lived in Cowley village for 20 years. The prospect of an improvement to A417 has been on the cards for that whole period. The road clearly needs improvement to stop the bottleneck at the non dual carriageway section and to improve road safety. However schemes that have been considered previously, the tunnel and then expansion of the current road (route 12) would have respected and preserved the countryside. Option 30 came upon us out of the blue. I was shocked when I attended an event to share the current options with the public to discover this option which cuts through greenfield land very close to Cowley and if built will blight an area of outstanding natural beauty. The main argument cited for choosing it over option 12 was that option 12 would require a 55mph speed limit in the area near the current air balloon roundabout which would have an adverse cost to the economy. This is despite option 12 being cheaper to build. However, since this consultation, there has been a pandemic and the world has reset its priorities. I believe today option 12 would be picked. It is less damaging to the environment and the beautiful walks so many have discovered during the pandemic, cheaper to build, and car speed limits are going to reduce in the future anyway to reduce climate change. I urge that the choice of route is reconsidered in light of the new world we find ourselves in where people who live in this area would chose to protect the beautiful countryside rather than shave a couple of minutes off their journey. The enthusiasm for the A417 scheme from locals, MPs and the press is for the idea of improving the road per se, which clearly does need to happen, rather than for the choice of route 30. People are truly shocked when I tell them where the new road would go, as they assumed it would simply be an expansion of the current road."
Non-Statutory Organisations
Climate Emergency Policy and Planning (CEPP) (Climate Emergency Policy and Planning (CEPP) )
"Dr Andrew Boswell, Climate Emergency Planning and Policy As an independent environmental consultant specialising in climate science, policy, and law, I object to the A417 Missing Link scheme: A. Table 14-17 of the Environmental Statement shows the scheme emitting over 900,000tCO2e of additional carbon emissions into the Climate Emergency era. B. The absence of cumulative, and short, medium and long-term, impact assessment of carbon emissions renders the Environmental Statement inadequate under the EIA Regs, and subject to EIA Reg 20. C. The applicant’s carbon assessment does not reduce operational carbon emissions over the 60-year appraisal period, as required by the government’s Transport Decarbonisation Plan (TDP) for ambitious quantifiable carbon reductions in transport at the local level. D. In the critical 4th carbon budget (2023-2027), an additional 96,302 tCO2e will be emitted, and approximately a further 37,000tCO2e will be emitted in 2028-2030. These additional emissions fall in the period leading up to the UK international commitment, via its NDC under the Paris Agreement, to reduce emissions by 68% by 2030, creating a serious risk against the UK delivering on its NDC commitment by 2030. E. No carbon assessment of the scheme has been made against the period 2038-2049 when the UK is required legally to achieve net-zero, but the scheme is modelled to generate an enduring high-level of carbon emissions. Scientists are clear that a net-negative world, with massive extraction of CO2 is required urgently well before 2050. See the recent report from Climate Crisis Advisory Group, chaired by Professor Sir David King, former UK Government's Chief Scientific Advisor commentary of the IPCC 6th Assessment report “The final warning bell” at [redacted]. F. No assessment of the scheme has been made against the 36-year period 2050-2085, post the UK 2050 net-zero target when the scheme is modelled to emit infinitely greater emissions than the Government and CCC’s implied budget for the post net-zero era. The applicant has provided no indication of how these additional carbon emissions would be mitigated. This has a clear material impact on the ability of the UK to contribute to the global endeavour to stabilise global heating at 1.5oC, and it does not comply with the UK obligations under the Paris Agreement. G. CEPP do not accept that only comparing carbon emissions from the scheme against carbon budgets for the entire UK economy is a credible assessment method. It is a deliberate tactic to “loose the signal in the noise”, and it is antithetical to good science. H. Carbon emissions should be tested locally, regionally and nationally against the UK obligations under the Paris agreement including the UK’s Nationally Determined Contribution (NDC), the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), the revised NPPF 152 planning requirement to “radical reductions of greenhouse gas emissions”, the statutory duty on Highways England under the Infrastructure Act 2015 section 5(2) to have regard for the environment, and relevant local authority Environmental Policies."
Members of the Public/Businesses
Elizabeth Gaffer
"I live on [redacted] and have concerns about the following in relation to the A417 development: 1 Increased speed of traffic on the A436 Modelling for this project has already predicted an increase in the speed of traffic on the A436. This will create greater hazards for both residents and people using the area e.g. Barber wood, as well as wildlife living in the area of the A436. This could be mitigated by reducing the current speed limit of 50 mph to 30 mph, particularly between east of Oxford Cottages and the new Ullenwood Junction roundabout. 2 Increased volume of traffic on the A436 Modelling suggests that traffic volume will decrease on this road, but the developed A417 will attract more traffic from Oxford making the route more popular due to reduced congestion. 3 Noise pollution along the A436 As a result of increased speed and volume of traffic. 4 Danger at the Ullenwood/Cowley cross roads on A436. There will be increased hazard, due to increased speeds and increase in traffic volumes over long term. Mitigation if the scheme were to go ahead would be measures put in place to slow traffic at this crossroads and to ensure safe crossing for WCH traffic and for motorised traffic either crossing or turning onto the A436. 5 Environmental impact of the proposed new A417 scheme The development will result in a net loss of wildlife habitat and not a net gain, which is the ambition of emerging legislation. This is a pivotal scheme in the country and so should be setting an example. At a time when it is so widely acknowledged that natural spaces are more precious than ever, any new scheme should avoid increased impact on the most sensitive wildlife habitat. The road expansion increases severance and destruction within Crickley Hill and Barrow Wake SSSI. No buffer zone has been included in your latest proposal. Natural England’s standing advice states that “For ancient woodlands, you should have a buffer zone of at least 15 meters to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone”. E.g. impact of air pollution with this scheme where there is a significant increase in traffic. Mitigation, if the scheme were to go ahead, would be to implement this minimum buffer zone. There are ancient and veteran trees outlined in the PEIR report that will be lost or significantly damaged as a result of the scheme (T17, T19, T157, T159, T57, T126, T127, ATI no: 196380, ATI no: 14130 and 143988, T67, T90, T108, ATI no: 155073, T171, T172, T174, T190 and T205). This could be mitigated by all ancient and veteran trees within or adjacent to the site boundary should be retained in situ and provided with a root protection of 15 times the stem diameter or 5 meters beyond the crown if that's greater, in line with Natural England’s Standing Advice."
Non-Statutory Organisations
Gloucestershire Local Access Forum (GLAF) (Gloucestershire Local Access Forum (GLAF))
"The main concern of the GLAF is contained in the Appendix H - Statement of Common Ground with the Walking, Cycling and Horse riding Technical Working Group. 5.1.1 There is one principal matter that remains outstanding or not agreed between Highways England and some members of the WCH TWG. In summary this is: ? The need for the scheme to provide at least one additional crossing of the A417 between Bentham Lane and Grove Farm underpass, to restore severed, address obstructed, or improve fragmented PRoWs."
Non-Statutory Organisations
response has attachments
Gloucestershire Wildlife Trust
"Two GWT nature reserves are affected by the road scheme – Crickley Hill and Barrow Wake. These form single Site of Special Scientific Interest (SSSI) and a core component of Gloucestershire’s Nature Recovery Network (NRN). Crickley Hill is also a well-loved green space for local communities, providing access to nature for 190,000 visitors per year. GWT acknowledges the need for the scheme and that important design improvements have been made. Three key concerns remain, and further details will be provided in future representations. The scale of adverse impacts on biodiversity GWT questions whether the scale of adverse biodiversity impacts can be compensated by other benefits. This falls short of the shared landscape-led vision and the scheme design principle of ‘delivering substantially more benefits than negative impacts’. Demonstrative examples included • 21% of biodiversity and 54% of habitat receptors are significant adversely affected by construction, with 19% and 75% by operation. • Many impacts are permanent and several affect irreplaceable features. • According to Biodiversity Metric 2.0, the scheme will result in 20-25% net loss of biodiversity. These outcomes don’t support Highways England’s aims ‘to enhance the biodiversity value of land and therefore reduce impacts’ and ‘to achieve no net loss of biodiversity across the strategic road network by 2025’. There are clear Government policy drivers for better biodiversity outcomes and the Environment Bill will require NSIPs to deliver 10% BNG from 2023. The reversion of Barrow Wake car park to species-rich grassland is an important opportunity to reduce biodiversity loss that should be included in the scheme. Delivery & management of a high-risk mitigation strategy The commitment to creating substantial new priority habitat is welcomed, but it is a high-risk mitigation strategy. Establishing priority habitat of equivalent quality is not guaranteed and could take more than 30 years. Creation success is affected by many factors e.g., hydrology, soil fertility, pH, management, seed bank, which haven’t been assessed. GWT disagrees that the estimated time lag between destruction and replacement is reliable and poses no significant risk to biodiversity. The likelihood of failure to establish habitat must be assessed and a robust system for long-term management, monitoring and remediation developed in collaboration with the environmental stakeholders. Impact of recreational pressure on designated sites Access to nature is important but enhancing access at designated sites being degraded by recreation pressure must be avoided. The scheme acknowledges that enhanced access will increase visitor pressure on the Crickley Hill and Barrow Wake SSSI. Demand for biking on Crickley Hill is also demonstrated. GWT considers that this will have a moderate, nationally significant adverse impact on the SSSI, rather than a minor one. Current mitigation proposals are inadequate, the Air balloon Way is unlikely to mitigate pressure because it doesn’t provide a view. GWT disagrees that the evidence presented demonstrates no cumulative effect on important biodiversity receptors. Whilst accepting that LA 104 guidance is followed, this discounts adverse recreational pressure on designated sites from improved access and ~21,000 population increase within the ZOI and excludes impacts on SSSIs."
Members of the Public/Businesses
Hannah Dawson
"This is an AONB, this new road will be a blot on the landscape and has completely cut off villages from their friends and neighbours. We will no longer be able to access villages on the other side of the Road without travelling a circuitous and more dangerous route adding 4 to 5 miles to our journey, so much for this environmentally-led scheme. What a great white elephant politically this will be when this over developed road has a speed limit imposed in future legislation or results of weather conditions on a high point on too fast a road. This route was chosen because we were told it had to be a 70mph road and the developing and widening of the existing route would result in only 50mph. The slower route is more environmentally friendly and has less impact on the AONB. The proposed route will prejudice the creation of the Cotswold National Park. Many organisations like the National Trust, Wildlife Trust etc are against this scheme because of the environmental impact, so why are warnings not taken on board. This scheme has never been environmentally-led, an over developed road with environmental add ons to appease the public."
Members of the Public/Businesses
Hugh Piggott
"We live on [redacted] and have concerns about the impact of the new road layout following the removal of the Air Balloon roundabout. Residents on this stretch of road are already suffering from the speed of traffic when there are no tail backs from the roundabout but with the revised scheme this is predicted to get a lot worse. The traffic speed also increases the noise disturbance that we are suffering. We appreciate that this stretch of road is the responsibility of Gloucestershire Highways but it will be impacted by the Highways England scheme. We are seeking a reduction in the speed limit from 50mph to 40mph between east of Oxford Cottages and the new Ullenwood roundabout (junction with the Leckhampton Road). Discussions with a previous GCC Highways Manager indicated that this could be implemented if financed by the A417 Missing Link scheme. There are also concerns about the impact of diverted traffic whilst the construction works are taking place and we are not aware of any mitigation measures regarding this. Furthermore there are concerns about noise and air quality during the construction period."
Members of the Public/Businesses
Linda Dawson
"Unfortunately, this road is going through on the highest point of the AONB with no apparent thought that it will be an eyesore and seen for miles around with the consequence being that the Cotswolds will not get National Park status. Just expand what is already there. Safety seems to be one of the main reasons for this so-called improvement but there is still going to be multiple exits and entrances onto high speed roadways. This road will still be congested at times, still include steep gradients, be exposed to increased fog, wind and icy conditions which is prevalent in this area, so what is going to change? With climate change being a high priority, why are we over developing roads, destroying farmland and physically altering the ecosystem and probably at the extinction of species. The repurposing does not go far enough in an AONB and should be put back to its original state not look like a suburban park. Primarily, because you are not offsetting the current road and there would be two areas of development within the AONB. Also, two roads off the existing road to Birdlip have already been decommissioned, it would make far more sense to keep the existing A417 open for local traffic and a feeder road to Cheltenham. Cowley being the village nearest to the new road we asked Highways to come and speak to us, they ignored our request. The budget has already been cut and the route changed bringing it even closer to our village and we have no guarantees that any adverse effects will be mitigated."
Members of the Public/Businesses
Mr. R Goodwin
"I moved to Cowley in 1971 [redacted]. As an amateur naturalist I was immediately struck by the exceptional diversity of flora and fauna, especially birds, that the area possessed. As time went by I was able to turn my hobby into a part-time profession[redacted] In recognition of my work I became sound recordist of the year 4 times, won an international competition and was nominated for a BAFTA for my work on the sound track of a TV film, BUT THIS IS NOT ABOUT ME, THE POINT HERE IS THAT IS THAT MY ACHIEVEMENTS WERE ONLY MADE POSSIBLE BECAUSE OF THE ABUNDANT WILDLIFE THAT FLOURISHED IN THE SUPERB ANOB. 30 years ago there were more than 100 different species of birds, including some rare breeding species, but this has since declined by 30/40%, wild flowers are now the exception rather than the rule and consequently moths and butterflies have seen a dramatic decline in both variety and numbers: small mammal numbers have declined to the extent that many are now endangered. It is imperative that we protect our dwindling countryside because, if we don’t act now, many more species will be gone forever and our children and grandchildren will not have the pleasure that we have enjoyed. It is in our hands, and indeed our duty, to protect wildlife for future generations. Option 30 would be an ecological and environmental disaster, it is criminal to drive a new 4 lane highway through ancient woodland and virgin farmland with all the ancillary disturbance caused. Why has this travesty been chosen when, in Option 12, there is a route with 2 lanes already in place, with little need for land grab and the resultant costs and no need for 2 very expensive road bridges to connect the severed land of Stockwell Farm ? Whoever is behind this heinous decision has no respect for, or understanding of, the needs of the world and Government Policy in respect of the Environment and Climate Change"
Other Statutory Consultees
National Trust
"The National Trust is Europe’s largest conservation charity with more than five million members. Established over 125 years ago, its purpose and duty is to look after places of historic interest or of natural beauty for the benefit of the nation. The Trust also has the unique ability to declare that its land be held inalienably (inalienable land). Since 1935, the Trust has owned the freehold of part of Crickley Hill. The Trust also has a farm business tenancy with rights of access relating to those areas of the country park and land at Barrow Wake which are in freehold ownership of Gloucestershire Wildlife Trust (GWT). The Trust and GWT work in partnership as custodians of Crickley Hill, enabling visitors to enjoy this unique place with panoramic views across the Severn Valley, whilst protecting the history and natural environment of this special site. Crickley Hill lies on the western scarp within the Cotswolds National Landscape (CNL) and together with Barrow Wake, is a biological and geological Site of Special Scientific Interest (SSSI) lying on the predominantly oolitic Jurassic Limestone belt that stretches from the Dorset coast to Lincolnshire. It is nationally important due to its Iron-Age hill fort (a scheduled monument), with human activity dating back to 4500BC, limestone grassland, ancient woodland, and diverse wildlife. The Trust acknowledges the traffic and safety issues associated with the existing A417 and the pressing need to find the right solution. This unique landscape deserves a bespoke approach to ensure the mitigation hierarchy respects the significance of delivering an NSIP within the CNL. It is important that the road scheme is policy compliant, compatible with this valued landscape context, and delivered with utmost care. The Trust has engaged with Highways England regarding the proposed road scheme in order to understand the implications for Crickley Hill and its landscape setting, to minimise direct harm, visual impact and ensure there are beneficial outcomes for people, nature and the landscape. This is summarised in our draft Statement of Common Ground. The principal matters outstanding from the Trust’s perspective include 1) Highways England’s assessment of the predicted impact on Crickley Hill and Barrow Wake SSSI during construction and operation, 2) that a holistic approach should be taken for scheme mitigation that overlays cultural heritage, historic environment, and natural environment to understand the significance of the landscape and therefore, mitigation proportionate to the significance and 3) the approach to biodiversity net gain and delivering best possible outcomes for nature. Highways England has made positive strides towards designing a landscape-led solution, but there are still a number of outstanding matters the Trust will want examined and addressed through the DCO process. These relate to design detail, access, mitigation and enhancement, construction and long-term management. Finally, the Trust expects Highways England to demonstrate that the road scheme is compatible with the government’s commitments to combat climate change, adheres to all relevant legislation, policy and guidance for climate change and nature, and exhibits best practice including low carbon design and construction."
Members of the Public/Businesses
Petra Vogel
"The area of the proposed road is in the AONB of the Cotswolds, which the government's may shortly make a National Park. The acceptance of impact of this new route is thus contradictary and unacceptable within this context. Different solutions to the route should be considered, especially in light of recent moves to limit the growth of car use, pollution concerns and reduction of emissions to combat climate change. The route which gained approval after the first consultation was moved substantially nearer Cowley without any notification which invalidates the initial approval figures. Highways England admitted at consultation that they had actually not visited Cowley to assess the effect the proposals would have on the village and have provided little firm evidence that mitigations will be effective."
Members of the Public/Businesses
Thomas Wheeler
"There is a clear conflict between the Government’s policies on transport and climate change. On transport, they are promoting schemes such as this one which would destroy valuable wildlife habitat and carbon ‘sinks’ in the form of hedgerows and woodland. These schemes would also encourage the use of private cars by making car journeys easier and quicker, thereby increasing greenhouse gas emissions. The construction of new roads also involves massive greenhouse gas emissions for example from the machinery used to build the road and in the manufacture of the concrete/tarmac used for the road surface. On climate change, the Government has committed to reducing emissions by 78% by 2035 and to net-zero by 2050. Transport Secretary Grant Shapps has indicated that, as part of the necessary move to a low-carbon society, “we will use our cars less”. It is often argued that major roads need additional lanes to accommodate increasing traffic – however, as Grant Shapps indicated, decarbonisation requires a reduction in traffic. This removes any argument that additional capacity is needed; at best building this new road would be a waste of money and of our limited carbon budget. At worst it would induce additional traffic, meaning that the Government fails in its ambitions to reduce car use and greenhouse gas emissions, and I consider this to be the more-likely outcome of proceeding with this scheme. The Climate Change Committee has advised that the Government’s current policies are not sufficient to meet these targets. The Government will therefore have to “introduce more challenging measures” to avoid missing these objectives. It is my view that cancelling road expansion projects such as this will be required to achieve the necessary reduction in greenhouse gas emissions. I therefore object to this scheme in its entirety on the grounds that it would increase greenhouse gas emissions, both in the short and long term, is not consistent with the Government’s decarbonisation policies and will damage wildlife habitats. Since the Government’s decarbonisation commitments are enshrined in law, proceeding with this scheme is potentially unlawful and the project should therefore be terminated at the earliest possible opportunity."
Members of the Public/Businesses
Anju Ahuja
"I am Anju Ahuja, wife of Rahul Ahuja, [redacted]. We own the property which will be in the closest proximity to the proposed option 30 route for the A417 missing link. In conjunction with all the points made by Rahul in his representation, all of which I support, I would also like to add the following issues regarding the proposed scheme which I strongly oppose. 1) I appreciate that a solution is required here but it needs to be more balanced and considered. As an alternative, an extension of the current road into a dual carriageway which would not be as disruptive to the local environment and habitat. There is ample room on either side of the footprint of the current road. With a section of tunnel past the village of Birdlip, so as to address noise and pollution issues for those residents. The accident blackspots, namely the crossing at Birdlip can be controlled using traffic lights and the approach to the Air Balloon roundabout broadened out and converted to a safer junction. The inability for traffic to flow faster due to the curvature of the existing road is not a valid reason for not considering this option. The priority here should be to keep the traffic free flowing to alleviate the current congestion that is caused approaching the Air balloon round about and making that stretch safer. It is worth noting that despite this being identified as a black spot, no serious attempts have been made to warn the oncoming traffic, for example through the use of signage and road markings along the existing road. 2) Devaluation of property values in Cowley village. Evidence of this has already started to emerge from our interactions with established estate agents in the area. We have written confirmation of this. 3) I disagree that having a dual carriageway for this 3.4 mile stretch will add much to the economy of the region. Traffic projections for road projects tend to over-shoot in order to fit financing models as evident by real world examples such as the M6 Toll (financially restructured due to 50% of the actual traffic vs original traffic assumptions). While we acknowledge that this is a publicly funded project the same issues apply on the modelling assumptions. 4) Contrary to adding to the economy of the area, the construction of the road is in fact impacting Stockwell farm quite severely who as we understand it are opposed to the current scheme. Also, the village of Cowley is the location of Cowley Manor, a grade II listed historical building converted into a hotel which attracts visitors from far and wide to the area. 5) The construction of this road which aims to bring more and faster flowing traffic to the area in a time where extreme climate conditions are plaguing the world over is not going to take the nation any closer to its Paris Accord or any other environmental protection targets."
Members of the Public/Businesses
Charlotte A. Hobkirk-Capps
"Option 30, Alternative 3: My family and I object strongly to this 'alternative', as our house would be impossible to live in [redacted]. Unacceptable Noise Levels: Currently, the noise from the A436 is horrendous both day and night, with container trucks and other traffic creating a decibel level that is almost unbearable, with 50 tonne container trucks that smash/bang/crash continuously, exacerbated by a new 'lowered' drainage grid opposite our house, that I have complained about, and which has been ignored. Pollution Levels: The pollution is so bad from diesel container trucks that if we are in the garden, at times (esp. between 2.30-6.30pm daily, but also much of Fridays), the smell of diesel is so overwhelming, that we have to come indoors, for fear of what this pollution may be doing to our health.[redacted] Horn Blowing: Speeding vehicles and container trucks (which have considerably louder horns than cars) on the A436, blast their horns at vehicles attempting the treacherous turn from Ullenwood Manor Rd. Therefore, spending any leisure time in our garden is impossible. This blasting of horns happens so constantly, that the garden is practically unusable; the noise is deafening, and probably above noise guidelines? Vibration: My bedroom literally shakes when a container truck or lorry passes on the A436, and if two vehicles cross outside as the same time, the shock waves through this house carry through to my bed, and I am literally 'shaken' in bed, ranging from once every couple of minutes, perhaps, to once every few seconds. This is highly disturbing, and it is impossible to sleep through the night. Dangerous Driving: Any increase in traffic at this junction will make the regular accidents that occur almost weekly (many go unreported, and I have photographic proof & dates of unreported accidents) increasingly worse. The A436 is regularly closed due to accidents on this junction, and this is an unacceptable risk and disturbance for our family, not to mention damage to our fencing, which has by now been smashed into so many times, that it is broken & ruined. Drop in House Price: My house has had its Council Tax Band reduced from Band H to Band E! This is entirely due to the A436 and when I moved here, I successfully had the band reduced from Band F to Band E based on noise pollution. Compensation: If Alternative 3 is chosen, I shall be seeking considerable compensation for the impact this would have on the future price of Old Ullenwood Lodge, on the basis that nobody would ever wish to live here. A life here for a family would be a nightmare and unsafe for health. The current plans are unclear? If Alternative 3 entails having a junction on our corner, the pollution levels for this house would be worse than ever, with vehicles idling and the noise of 'pressure' from hydraulic brakes, a continual nuisance. There are alternatives that do not directly affect residents, making living here unbearable, and Alternative 3 should be removed from the proposal or modified, this time with consideration for residents."
Members of the Public/Businesses
Chris Allcorn
"I am extremely concerned on the impact to the village especially noise and additional pollution as the road is closer than the existing road. I am also concerned of the impact to the environment and wildlife. There is another route that I believe has less of an impact on the villages (option 12)"
Other Statutory Consultees
response has attachments
Cotswolds Conservation Board
"A417 MISSING LINK - RELEVANT REPRESENTATION (REFERENCE NO. TR010056) BACKGROUND The A417 Missing Link road scheme is located entirely within the Cotswolds Area of Outstanding Natural Beauty (AONB). The Cotswolds Conservation Board (‘the Board’) is an independent, statutory body that was established by Parliamentary Order in 2004. The Board has two statutory purposes: 1. To conserve and enhance the natural beauty of the Cotswolds Area of Outstanding Natural Beauty (AONB); 2. To increase the understanding and enjoyment by the public of the special qualities of the Cotswolds AONB. In furthering these two purposes, the Board also has a statutory duty to seek to foster the economic and social well-being of local communities within the Cotswolds AONB. The Board has long accepted that there is a need to solve the significant concerns of public safety (including users of the Cotswold Way National Trail), traffic congestion and vehicle emissions on the existing A417 – and we fully understand the need for a scheme that mitigates these concerns. The Board also accepts that the scheme can, realistically, only be accommodated within the Cotswolds AONB, so therefore the A417 Missing Link should be in support of our statutory purposes. The Board also acknowledges that Highway England’s consultation and engagement has been good, especially over the past 12-18 months where a series of collaborative sessions with other key environmental stakeholders has led to scheme adaptations and improvements. We have commitment from Highways England to continue these collaborative sessions to refine the detail design on key aspects of the scheme. LANDSCAPE-LED A vitally important aspect of the scheme is the landscape-led vision, design principles, objectives and sub-objectives developed and agreed between Highways England and key stakeholders, including the Board. The challenge is to understand whether or not the scheme delivers against these. In their supporting documents Highways England state that landscape-led means that ‘landscape is a primary consideration in every design decision that is taken’ and that ‘the proposals have been designed to meet the character of the surrounding area, rather than changing the landscape to fit the proposals’. Whilst we fully endorse these measures as components of a landscape-led approach, we consider that a fully landscape-led approach is one in which a proposed development would, on balance, be compatible with, and positively contribute to, the purpose of AONB designation. It is our belief that if the proposed scheme does not have substantially more benefits than negative impacts for the Cotswolds AONB then it is at risk of not fulfilling the schemes own design principles. Furthermore, in the Board’s opinion, past decisions about the scheme - when considering various options - would appear to have been budget-led rather than landscape-led. As examples, the following are extracts from ‘7.1-Case for the Scheme’: – ‘A tunnel option was discounted due to the estimated cost (£1 billion)’ - section 2.1.2. – ‘The tunnel options offered poor value for money’ - section 2.2.12 It is, however, clear that landscape has been taken into account when taking forward and designing Option 30 and that some amendments, e.g. changing the gradient on Crickley Hill has had benefits for landscape in reducing both the cutting width and the volume of spoil to be transported off site. KEY QUESTIONS When writing the Relevant Representation, the Board has considered four key questions: 1. WOULD THE SCHEME CONSERVE AND ENHANCE THE NATURAL BEAUTY OF THE AONB? We consider the balance of adverse and beneficial effects on the factors that contribute to the natural beauty of the Cotswolds AONB (when compared to the current baseline) to be as follows: • Landscape quality/character: net adverse effect, with some of these adverse effects potentially being significant. • Scenic quality/beauty: net adverse effect, with these adverse effects potentially being significant in some locations. • Relative tranquillity: net beneficial effect for both residents and users of public rights of way, particularly the Cotswold Way National Trail. • Dark skies: net neutral or minor beneficial effect. • Natural heritage: net beneficial effect, albeit with some significant adverse effects on a nationally important SSSI and on irreplaceable ancient woodland habitat. • Cultural heritage: net adverse effect, with some of these effects potentially being significant. Taking into account the great weight that should be given to landscape and scenic beauty, we believe it is important that we continue a positive dialogue with Highways England to find ways of mitigating these adverse effects. 2. WOULD THE SCHEME HELP TO PROMOTE THE UNDERSTANDING AND ENJOYMENT OF THE SPECIAL QUALITIES OF THE AONB? We consider that the scheme would provide a net beneficial effect on opportunities for open-air recreation and on the recreational experience. This is primarily due to the recreational use of the re-purposed A417 and the reductions in noise levels on the Cotswold Way National Trail. 3. ARE THERE BETTER ALTERNATIVE OPTIONS? Since the announcement of the preferred route in 2019, we have asked Highways England to consider a number of variations to this route. Highways England has recently provided two detailed reports on these suggested alternatives and we are in the process of reviewing these as part of the ongoing collaborative sessions, including updating the Statement of Common Ground document. We aim to provide a fuller response in the Written Representation. 4. DOES THE SCHEME MODERATE DETRIMENTAL EFFECTS ON THE ENVIRONMENT, LANDSCAPE AND RECREATIONAL OPPORTUNITIES TO THE EXTENT POSSIBLE/ PRACTICABLE? Through the collaborative workshops with Highways England and their consultants during 2020, it was clear that there was a willingness to find solutions to moderate detrimental effects of the current scheme. However, there is more work required to further mitigate adverse impacts and fully maximise the beneficial impacts – especially with regard to landscape and scenic beauty. In addition, the Board would expect Highways England to demonstrate that the road scheme is compatible with the government’s commitments to combat climate change, adhering to all relevant legislation and guidance for climate change and nature’s recovery. The Board will make further Written Representation/s during the Examination to expand on matters included within this Relevant Representation."
Members of the Public/Businesses
Edward Williams
"I strongly object to the option 30 route plan for the following reasons: The proposed option 30 route appears to contradict a fundamental criteria of the Governments National Planning Policy Framework for Environmental Objective I believe that there is able room and scope to improve and widen the majority of the existing road layout to accommodate a dual carriage way without tearing up unspoilt countryside, AONB’s, and historic landmarks. One of the implied benefits of option 30 is that the road will have a 70mph along its entirety rather than 50mph on Crickley Hill and the bend at the top. However, the Cotswold escarpment is subject to thick fog and sudden server weather events, this coupled with HGV’s which are legally restricted to 56mph and will probably be traveling at <30mph up the hill is an accident waiting to happen. Therefore, I feel that to pursue a design ideology that will destroy a large area of unspoilt countryside just to achieve a theoretical 70mph road is ill conceived and dangerous. I do not believe that Cowley village has been listened to or considered at all in this consultation process, on multiple occasions I have received conflicting information about how access into our village will be linked to the new road layout. The whole consultation process has been biased towards option 30 with disregard to the concerns of residents, environmentalists, The National Trust etc. (Ref National Trust 417 Consultation March 2018) I am naturally concerned about future road noise which can already be heard from the existing road. The noise survey that has been conducted was from Cowley Manor which is at the lowest and most sheltered part of the village, therefore I do not feel this will be reflective of the true impact on the majority of the village, especially for the residents that are much closer to the road and at a higher elevation. The road noise will have a large impact on property prices in the village which is currently unspoilt."
Members of the Public/Businesses
Elaine Batt
"I am registering interest against the proposed Route 30 and question why the current A419 isn’t widened as per Route 12 for cost, disruption, environmental, ecological and safety reasons. • The proposed Route 30 is in AONB and the Glover report proposes uplifting the Cotswolds to a National Park. The Government’s National Policy Framework paras 174-188 cites “Planning policies and decisions should contribute to and enhance the natural and local environment” including “when considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development 60 other than in exceptional circumstances”. Route 30 cannot be deemed as “exceptional circumstances” when the existing stretch of the A419 could be widened (or made into 2 separate carriage ways) thus eliminating the devastating impact of Route 30 cutting through beautiful AONB and destroying local farmland, plant and animal habitat. • The Government is legally obligated to achieve net zero emissions by 2050. It is my understanding that Route 12 is deemed an unsafe option because of traffic using it at 70mph. However, due to its elevation that route experiences heavy snow, fog and mist, which means that Route 12 speeds would have to be lowered to max 50mph much of the time. The proposed Route 30 is at a higher elevation, causing more risk of accidents in inclement weather, and the same need as Route 12 for lower speed limits. There is extensive evidence (demonstrated by the Welsh Govt) proving that 50-60pmh speed limits are safer and reduce emissions by at least 17%; and the UK Govt is trialling 50mph on specific road stretches for these reasons – so surely this is another argument for constructing Route 12 instead of Route 30 and keeping it at 50mph to reduce emissions of increased traffic volumes and improve safety? • How can Highways England ensure construction traffic will not use the single-track lanes in and around Cowley, particularly when local landowners don’t want construction traffic using their land for access and storage? And how will they stop other traffic using these narrow lanes as a cut-through when A419 traffic is diverted or held-up due to construction work? This raises huge safety concerns for local pets, children and residents who live, walk, cycle and horse-ride on these lanes; environmental pollution issues; and also the impact on the old stone cottages, many built in the 1800s and not built withstand the impact and vibrations of passing heavy / sustained traffic. • Cowley residents are already experiencing the impact of the proposed road on potential buyers put off buying homes due to the proposed road and at least 3 local estate agents have already have predicted Route 30 will knock significant value off their homes."
Other Statutory Consultees
response has attachments
Environment Agency
"The construction and operation of the road scheme could result in potential adverse direct effects on surface waterbody features and groundwater bodies. Please see the Environment Agency's (EA's) letter dated 01/09/21 ref SV/2021/111028/01-L01 for detailed comments. In summary: We welcome the Hydrogeological Impact Assessment (HIA); it has raised no showstopper concerns, and we agree with it in principle. We consider the HIA has now effectively satisfied our concerns under matters A4 (topographic divide) and A5 (dewatering and drainage) in the Matters to be Determined section of the Statement of Common Ground (SofCG). We also welcome the progress made on the gathering of baseline data, but we consider there are still gaps in field data evidence. We will require on-going liaison with Highways England (HE) and their consultants on the most up to date data gathering, results and interpretation, which will hopefully confirm the predictions made in the HIA. To this end, and given we still have queries over the on-going gathering of data beyond 31 August 2021, we wish to keep matter A1 (surface water and groundwater monitoring) within the ‘Matters to be Determined’ category at this stage. We have commented at length previously on various environmental matters associated with the proposed scheme. We continue to emphasise the need for appropriate mitigation and enhancement across a range of environmental factors. These matters, and in particular the impacts on ground and surface water that we have focused on in this Written Representation, will need to be carefully managed through the DCO process and via appropriate Requirements. To this end, we wish to keep matter A2 (tufa springs/tributary to Norman’s Brook/proposed drainage solutions) within the ‘Matters to be Determined’ category at this stage as these are still key parts of the scheme from the EA’s perspective, including in relation to any potential impacts on fish, watervole and otter. However, given the lack of ‘showstopper’ concerns in the HIA, we anticipate that HE are correct in their consideration that further opening up of the Crickley Hill Stream culvert is not essential mitigation as part of the project. Accordingly we are satisfied that matters A3 (landscape led approach/de-culverting of watercourses) and A6 (Crickley Hill Stream) no longer need to be in the Matters to be Determined section of the SofCG. Please note this is purely from the perspective of the EA’s focus on ground and surface water; other bodies such as Natural England and/or Gloucestershire Wildlife Trust may still consider that further such mitigation is required, and our position on this matter should not be seen as weakening or in contradiction to another organisation’s viewpoint. Indeed, as previously, we would refer you to the comments made by our partner organisations, including Natural England and Gloucestershire Wildlife Trust on general matters of ecology, and particularly in relation to biodiversity net gain. We would also reiterate our advice that additional enhancements can, and should, still be sought through HE’s Designated Funds process."
Members of the Public/Businesses
Fisher German LLP on behalf of FlyUp Limited
"This representation is written on behalf of FlyUp Limited, Simon Ruskin and Angela Ruskin [Redacted], the freehold owners and occupiers of the land with plot numbers 1/19, 1/19a, 1/19b, 1/19c, 1/19d, 1/19e, 1/19f, 1/19g, 1/19h, 1/19j, 1/19k, 1/19m, 1/19n and 1/27 (part) and as right holders in the land with plot numbers 1/1, 1/15 and 1/15a in the above mentioned Development Consent Order. This constitutes a formal objection to the application for a Compulsory Purchase Order over the land referred to above. Over the course of two years, we have been meeting with representatives of Highways England to discuss the design proposals and tried to reach a position of mutual agreement as to the works. These discussions have generally been frustrating for our clients as key points provided to us have been contradicted at subsequent meetings and requests for amendments to the scheme to deal with our clients’ concerns have in many cases not been addressed at subsequent meetings, new areas of concern being added to instead. As example of this, we have been asking for Highways’ clearly stated position as to provision of replacement buildings at the site since before Christmas. Such arrived on 23rd August (Highways’ representatives being aware that I was away on holiday week commencing 23rd August) leaving little time to avoid objection being submitted or for the contents of such to be incorporated into this objection. The response is muddled in that it clearly states that requirement for permanent buildings is not justified but makes two references to supporting permanent buildings. Our clients’ live and work [redacted] running a downhill bike centre, with uplift vehicle shuttle, indoor and outdoor dirt jumps, bike shop and café. Customer access to the site currently runs between the house and the A417, past the existing buildings to the car park. Customers have to pass the registration building to reach the uplift pick up, also passing the café and shop. This is important as there is an insurance requirement that all users of the site are paying customers and income is maximised by all elements of the business being in close proximity. Highways’ current plan is that the existing car park be used for construction works, with new car park being provided by the scheme to the west of the site away from the registration buildings, shop and café. Highways have offered to potentially pay the costs of temporary buildings at the car park location. The access road to the site would be diverted and, post-works, all traffic would pass behind the house with the A417 remaining to the front, though closer than before. The house would therefore become an island between two roadways. There is a long and difficult planning history to this site, the current planning use having been hard fought. [redacted] We have asked that Highways’ gain planning consent for permanent buildings as part of their scheme. If the replacement car park is only temporary, then my clients’ wish for the access road to be reinstated to between the house and the A417 post works for the amenity of the house. Unfortunately Highways’ appear confused as to the operational requirements of this business and the specific issues raised by their works. Our clients’ grounds for objection are as follows; 1. The existing business’ main constraint is car park space. If the replacement car park and buildings at the entrance to the site are only to be temporary, then the existing car park needs reinstating to its full size at the end of the works. Highways’ plans appear to require permanent occupation of part of the existing car park. The site will not practically work with new car park to the west of the site and the business operating out of the existing buildings to the east. Any temporary building/s at the site of the new car park need to be fit for purpose, providing reception, café and shop space. The shop needs to be secure for holding c.£150,000 of bike stock in an isolated rural location, with access being away from the house (unlike at present). There are two known local examples of similar sites being raided leading to the closure of businesses due to being unable to gain further insurance. In practice the bike shop needs to be on the first floor and of suitable secure construction. We believe that the best value for money answer to the above issues is to provide a permanent set of buildings at the site of the new car park. Highways have not agreed to such. 2. Provision of the above replacement buildings is clearly mitigation for the impact of the scheme. Despite this, Highways have refused to entertain the buildings being part of their scheme, initially quoting betterment. It is not clear why their providing funding for temporary buildings is allowable under betterment but their providing them themselves is not. In their email of 23rd August, they give a number of further reasons which, with suitable time to discuss pre-submission of this objection, could have been answered to enable Highways to include the buildings within their scheme. Our clients found the process of gaining planning for the current use highly stressful, the local council not being supportive of the scheme. They are wary of having to follow a similar process to gain right for buildings that should be part of Highways’ own brief. Their great concern is that, if planning is refused, Highways’ work will continue anyway, leading to closure of the business. If the buildings are part of Highways’ scheme, this is less likely to be the outcome. 3. Highways’ have designed the access road to be diverted from the front of the house to the rear. This is acceptable if all customer access is to permanently terminate at a car park to the west of the site, meaning that the only traffic past the house is personal traffic and the uplift vehicles. It is not acceptable for, post construction, all traffic to be routed to the rear of the house whilst the A417 remains to the front, closer than previously. Either the track should be re-routed to the front of the house post construction, or the car park and buildings should remain permanent to the west of the site as per objection point 1. 4. Highways have included in their application areas of permanent and temporary acquisition that will interfere with the existing bike tracks. Due to the layout of the land and the physical requirements to make such tracks work, their land take will likely reduce the viability of the site. We have not been provided with meaningful engagement as to this land take and the effect on the business. As we understand that much of the relevant land take is for planting, we have offered alternative land or for the planting to be undertaken by our clients by agreement. Such has not been progressed by Highways. The lack of reasonable engagement has led to it being very difficult for the business to plan for the future, leading to losses in advance of the DCO being confirmed. We believe that Highways should be liable for such as part of the compensation process. 5. Highways’ consultation and design to date have not taken account of our clients’ concerns and lead to very real prospect of the business being closed for the duration of the works. The nature of the industry, with a number of competing sites having appeared in the area after FlyUp had established themselves, means that a temporary closure would likely become a permanent one. The provision of permanent buildings within the scheme to provide practical replacement for those currently in use would deal with these concerns and likely be cheaper option to the taxpayer. Highways’ refusal to entertain such idea and leaving their formal response on these matters so late in the process has led to this objection. The above objections have been raised directly with Highways England on previous occasions and have not been taken into account in the drafting of the Development Consent Order. In light of the above, we ask please that Highways be directed to meet the costs of objecting to the scheme. We reserve the right to amend these grounds and to raise further objections, should that prove necessary in due course."
Members of the Public/Businesses
Hanne Lene Schierff
"As a local Norfolk citizen I object to the A417 Missing Link scheme on the following grounds: 1. Table 14-17 of the Environmental Statement shows the scheme emitting over 900,000tCO2e of additional carbon emissions into the Climate Emergency era. 2. The absence of cumulative, and short, medium and long-term, impact assessment of carbon emissions renders the Environmental Statement inadequate under the EIA Regs, and subject to EIA Reg 20. 3. The applicant’s carbon assessment does not reduce operational carbon emissions over the 60-year appraisal period, as required by the government’s Transport Decarbonisation Plan (TDP) for ambitious quantifiable carbon reductions in transport at the local level. 4. In the critical 4th carbon budget (2023-2027), an additional 96,302 tCO2e will be emitted, and approximately a further 37,000tCO2e will be emitted in 2028-2030. These additional emissions fall in the period leading up to the UK international commitment, via its NDC under the Paris Agreement, to reduce emissions by 68% by 2030, creating a serious risk against the UK delivering on its NDC commitment by 2030. 5. No carbon assessment of the scheme has been made against the period 2038-2049 when the UK is required legally to achieve net-zero, but the scheme is modelled to generate an enduring high-level of carbon emissions. Scientists are clear that a net-negative world, with massive extraction of CO2 is required urgently well before 2050. See the recent report from Climate Crisis Advisory Group, chaired by Professor Sir David King, former UK Government’s Chief Scientific Advisor commentary of the IPCC 6th Assessment report “The final warning bell” at [redacted] 6. No assessment of the scheme has been made against the 37-year period 2050-2086, post the UK 2050 net-zero target when the scheme is modelled to emit infinitely greater emissions than the Government and CCC’s implied budget for the post net-zero era. The applicant has provided no indication of how these additional carbon emissions would be mitigated. This has a clear material impact on the ability of the UK to contribute to the global endeavour to stabilise global heating at 1.5oC, and it does not comply with the UK obligations under the Paris Agreement. 7. CEPP do not accept that only comparing carbon emissions from the scheme against carbon budgets for the entire UK economy is a credible assessment method. It is antithetical to good science. 8. Carbon emissions should be tested locally, regionally and nationally against the UK obligations under the Paris agreement including the UK’s Nationally Determined Contribution (NDC), the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), the revised NPPF 152 planning requirement to “radical reductions of greenhouse gas emissions”, the statutory duty on Highways England under the Infrastructure Act 2015 section 5(2) to have regard for the environment, and relevant local authority Environmental Policies. 9. It is a well studied and proven fact that building more roads leads to more traffic and more CO2 emissions. Alternatives to increasing traffic volumes urgently need to be identified"
Members of the Public/Businesses
Jack Brenannd
"I am registering interest against the proposed Route 30 and question why the current A419 isn’t widened as per Route 12 for cost, disruption, environmental, ecological and safety reasons. • The proposed Route 30 is in AONB and the Glover report proposes uplifting the Cotswolds to a National Park. The Government’s National Policy Framework paras 174-188 cites “Planning policies and decisions should contribute to and enhance the natural and local environment” including “when considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development 60 other than in exceptional circumstances”. Route 30 cannot be deemed as “exceptional circumstances” when the existing stretch of the A419 could be widened (or made into 2 separate carriage ways) thus eliminating the devastating impact of Route 30 cutting through beautiful AONB and destroying local farmland, plant and animal habitat. • The Government is legally obligated to achieve net zero emissions by 2050. It is my understanding that Route 12 is deemed an unsafe option because of traffic using it at 70mph. However, due to its elevation that route experiences heavy snow, fog and mist, which means that Route 12 speeds would have to be lowered to max 50mph much of the time. The proposed Route 30 is at a higher elevation, causing more risk of accidents in inclement weather, and the same need as Route 12 for lower speed limits. There is extensive evidence (demonstrated by the Welsh Govt) proving that 50-60pmh speed limits are safer and reduce emissions by at least 17%; and the UK Govt is trialling 50mph on specific road stretches for these reasons – so surely this is another argument for constructing Route 12 instead of Route 30 and keeping it at 50mph to reduce emissions of increased traffic volumes and improve safety? • How can Highways England ensure construction traffic will not use the single-track lanes in and around Cowley, particularly when local landowners don’t want construction traffic using their land for access and storage? And how will they stop other traffic using these narrow lanes as a cut-through when A419 traffic is diverted or held-up due to construction work? This raises huge safety concerns for local pets, children and residents who live, walk, cycle and horse-ride on these lanes; environmental pollution issues; and also the impact on the old stone cottages, many built in the 1800s and not built withstand the impact and vibrations of passing heavy / sustained traffic. • Cowley residents are already experiencing the impact of the proposed road on potential buyers put off buying homes due to the proposed road and at least 3 local estate agents have already have predicted Route 30 will knock significant value off their homes."
Members of the Public/Businesses
James Hamilton
"The missing link on the A417 needs to be made much more considerate of the environment. The route 30 that is being pushed forward is not as environmentally friendly as the route 12. It interferes with valuable ancient farmland that need not be disturbed. The proposed slower speeds will alter the construction criteria of the road and this in turn will not help the interaction with wildlife or the best improvements to the current AONB. As the area has been put forward for National Park Status and a badly considered road development could impinge on this decision this plan should be revisited to ensure the best is achieved. As transport and communication change over the next decades this does not want to be an ill considered development that has failed to take on these issues and then becomes an expensive eyesore in the not so distant future."
Members of the Public/Businesses
Jane Williams
"We bought our family house in Cowley 5 years ago having consciously made a choice to raise our children in a beautiful, quiet, clean village and we are hugely concerned that the current option 30 plans are going to have a significant impact on our, and our children's, quality of life. The wildlife, beauty and quiet of Cowley is what makes it the village that it is and the proposed plans are going to destroy this for us. The noise pollution will be significant, not to mention the pollution that we will now be subjected to from the increased traffic, faster traffic and proximity of the traffic to our home. The area being proposed by option 30 is pristine, beautiful Cotswold countryside and it is a travesty the impact this potential road would have on that; not only aesthetically but also in terms of the vast biodiversity that is supported by this area. During the construction of the road, the usage of the Cowley village roads for both construction traffic and traffic finding alternative routes will increase significantly. As a mother of two young children, we use these roads daily for walks and this will almost put a complete end to that as there are no pavements, it simply will not be safe. I feel strongly as a village we have not been heard. Our community has chosen to live in these houses for the tranquillity, nature and sense of isolation and that is being destroyed if these plans go ahead."
Members of the Public/Businesses
Jason Pearce
"I am registering interest against the proposed Route 30 and question why the current A419 isn’t widened as per Route 12 for cost, disruption, environmental, ecological and safety reasons. • The proposed Route 30 is in AONB and the Glover report proposes uplifting the Cotswolds to a National Park. The Government’s National Policy Framework paras 174-188 cites “Planning policies and decisions should contribute to and enhance the natural and local environment” including “when considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development 60 other than in exceptional circumstances”. Route 30 cannot be deemed as “exceptional circumstances” when the existing stretch of the A419 could be widened (or made into 2 separate carriage ways) thus eliminating the devastating impact of Route 30 cutting through beautiful AONB and destroying local farmland, plant and animal habitat. • The Government is legally obligated to achieve net zero emissions by 2050. It is my understanding that Route 12 is deemed an unsafe option because of traffic using it at 70mph. However, due to its elevation that route experiences heavy snow, fog and mist, which means that Route 12 speeds would have to be lowered to max 50mph much of the time. The proposed Route 30 is at a higher elevation, causing more risk of accidents in inclement weather, and the same need as Route 12 for lower speed limits. There is extensive evidence (demonstrated by the Welsh Govt) proving that 50-60pmh speed limits are safer and reduce emissions by at least 17%; and the UK Govt is trialling 50mph on specific road stretches for these reasons – so surely this is another argument for constructing Route 12 instead of Route 30 and keeping it at 50mph to reduce emissions of increased traffic volumes and improve safety? • How can Highways England ensure construction traffic will not use the single-track lanes in and around Cowley, particularly when local landowners don’t want construction traffic using their land for access and storage? And how will they stop other traffic using these narrow lanes as a cut-through when A419 traffic is diverted or held-up due to construction work? This raises huge safety concerns for local pets, children and residents who live, walk, cycle and horse-ride on these lanes; environmental pollution issues; and also the impact on the old stone cottages, many built in the 1800s and not built withstand the impact and vibrations of passing heavy / sustained traffic. • Cowley residents are already experiencing the impact of the proposed road on potential buyers put off buying homes due to the proposed road and at least 3 local estate agents have already have predicted Route 30 will knock significant value off our homes."
Members of the Public/Businesses
Joanna Pearce
"I am registering interest against the proposed Route 30 and question why the current A419 isn’t widened as per Route 12 for cost, disruption, environmental, ecological and safety reasons. • The proposed Route 30 is in AONB and the Glover report proposes uplifting the Cotswolds to a National Park. The Government’s National Policy Framework paras 174-188 cites “Planning policies and decisions should contribute to and enhance the natural and local environment” including “when considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development 60 other than in exceptional circumstances”. Route 30 cannot be deemed as “exceptional circumstances” when the existing stretch of the A419 could be widened (or made into 2 separate carriage ways) thus eliminating the devastating impact of Route 30 cutting through beautiful AONB and destroying local farmland, plant and animal habitat. • The Government is legally obligated to achieve net zero emissions by 2050. It is my understanding that Route 12 is deemed an unsafe option because of traffic using it at 70mph. However, due to its elevation that route experiences heavy snow, fog and mist, which means that Route 12 speeds would have to be lowered to max 50mph much of the time. The proposed Route 30 is at a higher elevation, causing more risk of accidents in inclement weather, and the same need as Route 12 for lower speed limits. There is extensive evidence (demonstrated by the Welsh Govt) proving that 50-60pmh speed limits are safer and reduce emissions by at least 17%; and the UK Govt is trialling 50mph on specific road stretches for these reasons – so surely this is another argument for constructing Route 12 instead of Route 30 and keeping it at 50mph to reduce emissions of increased traffic volumes and improve safety? • How can Highways England ensure construction traffic will not use the single-track lanes in and around Cowley, particularly when local landowners don’t want construction traffic using their land for access and storage? And how will they stop other traffic using these narrow lanes as a cut-through when A419 traffic is diverted or held-up due to construction work? This raises huge safety concerns for local pets, children and residents who live, walk, cycle and horse-ride on these lanes; environmental pollution issues; and also the impact on the old stone cottages, many built in the 1800s and not built withstand the impact and vibrations of passing heavy / sustained traffic. • Cowley residents are already experiencing the impact of the proposed road on potential buyers put off buying homes due to the proposed road and at least 3 local estate agents have already have predicted Route 30 will knock significant value off our homes."
Members of the Public/Businesses
Laura Delport
"I strongly object to option 30. The damage to the countryside and loss of wildlife habitats will be massive. To turf up this area of outstanding natural beauty is criminal. This is the worse possible alternative for the A417 and I can no way understand how this area was allowed to be even considered as an option. The view from there is breathtaking and it is hugely popular with walkers and horse riders. We should be protecting what is left of these areas of outstanding natural beauty. Having this road in this location would have a huge negative effect on the landscape and the rural feeling. Local communities standard of living would also be effected with noise pollution and visual impact. Noise pollution would also have a negative impact on wildlife. I feel to have such a huge negative impact on this area for a more efficient and faster journey for commuters is wrong and struggle to understand why the existing road cannot be widened. I regularly use this road and feel to sit in traffic is a small price to pay in protecting our beautiful countryside."
Members of the Public/Businesses
Lorcan Knox
"I strongly oppose Option 30 for this scheme for the following reasons: ENVIRONMENT: The Climate Change Act commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050. The UK is committed to working with all countries and joining forces with civil society, companies and people on the frontline of climate change to inspire climate action ahead of COP26. This development goes against everything the Government will be trying to promote at COP26. I believe option 30 is the worst possible route for the environment. Cutting down trees and destroying grassland when we have stated government policy to invest and plant more trees to reduce carbon dioxide is contradictory and in contravention to the 2015 Conservative manifesto. The proposed scheme will result in a net loss of wildlife habitat. At a time when the importance of nature and outdoor green spaces has become clearer and more precious than ever, it is essential that the scheme avoids increased impact on the most sensitive wildlife habitat. ANOB: The National Planning Policy Framework (NPPF). The Government has a clear commitment to protecting ANOB’s and that “planning permission should be refused for major developments in these designated areas except in exceptional circumstances. ROAD HISTORY: The proposed route has been chosen to ensure traffic speed can be maintained at 70mph. I do not believe the extreme weather conditions that routinely affect the area during the winter have been taken into account and it is very likely that there will be many accidents due to the thick fog that routinely forms in this area. Heads of the Valleys Road construction have reduced the speed limit to 50mph from a previously agreed 70mph, with the clear environmental benefits. Option 12 would therefore be much better suited, keeping speeds in this very dangerous area down to 50mph. NATIONAL PARK STATUS. The Government have indicated that they are considering turning the Cotswolds, currently AONB, into a National Parks and the move would see them placed under more stringent planning regulations to protect landscapes across the area. This development would be a contradiction. NOISE. The impact of Option 30 on the village of Cowley has not been accessed properly. The recent Highways report ‘6.4 Environmental Statement Appendix 11.4 Assessment Locations and Noise Prediction Results’ does not even mention my property, which is one of the nearest properties in Cowley to the proposed route."
Members of the Public/Businesses
Mr Alistair Miller
"I object to option 30 A417 missing link for a number of reasons and urge that it is reconsidered. The objective of the road upgrade is to provide a dual carriageway route all the way from the M4 to the M5 without interruption in order to reduce traffic jams, journey times and accidents which are very frequent on the section in question. Considerations are that the section in questions goes through AONB and this should be preserved. In addition the impact of noise and pollution should be minimised for surrounding villages namely Birdlip and Cowley. These villages share a parish council and it has always been Birdlip's views that have been put forward by them and these conflict directly with those of Cowley which have not been fairly represented. Given that there is ample room to expand the current road, this is a much more favourable solution, as not only will it cause less destruction of the countryside and wildlife but also it cheaper to build. Option 12 should be revisited and adapted to work. The main argument against it was the speed limit needed on the sharp bend. Given that speed limits on all roads will need to be reduced in the future this should not be a deciding factor. In addition, sticking more closely to the current footprint of the road would mean the survival of Stockwell Farm and have a less detrimental effect on Cowley village in terms of noise and pollution. Since the original consultation we have had a pandemic which has changed the way people live dramatically. Given this shift in peoples priorities I urge you to reject this damaging plan and work on a new option more closely aligned to the existing road footprint."
Members of the Public/Businesses
Moore Allen & Innocent LLP on behalf of Mr I F Medlock
"1. The document "Case for the Scheme" surmises at 2.2.12 that the option of the Tunnel outperforms the surface options for many reasons, save cost. The Tunnel cost was estimated to be in excess of £500m. The build cost of the chosen scheme is already estimated at £440m, which could easily rise. Should the Tunnel option not be reconsidered? 2. Linked with above, the proposal creates a second scar through the AONB (after the original road). The Tunnel option would largely mitigate this. 3. The additional road is likely to disrupt bat, owl and other species feeding grounds. The bat report however is listed "confidential" and cannot be accessed. 4. The Land Plans sheet 2 of 6 advise that all of Mr Medlock's land to the north of the road will be permanently acquired. Why is this? The Environmental Masterplan sheet 8 of 25 shows that the majority of the area is grassland with occasional specimen trees planted. The land not utilised for the scheme should be returned to the affected landowner. 5. Environmental Masterplan sheet 8 of 25 shows a new PROW created. If the land is to be returned to the original owner, this creates an additional burden on the land. 6. If the new road scheme was not detrimental enough, General Arrangement Plan 2 of 6 shows a large compound is to be located on both acquired land and temporarily acquired land. We request this is re-sited. 7. There continues to be a lack of information provided to landowners affected by this scheme. With 453 documents to analysis, it is possible that further information affecting our clients landholding will have been missed. I have been asked to make a further representation to 20028999. 1. Our clients property must remain accessible at all times before, during and after the period of construction. 2. The dwelling must be properly protected from traffic noise and headlights (light pollution), both on the new road and any access roads or roundabouts. Appropriate bunds, baffles and screening must be designed to protect all affected residences, details of which is so far lacking in the submissions. This requirement extends to construction compounds too. 3. Appropriate security measures must be considered and agreed with the landowner in connection with this scheme."
Members of the Public/Businesses
Bruton Knowles on behalf of Mrs Patricia Lesley de Lisle Wells
"Bruton Knowles represent Mrs Patricia Lesley de Lisle Wells [redacted]. We would like to raise our client’s concerns with the proposals which have been raised previously in the consultation responses:- Our client proposes that additional bunding is provided to shield her home from the noise of the scheme. This includes a small section at the south-east boundary of the current land take, where the bund and planting can infill what would otherwise be land that is not practical to farm. As previously raised, we also request that the bund is extended to the south east corner of the field to shield from the noise that will be generated by the new road and Shab-Hill junction. Highways England intend to sever the existing access to the property and provide a new access off the Shab Hill junction. Such an access will need to be of sufficient width, gradient and no weight limits must be imposed on our client. In particular, the route design of the new access road would need to allow for articulated vehicles to pass and use Shab-Hill junction safely. Our client’s field currently enjoys access directly off the highway. The current proposal has the future field access coming off an access road to a neighbouring property. Our client is concerned as to the future ownership of the access road and requires confirmation, once the scheme has completed, that it will remain as public highway in perpetuity, with full and unfettered permanent rights of access directly on to the public highway granted to my client. The decision to install a new bridge over the road for the footpath has the potential to cause unnecessary disturbance and trespass on our client’s land. We therefore request that appropriate permanent measures are taken to prevent the public from entering our clients land. The class 5 highway that passes the end of our client’s drive is used as a rat-run by motorists avoiding traffic on the surrounding roads and this will only get worse during construction. This coupled with the new footpath entrance, gives weight to the argument for demoting this road to a restricted byway. We request that the project actively engages with the local councils on this matter."
Members of the Public/Businesses
Mrs Patricia Ward
"A417 Missing link I strongly oppose the option 30 I am a resident of Cowley and agree that something has to be done at Nettleton bottom which is the only stretch not dual carriageway Because of this many lives have been lost and delays occur at peak times But the extremely expensive plans being put forward are unnecessary only achieving a faster road The obvious solution has to be just widening it to dual carriageway at Nettleton Bottom Should you say yes to this plundering-of 200 acres of prime agricultural land through an extremely beautiful valley Then the existing A417 from Nettleton Bottom to the AirBalloon should be dug up and the land given back to agricultural use. They are cost cutting by saying they are leaving it for the reasons they give They have encouraged more traffic on this A road by signpostingLONDON on the M5 to come down the A417 which will cause more deaths at Nettleton Bottom-Presumably to support their hugely expensive plans They say that they want traffic to go FASTER Surely we should be encouraging SLOWER speeds which are more environmentally friendly in this area of outstanding beauty"
Members of the Public/Businesses
National Star Foundation
"National Star Foundation is registered charity, supporting people with disabilities, based at Ullenwood, immediately adjacent to the proposed A417 Missing Link. One of the charity’s largest operations is National Star College which provides education, personal development, therapies and care for young adults with a range of profound, severe and complex disabilities and associated medical and behavioural conditions, both on a day and residential basis. The main site at Ullenwood is at the heart of the charity’s activities and is a specialist hub for its wide range of services and activities. National Star (NS) employs over 1100 staff, providing specialist services for young people and adults with disabilities on a local, regional and national basis and is considered a centre of excellence. NS is broadly supportive of the Highways England (HE) A417 Missing Link scheme. However, there are a number of issues to be adequately addressed by HE. It is vital that NS is assured of the absolute continuity of its services to students and service users throughout the period of the construction phase of the works, without detriment or disturbance, or impact on its ability to operate and to be accessed. Equality Impact Assessment (EqIA) The EqIA has not adequately taken the work of NS and its service users (with protected characteristics) into account. The EqIA process did not engage with NS or its service users in the drafting of the report in order to appropriately assess the disproportionate and differential effect and impact of the scheme on those who rely on NS’s services. Traffic NS have been informed that traffic levels will increase on the Leckhampton Hill, A436 and A417 as a result of the scheme during and post construction. Due to the nature of service user’s disabilities, travel time to and from the Ullenwood site is critical. Delays can have significant impact on wellbeing and ability to access critical services. This relates to day students from Gloucestershire and surrounding counties and residential students accessing Ullenwood from accommodation in Cheltenham and Gloucester. NS requires unimpeded access for staff, students, service users, suppliers and emergency vehicles. Failure to adequately address the critical issue of ease of access could lead to placements being unsustainable, students and service users being deprived access to their provision and staffing levels not being met. Noise and Air Quality The project team have not confirmed that there would be no adverse impact on NS due to scheme noise and air quality. NS is home to disabled students with sensitive issues. There are concerns that the prevailing south westerly wind could funnel noise and pollution down the valley and impact on users and activities. Disabled Access to Scheme Enhancements NS have previously discussed the potential for creating a route from NS to Crickley Hill but are awaiting comments from HE. Land take and land Interest HE have failed to provide reasoning for the proposed drainage temporary easement or assessment of how the water will be dealt with at the outfall in the middle of the charity’s site."
Members of the Public/Businesses
Nicholas Reed
"I strongly oppose option 30 for the scheme and wish to make the following points: 1 - Environmental impact - Option 30 is the highest environmental impact, with unnecessary destruction of trees. This runs against the declared government policy of encouraging more trees. There will also be a significant destruction of wildlife habitats. The aims of improving traffic flow could be achieved by converting the current road to dual carriageway - there is plenty of space for this - without compromising the declared aims of govt policy and the Paris Accord. 2 - The villagers of Cowley have not yet had fair representation or consultation in this process. I would point out the local Parish Council is joint between Cowley and Birdlip, and has a conflict of interest therefore and doesn't represent Cowley views. 3 - One of the stated benefits of this proposition is safety given the number of accidents on the A417. However, many of those are on the stretch between The Air Balloon and Brockworth, and won't be improved by this scheme. In addition, there are other mechanisms to improve the safety of the road without this. 4 - Route 30 is unnecessarily destructive to Cowley and Stockwell, and more appropriate Route 12 is a far more appropriate routing,"
Members of the Public/Businesses
Pascale Gysi
"I very strongly oppose Option 30 for this scheme and my reasons are as follows: 1) Increase of Noise – we can already hear the current A417 which runs to the south of our house. The new proposed road will bring the road a lot closer to our house and as a dual carriageway on both that side and to the west of our house, therefore from two directions. Despite the deployment of quiet road surfaces the noise level will increase significantly and will have an impact on our lives and we believe the valuation of our house. The current A417 was built some twenty years ago and the Birdlip residents have been complaining about noise and air pollution levels ever since. Shifting the road towards Cowley in a larger format is just transferring the problem on to the village of Cowley, which cannot be the right solution. 2) Environmental Impact / AOB / Nature England and Cotswolds National Parkland plans- I believe option 30 is the worst possible route for the environment and the village of Cowley which sits in an AOB. Cutting down trees and destroying grassland in an AOB, when we have stated government policy to invest and plant more trees to reduce carbon dioxide is contradictory and in contravention to the 2015 Conservative manifesto. The proposed scheme will result in a net loss of wildlife habitat. This surely comes at a time when the importance of nature and outdoor green spaces has become more important and more precious than ever, it is essential that the scheme avoids increased impact on the most sensitive wildlife habitat. Furthermore Nature England wants to turn the Cotswolds into a National Parkland – this surely would contradict the new road proposal. 3) Unfair representation of Cowley village interest I do not, alongside other villagers at Cowley believe that our interests have been at all fairly represented and therefore considered by Highways England in the consultative process. We have a joint Parish council with Birdlip and for reasons stated above (in Point 1) this naturally presents a huge conflict of interest issue. 4) The disruption to Cowley village life during the construction phase which is likely to last for at least four years is huge. I don’t agree that the transition from the existing road to the new one will be as smooth and seamless as presented in the plans. These projects always tend to over-run in costs and timing, especially in the current environment /post Brexit where there are huge supply chain constraints. I do strongly believe that the construction and other traffic will use the already very narrow and fragile/ broken roads in the village and it will result in totally destroying the peace in the village. Our family moved out of town many years ago to live in a peaceful village and this will now be destroyed! 5) Unbalanced and not fully considered solution I fully understand that a solution to the current A417 is necessary but it needs to be much more balanced and considered. As an alternative, an extension of the current road into a dual carriageway would not be as disruptive to the local environment and habitat / AOB. There is ample room on either side of the footprint of the current road. With a section of tunnel past the village of Birdlip, so as to address noise and pollution issues for those residents. The accident blackspots, namely the crossing at Birdlip can be controlled using traffic lights and the approach to the Air Balloon roundabout broadened out and converted to a safer junction. The inability for traffic to flow faster due to the curvature of the existing road is not a valid reason for not considering this option. The priority here should be to keep the traffic free flowing to alleviate the current congestion that is caused approaching the Air balloon round about and making that stretch safer. It is worth noting that despite this being identified as a black spot, no serious attempts have been made to warn the oncoming traffic, for example through the use of signage and road markings along the existing road. 6) Devaluation of property values in Cowley village. Evidence of this has already started to emerge from our interactions with established estate agents in the area. We have written confirmation of this. 7) No increase in economy I strongly disagree that having a dual carriageway for this short 3.4 mile stretch will add to the economy of the region. Traffic projections for road projects tend to over-shoot in order to fit financing models as evident by real world examples such as the M6 Toll (financially restructured due to 50% of the actual traffic vs original traffic assumptions). While I acknowledge that this is a publicly funded project the same issues apply on the modelling assumptions. 8) Destroying Stockwell Farm and livelihoods of farm workers Contrary to adding to the economy of the area, the construction of the road is in fact impacting Stockwell farm and the lives of Stockwell farm workers severely who as we understand it are strongly opposed to the current scheme. Also, the village of Cowley is the location of Cowley Manor, a grade II listed historical building converted into a hotel which attracts visitors from far and wide to the area. The noise increase of the new road will deter many visitors wanting to come to Cowley Manor Hotel. 9) Contradiction to Paris Accord and environmental protection targets The construction of this road which aims to bring more and faster flowing traffic to the area in a time where extreme climate conditions are plaguing the world over is not going to take the nation any closer to its Paris Accord or any other environmental protection targets. Pascale Gysi [Redacted]"
Members of the Public/Businesses
Paul Vogel
"I am most concerned with mitigation measures to reduce ambient noise air pollution and visual impact in this AONB."
Members of the Public/Businesses
Rahul Ahuja
"Background I am Rahul Ahuja, [redacted] Having a dual carriageway constructed within a kilometre from our house will destroy those surroundings and is already having a detrimental impact on the value of it. My representation, limited to 500 words is given below, in addition my wife, Anju Ahuja will make her own representation as the second adult in the household which I fully support. The representation/ Summary of points; I strongly oppose Option 30 for this scheme for the following reasons: 1) Noise – we can already hear the current A417 which runs to the south of our house, this is being brought a lot closer and as a dual carriageway on both that side and to the west of our house, therefore from two directions, the noise levels will definitely be increased, notwithstanding the deployment of quiet road surfaces. The current A417 was built some twenty years ago and the Birdlip residents have been complaining about noise and air pollution levels ever since. Shifting the road towards Cowley in a larger format is just transferring the problem on to us, this is not the solution to that problem. 2) Environmental Impact - We believe option 30 is the worst possible route for the environment. Cutting down trees and destroying grassland when we have stated government policy to invest and plant more trees to reduce carbon dioxide is contradictory and in contravention to the 2015 Conservative manifesto. The proposed scheme will result in a net loss of wildlife habitat. At a time when the importance of nature and outdoor green spaces has become clearer and more precious than ever, it is essential that the scheme avoids increased impact on the most sensitive wildlife habitat. 3) We do not, alongside other villagers at Cowley believe that our interests have been fairly represented and therefore considered by Highways England in the consultative process. We have a joint Parish council with Birdlip and for reasons stated above (in Point 1) this naturally presents a conflict of interest issue. 4) Disruption to village live during the construction phase which is likely to last for at least four years. I don’t agree that the transition from the existing road to the new one will be as smooth and seamless as presented in the plans. These projects tend to over-run in costs and timing, especially in the current environment where there are supply chain constraints. I do strongly believe that the construction and other traffic will use the already narrow and fragile roads in the village and destroy the peace in the village."
Members of the Public/Businesses
Richard Hamilton
"I strongly oppose Option 30 for the following reasons; A. Environmental Impact - Option 30 in my opinion is the worst possible route for the environment. Destroying natural habitat, grassland and woodland is contradictory to the 2015 Conservative manifesto and the proposed scheme also goes against the National Planning Policy Framework (paragraph 176 & 177) of protecting the AONB. B. Pollution & Noise – the A417 has always been a contributing factor to air pollution within the area and with a prevailing south westerly wind, the relocation of the road and the increase in size will increase the amount of pollution moving the problem away from Birdlip to Cowley, merely shifting the problem not solving the problem. C. Birdlip and Cowley share a parish council. The relocation of the road from Birdlip to Cowley obviously creates a conflict of interest and as such Cowley hasn’t been fairly consulted by Highways England with no record of notes or meeting minutes. D. Construction Impact – all transport upgrades have a detrimental impact on local roads. The local roads are already in a poor condition and with construction traffic being stored on local land, the fragile infrastructure will deteriorate as they are not fit for purpose in their current state. E. Uneconomic Benefits - an expansion of the road will do little for the economy of the region. The A417 is a connection between the M4 & M5. Traffic projections for such road projects are typically over stated for financial modelling purposes and with the effect of Brexit and COVID any previous models need to be updated to take into account current and future changes to working practices."
Members of the Public/Businesses
Sean Paul Pritchard-Nash
"A417 Missing link. I strongly object to Option 30 for the following reason. As a young person [redacted] I believe that we have to take responsibility for the future of our planet, and this means having the least impact on it that is possible. I have lived most of my life in Cowley and treasure it and would like my children to have the same wonderful experiences I have had of growing up in the country with nature and fresh air. To me it is very clear following the existing route (Option 12) and widening to a dual carriage way with various traffic flowing methods can solve the situation with the least impact on the environment. It is time to stop being driven by money and start thinking about what we can actively do for the future generations of mankind and animals. Sean Pritchard Nash [redacted]"
Members of the Public/Businesses
Sonja Bradley
"Objection to the A417-Missing Link I write in connection with the above planning application, I have examined the plans thoroughly and I know the proposed area well. I wish to object strongly to ‘’Chosen Option 30’’I was at the meeting in 2018 held in Elkstone church Hall, the consensus was opposed to this option, in fact the gentleman representing the missing link we spoke to told us we could object but basically it was a done deal!!! I have lived in the area for over 17 Years and seen the disruption and chaos in our village every time there is an accident on either the 435 or the 417 and Cowley, Coberly and Elkstone become a diversion it becomes a dangerous trap on our small village roads that are not equipped for heavy traffic as we live in a rural area of natural outstanding beauty. I am on the road a lot of the time and have found the traffic to move steadily on the 417 and I find people are accommodation to let people in, and yes a change needs to happen to make the road better but at what cost to our ecology and to an area of outstanding beauty, after a pandemic and global warming it seems senseless that we are now looking to build a total new road and destroying stunning land that inhabits amazing wild life that will now be more at risk between all these vicious fast senseless roads, I Cannot believe that option 30 is more cost effective , and believe option 12 is far more sensible as it does the least amount of damage to the surrounding environment , The existing road gets widened and like all big round abouts in the UK it has a traffic light to create a flow giving all directions a good turn, at Birdlip there should be a filter lane like entering any dual carriage way , this will stop people from taking chances. The proposed road will create such pollution and harm as you are encouraging a faster more dangerous speed when approaching a downhill bend, not to mention the noise that will echo across the valley. As I walk the area extensively I did see with my own eyes that your current diggings on the upper part of Stockwell farm found Roman artifacts in what was an ancient Roman Village , this was just covered up and kept quiet, this hardly seems right that we just dismiss important findings of history and merrily build a senseless road, god knows planning wont allow me to build to near to the woodlands due to light pollution and disruption of our fantastic bats and wild life but it’s okay to bulldoze a road and ruin this outstanding area for life. With Pollution, noise and rubbish. How is Cowley meant to cope with the excess traffic when this senseless road is built, there is now way Cowley will not be affected and our picturesque village walls ruined by excess overweight traffic, not to mention the depreciation to the value of our homes! Thank you for taking the time to read my objection. Kind Regards Sonja Bradley. [redacted]"
Members of the Public/Businesses
Steven Batt
"I am registering interest against the proposed Route 30 and question why the current A419 isn’t widened as per Route 12 for cost, disruption, environmental, ecological and safety reasons. • The proposed Route 30 is in AONB and the Glover report proposes uplifting the Cotswolds to a National Park. The Government’s National Policy Framework paras 174-188 cites “Planning policies and decisions should contribute to and enhance the natural and local environment” including “when considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development 60 other than in exceptional circumstances”. Route 30 cannot be deemed as “exceptional circumstances” when the existing stretch of the A419 could be widened (or made into 2 separate carriage ways) thus eliminating the devastating impact of Route 30 cutting through beautiful AONB and destroying local farmland, plant and animal habitat. • The Government is legally obligated to achieve net zero emissions by 2050. It is my understanding that Route 12 is deemed an unsafe option because of traffic using it at 70mph. However, due to its elevation that route experiences heavy snow, fog and mist, which means that Route 12 speeds would have to be lowered to max 50mph much of the time. The proposed Route 30 is at a higher elevation, causing more risk of accidents in inclement weather, and the same need as Route 12 for lower speed limits. There is extensive evidence (demonstrated by the Welsh Govt) proving that 50-60pmh speed limits are safer and reduce emissions by at least 17%; and the UK Govt is trialling 50mph on specific road stretches for these reasons – so surely this is another argument for constructing Route 12 instead of Route 30 and keeping it at 50mph to reduce emissions of increased traffic volumes and improve safety? • How can Highways England ensure construction traffic will not use the single-track lanes in and around Cowley, particularly when local landowners don’t want construction traffic using their land for access and storage? And how will they stop other traffic using these narrow lanes as a cut-through when A419 traffic is diverted or held-up due to construction work? This raises huge safety concerns for local pets, children and residents who live, walk, cycle and horse-ride on these lanes; environmental pollution issues; and also the impact on the old stone cottages, many built in the 1800s and not built withstand the impact and vibrations of passing heavy / sustained traffic. • Cowley residents are already experiencing the impact of the proposed road on potential buyers put off buying homes due to the proposed road and at least 3 local estate agents have already have predicted Route 30 will knock significant value off their homes."
Members of the Public/Businesses
Thomas Stuart Bradley
"A417 Missing Link I strongly oppose Option 30 for this scheme for the following reasons. Whilst I do agree that the road congestion at Birdlip and the AirBalloon roundabout needs to be addressed as a matter of urgency. Environmental impact -I believe option 30 to be the worst route in terms of environmental impact, it cuts into swathes of greenbelt destroying grasslands and woodlands and natural habitat of many species of wild animals. At a time when we are just coming to understand the damage we have caused to our planet we need to stop and think about the results of our actions, which too many times have been driven solely by economics with no thought for future generations. We live in an ANOB (it has been suggested should become a national park) which should be treasured as a national asset as once gone will never come back. Noise- as a resident of Cowley the noise levels we can currently hear the A417 will definitely increase , even with mitigating surfaces, thus spoiling the charm and appeal of ANOB and further degrading our environment. Disruption- this proposed route will cause massive disruption and destruction to our narrow single track roads during the construction, which cannot even allow two small cars to pass each other. Whilst construction traffic should be banned, we all know that with the use of so many subcontractors this will be ignored. Leaving us with miles of destroyed verges, hedgerows and ditches and loss of habitat for wild animals. We have had a pothole in our village for the entire time I have lived here (17years) which Highways have been unable to repair, how would they cope with miles of damage! Devaluation- it is becoming evident that even now that our properties are devaluing and a reluctance of purchasers to make an offer due to the negative impact of option 30. Which is being confirmed by estate agents. Solution- I believe option 12 should be the preferred one, using the existing footprint of the A417 which will have the least damaging effect on the ecology and environment. Highways have used the imbalance of Cowley and Birdlip to their benefit when really their motive is purely economic. Route- the suggested large sweep needed in option 30 due to motorway speed of 70mph, is not realistic because a speed limit of 50mph will have to be enforced for safety on Crickley hill due to the amount of HGV’s using this route. The black spot at Birdlip can be negated by introducing filtering measures. T.S. Bradley [redacted]"
Members of the Public/Businesses
Tim Knox
"I strongly oppose Option 30 for this scheme for the following reasons: ENVIRONMENT: The Climate Change Act commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050. The UK is committed to working with all countries and joining forces with civil society, companies and people on the frontline of climate change to inspire climate action ahead of COP26. This development goes against everything the Government will be trying to promote at COP26. I believe option 30 is the worst possible route for the environment. Cutting down trees and destroying grassland when we have stated government policy to invest and plant more trees to reduce carbon dioxide is contradictory and in contravention to the 2015 Conservative manifesto. The proposed scheme will result in a net loss of wildlife habitat. At a time when the importance of nature and outdoor green spaces has become clearer and more precious than ever, it is essential that the scheme avoids increased impact on the most sensitive wildlife habitat. ANOB: The National Planning Policy Framework (NPPF). The Government has a clear commitment to protecting ANOB’s and that “planning permission should be refused for major developments in these designated areas except in exceptional circumstances. ROAD HISTORY: The proposed route has been chosen to ensure traffic speed can be maintained at 70mph. I do not believe the extreme weather conditions that routinely affect the area during the winter have been taken into account and it is very likely that there will be many accidents due to the thick fog that routinely forms in this area. Heads of the Valleys Road construction have reduced the speed limit to 50mph from a previously agreed 70mph, with the clear environmental benefits. Option 12 would therefore be much better suited, keeping speeds in this very dangerous area down to 50mph. NATIONAL PARK STATUS. The Government have indicated that they are considering turning the Cotswolds, currently AONB, into a National Parks and the move would see them placed under more stringent planning regulations to protect landscapes across the area. This development would be a contradiction. NOISE. The impact of Option 30 on the village of Cowley has not been accessed properly. The recent Highways report ‘6.4 Environmental Statement Appendix 11.4 Assessment Locations and Noise Prediction Results’ does not even mention my property, which is one of the nearest properties in Cowley to the proposed route."
Non-Statutory Organisations
Western Gateway Sub-National Body
"The Western Gateway Sub-National Transport Body (STB) would like to register as an Interested Party for the A417 Missing Link Project. Within the STB’s Strategic Transport Plan (2020-25) it identifies this scheme as a regional transport priority recognising its role in improving highway safety and network resilience for this strategically important travel corridor."
Members of the Public/Businesses
Adam Dawson
"This representation sets out why I am against the A417 Missing Link scheme. The overarching reasons are that this scheme does not appear to provide significant value for money. The negatives, such as cost, impacts on the environment and impacts on the government’s commitment to climate action. These do not seem to outweigh the benefits of reduced queuing time on a very small stretch (<5 km) of road. While safety is a concern, I am sure that there could be less expensive solutions to improve safety. This scheme has been in the pipeline for 20-30 years, and people in the area have managed to cope without significant impacts to the economy. It seems fool hardy to commission a scheme that will be under construction for a decade when people are starting to change the way they work and travel, potentially making this scheme redundant. Even a delay to assess these issues would be welcomed. In terms of the impact of the scheme itself, the EIA has concluded permanent significant adverse effects on landscape, biodiversity, cultural heritage, and noise, as well as not being able to rule out significant effects on nearby European habitat sites. I do not see the benefits of spending a huge amount of money to the detriment of a valuable area of environmental, cultural and economic significance, such as the Cotswold area of outstanding natural beauty, for such a limited gain."
Members of the Public/Businesses
Carter Jonas LLP on behalf of Alan Dick
"Mr Alan Dick owns approximately ( 10.5 ) hectares of land at [redacted]. The Property would be affected by the A417 Missing Link (the ‘Scheme’) summarised as follows: - Compulsory purchase of approximately 6.32 hectares of land for the purpose of environmental mitigation. - Temporary possession of approximately 1791 square meters of land for construction - Creation of numerous new rights in favour of statutory undertakers over the land, and a new public right of way. Mr Dick has sought to cooperate with Highways England Company Limited (the ‘Applicant’) during the pre-application period, including multiple meetings, the grant of licences and raising the potential to enter into a management agreement to obviate the need to compulsory acquire his property. Regrettably these discussions have to date proved unproductive due to the Applicant’s lack of firm proposals and inability to clearly express its intentions for the Property, even at the DCO application stage. Mr Dick therefore objects to the Scheme, principally as the Applicant has not demonstrated a compelling case in the public interest for the use of compulsory purchase powers over the Property and because the Scheme conflicts with the UK’s International commitments and domestic policy on climate change. Mr Dick considers the following matters to be relevant to the DCO examination: 1. The UK’s International and domestic legal obligations to limit greenhouse gas emissions conflict with the Scheme. 2. The Applicant has not demonstrated a compelling case in the public interest for the exercise of compulsory purchase powers over the Property: - The Applicant has only a vague idea of its intentions for this land. This is ostensibly to compensate for a loss of 1.38 hectares of neutral grassland and 4 hectares of species rich lowland meadow however there is no detail in the application as to the condition of this grassland / meadow, why it needs to be compensated, and how this will be achieved on the Property. - Mr Dick has been advised that “Site specific ecological mitigation management plans will be developed at the detailed design stage of the scheme.” If the Applicant cannot say how it will use the Property then it follows that it cannot demonstrate the Property is needed for the Scheme, nor that any compensation shown to be needed will in fact be delivered. - The land already comprises neutral grassland. It is not in agricultural production rather has been in extensive environmental management for several years. Mr Dick is actively considering enhanced ecological management under the ELMs scheme to which the land is particularly suited. In order to provide ecological mitigation the Applicant should identify alternative land in agricultural production in order to compensate for loss of other habitat, and not land which is already in extensive environmental management. - Mr Dick has offered to enter into a management agreement with the Applicant as an alternative to compulsory acquisition. No agreement has been offered by the Applicant and discussions have been inconclusive as the Applicant’s plans are insufficiently ready for them to commit to an agreement. The Applicant is under an obligation to seek to reach agreement for land acquisition prior to applying for compulsory purchase powers and it has failed to satisfy this obligation. 3. There has been no information provided to Mr Dick by the Applicant about rights over land being created for statutory undertakers. 4. Mr Dick objects to the creation of a new right of way over the Property. This is understood to be creation of a new right of way (as opposed to a diversion or replacement) and the Applicant has failed to demonstrate any need for such a right of way justifying the use of compulsory purchase powers. 5. There has been no proposal put to Mr Dick in outlining where any new septic tank will be located to serve ( all ) the buildings at [redacted]. The Scheme necessitates the removal of the existing facility (which is on the Property)."
Members of the Public/Businesses
Andrew Dawson
"I would urge that the route be re-considered due to environmental impact, the major change in traffic trends in the recent months and future speed restrictions. I do accept that something needs to be done about the congestion, but prefer it is done in a more environmentally-friendly manner than proposed by the supposedly green current scheme and without the huge impact on the AONB it demands. As well as Honda closing, more people are working from home, following COVID-19 and traffic has reduced significantly and should be taken into consideration. I realise this would increase once the route is improved, but surely not to a degree that requires such a massive scheme. The likelihood of a reduced national speed limit currently under consideration within environmental issues/requirements means that the removal of the main cause of the congestion may be achieved by widening the existing road and providing a series of slip-roads and bridges as suggested by Route-12 – ruled out as being only 50mph so inadequate!?. The congestion is after all caused mainly by A417 and A436 traffic intersecting at the roundabout forming a bottleneck, solvable by medium speed slip-roads/flyovers and without the need for new scar in the AONB which will be seen for miles across the Severn Valley. Speed should anyway be limited here, especially in the winter, regardless of road design, because of the frequent low cloud, fog and general poor weather naturally occurring at the highest point in the Cotswolds. Ploughing a brand new 70mph route through this point is wasteful and a disaster waiting to happen, environmentally, safety-wise and (sooner or later) politically. Noise levels will increase further for Cowley now that the National Trust has pressured for the route to be moved because of Woodland destruction by the scheme. The Highways England noise model originally showed a small increase for Cowley but no updated figures have been issued since the route was moved closer to the village this year. What has not been explained is how the comparison was arrived at - Highways England have not published the existence of a noise meter within the village. I asked this at a public consultation event in Witcombe and the Highways representative said that Cowley was outside the boundary of the scheme so was not monitored! I was disappointed by the lack of consultation by Highways with Cowley residents generally, given that it is the village most adversely affected by the scheme – an exhibition was not even held in the village during the Public Consultation period (the Guide Camp was available), further showing their disregard. This is the last chance to avert a tragedy for the environment so please let’s look at this again with the future in mind."
Members of the Public/Businesses
Carla Jackson
"I currently live on [redacted] and have significant concerns about the impact of the new road layout following the removal of the Air Balloon roundabout. As a resident on this stretch of road I and my neighbours are already suffering from the speed of traffic when there are no tail backs from the roundabout. With the revised scheme this is predicted to get a lot worse. The traffic speed also has an impact on the noise disturbance due to the increased noise. We recognise that this stretch of road is the responsibility of Gloucestershire Highways but it will be impacted by the Highways England scheme. We are seeking a reduction in the speed limit from 50mph to 30mph between east of Oxford Cottages and the new Ullenwood roundabout."
Members of the Public/Businesses
Cellnex UK
"Cellnex UK A417 Missing Link Planning Inspectorate Reference: TR010056 Summary of Objections to the Development Consent Order We take this opportunity to provide a summary of our objections to the Development Consent Order. We intend to expand upon these points within further representations to be submitted at the appropriate time during the examination process. We reserve our right to attend and participate in the relevant examination hearings. Background Cellnex Group is a significant pan-European tower operator with sites in the UK, Ireland, Spain, Portugal, Sweden, Denmark, Austria, Poland, Italy, France, Switzerland and the Netherlands. It has 131,000 communication sites, 71,000 of them already in the portfolio and the rest in the process of closing or planned roll-outs up to 2030 and positions the company to develop new generation networks. Cellnex UK is the largest supplier of sites available for sharing by other operators, for example, the Mobile Network Operators (MNOs), Airwave and other emergency/breakdown service network operators, the RNLI, the Coastguard and Maritime Services, Mountain Rescue and a range of central and local government departments and agencies. It operates around 9000 active shared wireless infrastructure sites (neutral host) utilised by all the MNOs for the deployment of existing and future generations of mobile connectivity and particularly 5G. Additionally, Cellnex UK has access to other tall buildings and structures not yet developed for electronic communications use. Objections Whilst we do not object to the aims of the Development Consent Order (DCO) the proposed works potentially impact on two of our sites. We expand on our objections as they relate to each mast site below: 1. Existing mast site at Shab Hill, Birdlip, Gloucester, GL4 8JX (NGR: 393952E 215377N) Cellnex UK operates a 67m high lattice mast and associated development from this site. Although our mast site is located outside of the DCO area, the DCO boundary is situated in close proximity to the south and east where major construction works are proposed. The potential impacts of the proposed works require further investigation but are likely to include the following: (i) Operational/Technical Impacts – Any development that includes an increase in land levels could impact on the signal propagation from antennas and line of sight linkage of transmission dishes located on the mast. Technical impacts will require assessment and any required mitigation measures agreed with Highways England (HE) so that services currently provided from the mast are not impacted by any development associated with the DCO. (ii) Access Arrangements – Existing access arrangements to the site may be impacted by the proposal (iii) Power and Fixed Line Provision – Given the proximity of the proposed works any provision of services to the site from the east are likely to be impacted. (iv) Drainage Provision – Watercourse ditches are proposed in proximity to our site. Assurance is required that these will not represent a flooding issue. (v) Construction - There is a possibility that, due to proximity, the construction works could impact the operation of the mast in terms of dust, vibration and the operation of cranes blocking signal propagation and line of sight. We will therefore require mitigation measures to be put in place to safeguard our operations from the site. 2. Existing mast site, Land at Stockwell Farm, Birdlip, Cheltenham, GL53 9PF (NGR: 185492E 054007N) Cellnex operates a 15m monopole mast and associated development from this site. Although our mast site is located outside of the DCO area, the DCO boundary is located in close proximity to the east and in particular to the west where major construction works are proposed. The potential impacts of the proposed works require further investigation but are likely to include the following: (i) Operational/Technical Impacts – the main highways works including a bridge are located a short distance to the west of our installation. Any impact on signal propagation and line of sight dish linkage will require further assessment and any impacts mitigatedby HE. (ii) Access Arrangements – The proposed high works will bisect our existing legal access to the site from Stockwell Farm to the west. A permanent replacement access to the site and a temporary access during construction works will be required. We note that a bridge is proposed over the main highway to provide replacement access from the farm to the agricultural fields to the east we will require a legal agreement to use this. Our site operates on a 365 days, 24hrs day basis, so during highway construction, appropriate measures must be made for service personnel to access our site at short notice so that the public communication services provided from the site remain unaffected. (iii) Power and Fixed Line Provision – Given the proximity of the proposed works any provision of services to the site from the west are likely to be impacted. (iv) Drainage Provision – Watercourse ditches are proposed in proximity to our site. Assurance is required that these will not represent a flooding issue. (v) Construction - There is a possibility that, due to proximity, the construction works could impact the operation of the mast in terms of dust, vibration and the operation of cranes blocking signal propagation and line of sight linkage. We will therefore require mitigation measures to be put in place to safeguard our operations from the site. Further details of impacts and required mitigation measures for both sites will be detailed in our representations to be submitted in due course and we therefore lodge holding objections for both sites in the interim until discussions are undertaken with HE with regard to impacts and mitigation. The public and sustainable development benefits of mobile connectivity are now well-understood and we are in an electronic communications revolution with businesses and society in general using and relying upon all forms of modern communications to an ever-increasing extent. The protection of the above sites and the wireless communication services provided from them is clearly in the public interest as the loss of or impact on these services has the potential to affect several thousand mobile communications users. Whilst setting out our objection within these representations, we would welcome the opportunity for early dialogue with HE to address the objections and to minimise issues through negotiation and agreement. We would therefore be pleased to have contact with HE in this regard. We look forward to receiving further details of the examination. If you do require any further information or clarification, please do not hesitate to contact our Matthew Waugh on [redacted]"
Members of the Public/Businesses
Daniel Chesmore
"The planned route for Option 30 is damaging to the environment. The route that it plans to take will cut down trees and damage landscape. To say nothing of the impact that this will have upon the local wild life. It seems counter-intuitive that there are plans to put in bigger roads, damage the environment all the while the country is promising to lower carbon emissions and the world is facing a climate crisis. It is deeply questionable that this idea was put forward in such a troubling time. Having worked with heavy machinery before and having seen the impact that it can have upon roads, land and traffic the set out plans do not appear to meet that. Moving HGVs along single track roads will only cause traffic jams around the village, damage the land as people try to get past each other and increase the risk of accidents. This is before one takes into account the supply issues that the country is facing and the nature of large projects such as this to over run their time frame. The quiet nature of the village will be destroyed as the single track roads fail under the weight of the rat race. There will be irreparable damage to the roads, to the character of the village, the wildlife and all the while causing accidents. There have been arguments put forward that the new duel carriage way will be an economic advantage to the village. There is a grade II listed hotel and small village shop otherwise there is no other are of industry, sales or business in the village that could possibly benefit from this. As such this argument is null and void as the village is where people live not work."
Members of the Public/Businesses
David Ayling-smith
"Whilst we understand there needs to be a significant improvement to the traffic flow on the A417, we find the current proposal unsatisfactory for the following reasons. Given the Governments public commitment to preserving AONB’s , this proposal is unsuitable as it will destroy significant local habitats and AONB land. It would surely be less destructive to enlarge existing routes. As a local resident we are very concerned about noise and light pollution, the affect on local wildlife, the impact on the sensitive environment hereabouts and the potential to severely impact the tranquility of a quiet local village . We don’t understand or agree with the proposal that it will bring prosperity to the area in fact we fear the opposite result , with a likely decrease in house prices and a possible negative impact on local business like The Green Dragon and Cowley Manor that have a reputation of being quintessentially tranquil Cotswolds establishments. We are very concerned about the potential for increased traffic flow through the village during construction and after the road is built due to the development of Cowley roundabout . Access to the village is almost exclusively through single track lanes that have no ability to take a larger volume of traffic . We would like to see much more stringent mitigation measure implemented to address the above concerns or consideration of an alternative plan that makes more use of the existing route and makes less impact on the AONB"
Members of the Public/Businesses
David Steele
"My concerns comprise: - the effect of the A417 improvements on traffic volumes and speeds along the A436. This is already a serious problem along this stretch with very frequent accidents and some fatalities, and very high levels of traffic noise. The improved flow, and elimination of the steepest gradients on Crickley Hill seems very likely to attract traffic travelling cross- country to the M5. This does not seem to have been reflected in the traffic modelling, nor have I seen any specific mitigations for this inevitability. - the movement of materials during excavations & building works. Clearly there are few ways into & out of the area, and it seems highly likely that much construction traffic will need to pass along the A436, exacerbating the above problems. [redacted]"
Non-Statutory Organisations
Gloucestershire Ramblers
"This scheme for a new dual carriageway within an Area of Outstanding Natural Beauty is fundamentally flawed, in its claims of 'landscape-led' and 'recreational enhancement', without proper consideration of tunnelling. 'Landscape led': The current road from Brockworth to Cold Slad turn has a noticable 7% gradient and is low in the landscape to minimise visual and noise intrusion. The plans increase the gradient to 8%, to cover a step change in height of terrain, and include a flyover at the highest point, Shab Hill. Part of a SSSI is removed and the landmark Air Balloon demolished. 'Recreational enhancement': Paths and tracks are severed or diverted, facilities and heritage are lost at the Air Balloon, local connection between villages is removed and popular parking at Barrow Wake reduced. Where footpaths are changed to include broader use, this would not be generally considered beneficial by walkers. 'Government National Planning Policy Framework' says Para 174 - decisions should contribute to and enhance the natural and local environment Para 176 - Great weight should be given to conserving and enhancing landscape and scenic beauty in ..... Areas of Outstanding Natural Beauty. The proposals sever the historic landscape and natural connectivity. Instead the road could be kept low in the landscape. Short tunnels or vegetation covered bridges would increase connectivity, including between Barrow Wake and Crickley Hill SSSIs, enhance the environment for both walkers and wildlife and retain the Inn. 'The Design Manual for Roads and Bridges LA 112 Population and Human Health' Table 3.11 has a 'very high' sensitivity for National Trails, promoted routes and existing employment sites. Table 3.12 lists WCH diversions greater than 500 metres (0.3 mile) as a 'major adverse impact'. Section 3.15 says: a) identify alternative design/route options that avoid the requirement to compulsory purchase property, land and assets; and b) identify alternative design/route options that avoid introducing or worsening severance and avoid reducing WCH provision/increasing journey times. The proposal extinguishes or diverts existing footpaths, worsens severance and increases journey times. An alternative design could retain connectivity and avoid compulsory purchase of the Air Balloon (an employment site) where the Cotswold Way National Trail meets the Gloucestershire Way. 'Tunnelling ' should be properly considered. The North and South Downs AONB use a low-cost reinforced sprayed concrete method to maintain footpaths and the landscape above new roads. The HS2 and Network Rail infrastructure upgrade also use various types. For this project, tunnels were discounted largely on grounds of cost, with the use of expensive twin tunnel boring machines. However by going underground, surface features can be maintained and gradients reduced. A step change in height of terrain could contain a tunnel entrance. Ramblers have campaigned here for over 20 years for through traffic to be removed from local roads so that roads become crossable and walkable again, preferably with a tunnel so the landscape remains much the same. If proposals were reconsidered, footpaths and the countryside could be retained within the scheme for enjoyment by future generations."
Members of the Public/Businesses
Helen Chesmore
"It is evident that there needs to be change to how the road is at present. However it needs to be more balanced and to take into consideration the wider options available. The most obvious would be that there is enough space either side of the current roads footprint to accommodate the new road. To solve the accident blackspots, the crossing at Birdlip as well as the Stockwell turning, could be eased with the introduction of traffic lights. The Air Balloon roundabout would likewise benefit from a traffic light system as well as widening. These all seem like actions that should have taken place before any talk of new duel carriage ways began. Thus the idea that the new road is safe seems questionable when no other option has been explored or implemented. The village of Birdlip has been complaining about the noise pollution since the introduction of the road twenty years ago. In shifting the road, and accommodating their requests, one has to feel that this is simply shifting the problem. There is not actual solution to the noise pollution problem. Instead this feels like seeking to appease one village at the expense of another rather than looking for an actual solution. I understand that there have been environmental surveys performed however if they were performed during the lock down then they do not reflect the actual impact the road has upon the area. With the world facing a global climate crisis as well as the Primeminister’s commitment to the Paris accords there must be an accurate survey performed to show that the proposed road will be greatly damaging to the local ecosystem. To pus ahead with such plans is irresponsible when considering future generations. As a property owner the introduction of the road will reduce the value of my property. [redacted] Having spoken to real estate agents and to other villagers to learn that not only would the road increase noise but would devalue my property thus robbing me of financial security for the coming years. I am not alone in this situation. The road will not only damage the character of the village, damage the roads, bracket us in on two sides with duel carriage ways but also mean that my financial future is at risk. This seems deeply irresponsible and ignorant of the current climate that people are living in."
Other Statutory Consultees
Historic England
"The Historic Buildings and Monuments Commission for England (known as Historic England) is an executive non-departmental public body sponsored by the Department for Culture, Media and Sport (DCMS). We are the Government’s lead advisory body on all aspects of the historic environment in England. We have a statutory role in the planning system. Central to this role is the advice we give to local planning authorities and government departments on development proposals affecting designated heritage assets, such as listed buildings, scheduled monuments, registered parks and gardens and conservation areas. Historic England made representations during the pre-application stage, directly to the applicant, as part of the consultation exercises under section 42 of the Planning Act 2008 (as amended). This has taken the form of meetings and letters since 2017. We now offer the following comments to register our interest and to briefly summarise our position: Points of Agreement: 1. Historic England accept the principle of a new strategic road link at this location. 2. Historic England agree with the strategy to include a Green Bridge and other footbridges across the new road, to retain links across the landscape and between the various heritage assets. However, if this scheme is to be acceptable in practice we believe it is essential for a number of matters to be addressed satisfactorily and we set these out below. Points of Disagreement: 1. Impacts on Designated Heritage Assets Historic England have concerns relating to the impacts on the setting of listed buildings and scheduled monuments along the route. These assets are listed and assessed within the ES. Of particular concern are a small number of designated assets, • Three Bowl Barrows known as Emma’s Grove round Barrows Scheduled Monument (Mon No., 32381, National Heritage List for England No. 1017079) • Crickley Hill Camp Scheduled Monument (Mon. No. GC40, NHLE No.1003586) • Shab Hill Barn Grade II building (NHLE No. 1091775) In each of the assets noted above there will be an impact on the significance of the asset through a change in their setting which contributes to their significance. The Grade II listed building falls outside of our statutory remit within the planning system and we would expect the local authority to provide further information on this asset. Historic England have concerns that the approach taken in the ES to assess the impacts on heritage assets through a change in setting which contributes to their significance is not robust enough or holistic. When considering the application, we feel that the harm caused should be assessed within the holistic historic landscape not just as individual assets. The scheme is a landscape led scheme to be designed to enhance and reflect the protected landscape of the AONB. It also seeks to look at the holistic impacts and enhancements the scheme can bring to that landscape, both natural and historic. Whilst the harm caused to the setting of these assets is less than substantial and the public benefits are acknowledged, we do not feel that it has been demonstrated that all efforts have been made to avoid or minimise conflict between the heritage assets’ conservation and the proposed development. If sufficient mitigation is not successful then there should be discussion of whether other action by National Highways could counteract the negative impact. These measures would be directly related to enhancement at the sites affected, such as carrying out or paying towards repair work. 2. Understanding of Undesignated Heritage Assets Historic England have concerns that there is not a full understanding of the impacts of the scheme on the undesignated archaeology along the route. There are other undesignated heritage assets within the landscape that contribute to the significance of the designated assets through association, a few of these are: • Peak Camp Neolithic Promontory Fort (Gloucestershire Historic Environment Record No. 4754) • Roman Roadside Settlement at Cowley Junction (GHER 11200) • Ermin Way/Street (GHER 7542) • Stockwell Deserted Medieval Village (GHER 5758) • Prehistoric pits and enclosure east of Emma’s Grove (GHER 22541) Some of these sites are within the DCO boundary and will be excavated or partially investigated as part of the mitigation. However the level of archaeological assessment that has so far been undertaken has not been adequate. This is partially due to issues with access to the land. Historic England also disagreed with the level of evaluation trenching undertaken; in our view this was not sufficient to provide a good sample of the potential across the scheme. Most of the investigation works were also undertaken late and therefore the results could not be fully integrated into the ES. There are areas that have not been surveyed at all and have the potential to have significant archaeology within them. Of particular concern is the lack of geoarchaeological investigations. All of our consultation responses and during meetings we had advised that this work needed to be undertaken pre-DCO. This did not happen. Therefore the assessments have been limited and do not include some areas of potential importance. It is therefore essential that the draft Development Consent Order provides for the completion of all necessary ground investigations inclusive of archaeological analysis and interpretation as detailed within Written Schemes of Investigation (WSI) to address all relevant archaeological issues of this proposed development, before construction starts. As there has not been adequate assessment of the environmental impacts which relate to the buried archaeology, the mitigation outlined in the ES is not adequate. The outline Written Scheme of Investigation needs further work to make it suitable for the level of works needed to do a full assessment of the archaeology prior to the mitigation being agreed. 3. Proposed enhancement of Emma’s Grove Barrows Historic England do not agree with the proposed mitigation and enhancement of Emma’s Grove Barrows as part of the Landscape mitigation within the ES. The barrow group is on the Heritage at Risk Register due to poor management and scrub growth. The application includes some improvements to its condition, but we feel this is not adequate and will not be sustainable. 4. Limited understanding of wider construction and mitigation impacts on the archaeology The ES does not provide sufficient information about the impacts of construction and landscape/ ecological mitigation beyond the road corridor. During pre-application discussions we repeatedly asked for further information on these impacts on the buried archaeology. This includes drainage, embankments, fencing, tree planting etc. Many areas identified for this construction work or mitigation has not been assessed archaeologically and therefore we do not understand the full impacts."
Members of the Public/Businesses
Atkins on behalf of Joint Councils (Gloucestershire CC Cotswold DC & Tewkesbury BC)
"Gloucestershire County Council, Cotswold District Council, Tewkesbury Borough Council – ‘The Joint Councils’ – Relevant Representation for the A417 Missing Link scheme Development Consent Order (DCO), September 2021. Gloucestershire County Council, Cotswold District Council and Tewkesbury Borough Council (the Joint Councils) are the host authorities for the Scheme. The Joint Councils have long recognised the need for the dualling of the final single-carriageway section of the strategically important A417. It is the Joint Councils’ view that the proposed A417 Missing Link DCO would deliver this objective. The Scheme would provide a safer, less congested alternative to the M5 for strategic traffic. It would reduce ‘rat-running’ of strategic road traffic on local roads and reduce the severing effect that the existing section of A417 has on local communities and users of the Gloucestershire Way, Cotswold Way and local Public Rights of Way network. The Joint Councils have engaged with Highways England throughout the pre-application stage, providing advice on the design and impacts of the Scheme and discussing elements of the project that the County Council will become responsible for in the future. While the Joint Councils are fully supportive of the need and principle of the Scheme, there are a number of issues which require attention during Examination and within the draft DCO. These include: Environment • Air Quality o Measures to mitigate impacts during construction at Air Balloon Cottages from the increase in HGVs. o The significant adverse effect from nitrogen deposition on Ullenwood Ancient Woodland and some of the veteran trees, and whether monitoring should be required. • Cultural Heritage: o The insufficient sample density of archaeological trial trenching carried out to inform the baseline for the Environmental Statement. • Landscape (see point on lighting below) • Biodiversity: o While there is no current legal or policy requirement for the Scheme to do so, Highways England has made a commitment to delivering biodiversity net gain. Further detail is required around the proposals for delivering Biodiversity Net Gain and the mechanism for securing its delivery. • Material Assets and Waste o The final quantity and management of the surplus soil from the Scheme • Noise and Vibration: o The level of noise mitigation proposed for the Scheme, in particular, there is currently no mitigation proposed by Highways England that can avoid the significant adverse noise effects identified on 17 properties at Stratton and Leckhampton Hill. The Joint Councils are generally satisfied with the environmental impact assessments undertaken for the other environmental topics including landscape, geology and soils, population and human health and road drainage and the water environment. This is subject to appropriate protections being secured within the DCO. Design / Highways • The County Council, in its role has Local Highway Authority, has concerns over highway safety at ‘conflict zones’ on side roads which would not be lit to highway standards. Once constructed, the County Council will adopt these roads and it requires highway lighting to be included in the design. The Joint Councils agree that any highway lighting proposed in the Scheme would need to utilise a mix of standard and innovative lighting solutions which balance highway safety, ecology and landscape concerns. Additional assessment of ecology and landscape impacts would be necessary during the Examination and may identify the need for design changes to mitigate landscape and biodiversity impacts. • There is currently no mitigation proposed for the forecasted increases in traffic at Leckhampton Hill, Gloucester Road, Stratton, B4070 south of Birdlip and the road leading to Brimpsfield. • Further details related to the roads and assets to be de-trunked, including agreeing the commuted sums necessary for the maintenance of these roads by Local Highway Authority and agreement of a clear handover process. Draft DCO Detailed comments on the draft DCO and DCO Requirements will be provided to the Applicant and Examining Authority during the examination. The Joint Councils will engage with Highways England to seek to agree necessary revisions to the DCO where possible. At this stage, we note the following: • Omission of DCO Requirements related to the submission for written approval of construction pollution prevention measures and the details of design / external appearance of proposed structures including the Gloucestershire Way and Cotswold Way Crossings. • The proposed arrangements in Schedule 2 Requirement 4 of the draft DCO for consulting the local planning authorities and highway authority on the discharge of Requirements are not accepted. • The DCO provides for sections of both new and existing highway, PROW and private streets to become maintainable by GCC as the local highway authority. A clear handover and sign off process is required, including a suitable maintenance period. • In the absence of an agreement between GCC and HE, protective provisions for GCC are appropriate to be included within the DCO. • Generally, the DCO in many areas imposes matters on the local highway authority. For example, the date of de-trunking and revocation of existing traffic regulation orders. Greater protections and a clearer process involving GCC are required given the significant liability and changes proposed to the local highway network. • The Joint Councils should be expressly referred to as consultees in respect of relevant articles and requirements. For example, under article 19(8) in respect of traffic regulation."
Members of the Public/Businesses
Julie Jaffar
"In order to preserve and protect the landscape, wildlife and the residents of Cowley and the surrounding area , I fail to understand why more effort has not been put into improving the existing route with an extension, better signage and the most up to date methods of controlling the speed of vehicles. No one is questioning the need to improve the safety of motorists and save lives here but the extravagant and destructive route 30 option is doomed to go down in history as yet another out of control wasteful overspend of public funds where promises to mitigate the ensuing noise pollution and blight upon the residents lives in the close vicinity will very likely not be met on completion of the project if spending runs over budget."
Members of the Public/Businesses
Leon Flexman
"Whilst improvements to this stretch of the a417 are necessary, the draft Development Consent Order does not demonstrate that the impacts on the village of Cowley have been sufficiently investigated and understood and appropriate mitigation therefore proposed. Noise impact mitigation appears to have been dealt with at a generic level (road surface design and bunding, construction working hours) rather than through consideration of specific properties in the Village of Cowley and potential mitigations. The potential impact on property prices does not appear to have been adequately addressed. Most concerningly there is not enough evidence that the applicant has understood how traffic will behave during construction - the precise timeline for which still remains "tbc". A key part of the case for the scheme has been to reduce 'rat running' on local roads which are not designed to cope with high volumes of traffic. More needs to be done to provide reassurance that this will be managed appropriately and not in fact be worsened during the construction phase, creating nuisance, air quality, noise and most seriously real safety risks. Finally I do not believe that that the consultation has been adequately designed to take account of the fact that, at a very local level, the Parish Council represents both Cowley and Birdlip and has therefore been placed in a position of conflict of interest (given the latter is a clear beneficiary of this scheme and the former will suffer obvious detrimental effects). I would like the opportunity to expand on these points during the examination phase. Currently the tone of the application feels like Cowley is acceptable collateral damage given the need for a greater good. The village deserves reassurances that the appropriate level of detailed consideration (i.e. as though the applicant was living in Cowley) has been given to the impacts, in particular during construction. Proportionate mitigation, both statutory and voluntary as appropriate, should then be proposed, especially given the money saved by avoiding the options involving tunnelling (which Highways England concedes would have performed better on all key measures except cost)."
Members of the Public/Businesses
Moore Allen & Innocent LLP on behalf of Mr B J Ford
"Our client wishes to raise the following representations: 1. It is proposed that Cowley Wood Lane is stopped up and becomes a private means of access and public right of way. The land is currently used for agricultural purposes and no detail has yet been provided on whether this may continue. The lane also serves other dwellings. Further information is requested on this proposal. 2. Our client rejects the proposed compound which appears to extend to an estimated 18 acres of key agricultural land. This seems excessive and sterilises a large area of the farm for the period of construction. 3. The DCO boundary includes land to the north of the new access road and proposes tree planting on amenity land off Cowley Wood lane, well away from the new road. This appears out of keeping with the scheme requirements and has not been consulted on. 4. The Planning Inspectorate website lists 453 documents. It is unrealistic to be able to view each one, especially as our client does not have reliable internet access. Surely a bundle of relevant plans, reports and documents relating to their landholding only could have been sent to the clients without incurring a charge of £500?"
Members of the Public/Businesses
Mr Craig Deacon
"This is a terrible idea and there is a viable alternative solution that is seemingly being ignored. The plan needs to be revisited."
Members of the Public/Businesses
Moore Allen & Innocent LLP on behalf of Mrs C E Ford
"Our client wishes to raise the following representations: 1. It is proposed that Cowley Wood Lane is stopped up and becomes a private means of access and public right of way. The land is currently used for agricultural purposes and no detail has yet been provided on whether this may continue. The lane also serves other dwellings. Further information is requested on this proposal. 2. Our client rejects the proposed compound which appears to extend to an estimated 18 acres of key agricultural land. This seems excessive and sterilises a large area of the farm for the period of construction. 3. The DCO boundary includes land to the north of the new access road and proposes tree planting on amenity land off Cowley Wood lane, well away from the new road. This appears out of keeping with the scheme requirements and has not been consulted on. 4. The Planning Inspectorate website lists 453 documents. It is unrealistic to be able to view each one, especially as our client does not have reliable internet access. Surely a bundle of relevant plans, reports and documents relating to their landholding only could have been sent to the clients without incurring a charge of £500? 5. Access to our clients property should not be impinged at any point during the construction of the road or after completion."
Members of the Public/Businesses
Mrs Carol Gilbert
"Please refuse the current proposal as follows: 1.Ecological and Environmental Option 30 represents a catastrophe, not only destroying a wonderful, productive farm and reducing its ability to provide food for all time but the destruction of wildlife described by DEFRA as the best of any farm or estate in the region and so diverse that it was used by the BBC for wildlife sound recording for many years. Planting new trees will not replace the carbon reducing effect of the lost ancient woodland for decades and the beauty and biodiversity will never return. It is totally contrary to LNRSs and NRNs contained in the Government’s new Environment Bill with its new, legally binding, targets to halve the decline in wildlife. Also to NPPF Policy in an AONB, (para 116 of same), and the new Environmental Land Management Schemes (ELMS) consisting of: Sustainable Farming Incentive (SFI), Local Nature Recovery (LNR) and Landscape Recovery (LR); you cannot sustain a farm with its heart ripped out or recover a destroyed ancient woodland. The Government prides itself on being a world leader in reversing climate change but cannot hope to influence other, poorer countries at COP 26 if its own Policies and targets are ignored. 2. Road Safety Option 12 is by far the best environmentally, using wide verges left for the purpose c25years ago, but objections are that a 50mph speed limit would be needed near the Shab Hill Junction and the road would have to be divided at Nettleton Bottom. Government Policy is to reduce speed on major roads and in this area, 940 feet above sea level where large volumes of traffic from the A436 would filter in with both Options 12 and 30, weather conditions can change from misty to thick fog or rain to blinding snow in a matter of seconds. A 50mph limit could save countless accidents, injuries, possible loss of life and resultant pressure on the emergency services and NHS. There are several places where Motorways and major roads are divided effectively: e.g. M6 between Exits 38/39 and 39/40: A38 north of Bridgewater 3. Public Order/Safety The “repurposing” of a section of the existing A417 could be a recipe for chaos. The general public, especially the disabled, horses and cyclists do not mix. Horses are flight animals and spook at the unfamiliar and crowds, many cyclists have absolutely no regard for horses and little for public safety and access to the area would cause blockages and accidents on local single track lanes. Further, the provision of such a site would encourage every type of anti social behaviour from littering, dogging and drug taking to the possible holding of illegal raves, with no direct access for emergency services. Option 12 uses this land, leaving the farm, woodland and wildlife intact and could save the Air Balloon from demolition, thus providing much needed refreshment and toilet facilities for visitors to the new green bridge"
Non-Statutory Organisations
Norwich & Norfolk Friends of the Earth
"I am concerned that the building of this road will contravene EU Habitats Directive and have a direct affect on wildlife. It will also be impossible for the Local Authority to comply with EU Air Quality legislation. There are also many issues relating to increasing carbon emissions whilst we are already in the throes of a climate and ecological emergency. In particular carbon emissions should be tested locally, regionally and nationally against the UK obligations under the Paris agreement including the UK's Nationally Determined Contribution (ND), the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), the revised NPPF 152 planning requirement to "radical reductions of greenhouse gas emissions", the statutory duty on Highways England under the Infrastructure Act 2015 section 5 (2) to have regard for the environment, and local authority Environmental Policies."
Members of the Public/Businesses
R.w. de Lisle Wells
"I Robert de lisle wells own land that is going to be taken for the road scheme.. There are multiple concerns I have that has not been addressed in the consultation( many not even acknowledged). * I feel that there has not been a full consultation with the land owners. * Futher bunding is required at the south end of my land help reduce noise from the two round abouts. * Attention should be paid to light pollution. No intrusion of car lights on my land and my home. * During consultation there should be a comprehensive security system to the maximum the law allows. * The access to my property should be of a design that allows articulated vehicles, moden agricultural vehicles to enter and leave safely and with ease. ( The [redacted] property enjoys a legal agreement to access with no weight limit and I require that to remain). * Access to my property most be maintained at all times during construction . * The access to my property is via a gated road I require that to remain in the new road scheme. * The access to my property must enjoy all legal rights as it enjoys today and not to have any encumbered rights from the highway over and under ground. All my rights must be in perpetuity with full and unfettered permanent rights of access directly onto the highway. * The design of the scheme encourages the public to enjoy the immediate area of AONB( as it should do). It should be suggested the class 5 highway (single carriagewayt) running from Shab Hill to Ullenwood to become a restricted highway. H.E. should actively engage with the of Gloucestershire Highways regarding this matter. It must be pointed iout t will become a major nightmare of a rat run during construction endangering lives. * The decision of the new bridge over the road for the general public to enjoy the countryside comes out at the bottom of my drive. I request that there should electronic gates placed by H.E. at the bottom of my drive in order to prevent the public trespassing and causing disturbance of my home. * The current bus stop at the Air Balloon will be lost due to the scheme and therefore should be relocated at the new roundabout junction in order Shab Hill can still enjoyed public transport. * Double yellow lines should be placed on the new access from the roundabout junction to my place to stop any parking on the road that might hinder access [redacted]. * I leave these comments and observations open that they might have to be added to and expanded Robert William de Lisle Wells. I Robert de Lisle Wells of [redacted] ask will the water table be retained on my land? Reason I have the only pond and water coarse in the area. The lowering of the water table would result in a pond drying up being no more, causing devastation to the wild life drinking and feeding of swallows with several other birds which are enjoyed by all Life. * The area of Shab Hill has a high Radion count, how are H.E. addressing this carcinogenic gas? Regards R.w.de Lisle Wells"
Members of the Public/Businesses
Ralph Hampton
"AN IMPORTANT SAFETY ISSUE FOR NON-MOTORISED USERS OF RIGHTS OF WAY The proposed bridleway from the Ullenwood Junction to Crickley Hill Park entrance needs to continue alongside Leckhampton Hill Road, at least as far as Coberley BridleWay 10. This would provide an excellent safe route for horse riders and cyclists that runs parallel to the Cotswold Way footpath that goes along the length of Crickley Hill. A third separated lane for WCH, as proposed for B4070 from Shab to Barrow Wake should be considered, with an appropriate speed limit. Given that horses are NOT allowed by law to go on pavements, you can clearly see that horse riders, cyclists and pedestrians currently have no option but to fully occupy the narrow lanes on this very busy road that is not safe for non-motorised users, and will inevitably become even busier and even less safe once the scheme has been built. I note that the red line project scheme area continues right up to Coberley BridleWay 10, along the NW side of the Leckhampton Hill Road, with a considerable area on the SE side of the road extending towards Star College. You are re-building the road at least as far as the wood on the left side, (heading NE). This would therefore be a very low cost and effective improvement to the rights of way system. I made this proposal in response to the 2020 consultation process. It was unfortunately not taken up. It does however in my opinion offer an opportunity to make a major improvement to the safety and efficacy of the Rights of Way network around the project at very little cost."
Members of the Public/Businesses
Rosanna Hodson
"This representation sets out why I am against the A417 Missing Link scheme. The EIA has concluded permanent significant adverse effects on landscape, biodiversity, cultural heritage. I do not see the benefits of spending a huge amount of money to the detriment of a valuable area of Cotswold area of outstanding natural beauty, for such a limited gain such as less traffic. I do not see the benefits in any way, the government should invest 500 million in other means to improve transport in the area or help change permanently behaviours in how we travel. I do not think that impacting the Cotswold AONB landscape by building a road on the highest point is a great idea. Especially as the area benefits economical from its beauty."
Other Statutory Consultees
BNP Paribas Real Estate on behalf of Royal Mail Group
"Royal Mail does not have an in principle objection to this proposed road scheme but is seeking to secure mitigations to protect its road based operations during the construction phase. Under section 35 of the Postal Services Act 2011 (the “Act”), Royal Mail has been designated by Ofcom as a provider of the Universal Postal Service. Royal Mail is the only such provider in the United Kingdom. The Act provides that Ofcom’s primary regulatory duty is to secure the provision of the Universal Postal Service. Ofcom discharges this duty by imposing regulatory conditions on Royal Mail, requiring it to provide the Universal Postal Service. The Act includes a set of minimum standards for Universal Service Providers, which Ofcom must secure. The conditions imposed by Ofcom reflect those standards. Royal Mail is under some of the highest specification performance obligations for quality of service in Europe. Its performance of the Universal Service Provider obligations is in the public interest and should not be affected detrimentally by any statutorily authorised project. Royal Mail’s postal sorting and delivery operations rely heavily on road communications. Royal Mail’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. Royal Mail is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on Royal Mail’s operations, its ability to meet the Universal Service Obligation and comply with the regulatory regime for postal services thereby presenting a significant risk to Royal Mail’s business. Royal Mail has five operational facilities within 12 miles of this road scheme, in Cheltenham and Gloucester. The Traffic Management proposed for this scheme has potential to present risk of construction phase impact / delays to Royal Mail’s road based operations on the surrounding road network. Every day, in exercising its statutory duties Royal Mail vehicles use all the main roads that may be impacted by any additional traffic arising / delays during construction of this scheme. Any periods of road disruption / closure, night or day, have the potential to impact operations. Royal Mail does not wish to stop or delay this scheme from being constructed, but does wish to ensure the protection of its future ability to provide an efficient mail sorting and delivering service. In order to do this, Royal Mail requests that: 1. the DCO includes specific requirements that during the construction phase Royal Mail is notified by Highways England or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and on the content of the final CTMP, and 2. the final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary as identified above). Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed."
Members of the Public/Businesses
Sebastian Chesmore
"The noises from the A417 which runs to the south of our house is already noticable at most times of the day and this will only get worse with the road being brought closer. The residents of Birdlip have always complained about road noise and moving the road towards Cowley only moves the problem rather than solving it. This being said, the representation by the parish council can also be seen as conflict of interest when we share a parish with Birdlip. I also don't feel that there has been proper consideration for the construction and traffic problems involved with the samll back roads around Cowley and Elkstone becoming more dangerous with commuters trying to avoid construction ."
Members of the Public/Businesses
Susan Hamilton
"I wish to submit my representation to be registered as an interested party for A417 Missing Link, Planning Inspectorate Reference: TR010056. I am a property owner in the village of Cowley, a short 7-minute walk from the proposed Route 30 which I strongly oppose for the following reasons; A. Environment & Nature - Option 30 in my opinion is the worst possible route for the environment. Destroying natural habitat, grassland and woodland is contradictory to the 2015 Conservative manifesto and the proposed scheme also goes against the National Planning Policy Framework (paragraph 176 & 177) of protecting the AONB. Other route options would do much less damage to the environment. Route 12 is a better option, following the existing route of the A417. Alternatively, the A3 Hindhead tunnel is good example of how to resolve the conflict between traffic and natural, unspoilt countryside. The 4-mile tunnel is a clean and fast connection from Portsmouth to Guildford. The Cotswolds have recently been earmarked to be elevated from AONB to National Park Status and therefore demands to be protected. B. Pollution & Noise – the A417 has always been a contributing factor to air pollution within the area and with a prevailing south westerly wind, the relocation of the road and the increase in size will increase the amount of pollution moving the problem away from Birdlip to Cowley, merely shifting the problem onto a different population not solving the problem. It's non-sensical. C. Birdlip and Cowley share a parish council. The relocation of the road from Birdlip to Cowley obviously creates a conflict of interest and as such Cowley hasn’t been fairly consulted by Highways England with no record of notes or meeting minutes available for reference. D. Construction Impact – all transport upgrades have a detrimental impact on local roads. The local roads are already in a poor condition and with construction traffic being stored on local land, the fragile infrastructure will deteriorate as they are not fit for purpose in their current state. Local Farms and businesses will be devastated and the safety of our children who are currently free to roam in our village will be compromised. E. Economy - an expansion of the road will do little for the economy of the region. The A417 is a connection between the M4 & M5. Traffic projections for such road projects are typically overstated for financial modelling purposes and with the effect of Brexit and COVID any previous models need to be updated to consider current and future changes to working practices."
Non-Statutory Organisations
The Woodland Trust
"The Woodland Trust welcomes the opportunity to register a representation to the following project. We hold significant concerns regarding the removal of two veteran beech trees and a veteran sycamore tree referenced as T57, T126 and T127 within the applicant’s Arboricultural Impact Assessment (AIA) [APP-353], alongside potential detrimental impact to a number of other veteran trees adjacent to the scheme boundary. In addition, we are also concerned about damage and detrimental impact to Ullen Wood, an area of ancient semi-natural woodland recorded on the Ancient Woodland Inventory. Whilst the Trust acknowledges that there will be no direct loss of ancient woodland to facilitate the proposed scheme, we are concerned that Ullen Wood will be subject to noise and dust pollution during construction, as well as increased nitrogen deposition. As such, the Woodland Trust recommends that a buffer zone of 50 metres is implemented to mitigate for the above impacts during construction. This is in line with Natural England’s Standing Advice which states: “For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone.” Furthermore, The Trust asks that all trees displaying veteran characteristics are retained, and adequately protected during construction in line with Natural England’s Standing Advice which states: “A buffer zone around an ancient or veteran tree should be at least 15 times larger than the diameter of the tree. The buffer zone should be 5m from the edge of the tree’s canopy if that area is larger than 15 times the tree’s diameter.” In summary, the Woodland Trust objects to the proposed development on the grounds of detrimental impact to ancient woodland and direct loss of veteran trees. We hope our comments are of use to you."
Non-Statutory Organisations
Transport Action Network
"Transport Action Network objects to the A417 Missing Link road scheme on the following grounds: 1) It will increase carbon emissions by almost a million additional tonnes at a time when we should be rapidly reducing our emissions to reach net-zero by 2050. There will be significant increases in the fourth, fifth and sixth carbon budgets; the most critical periods to reduce emissions. However, we also believe that not all emissions have been included in these assessments and as such the totals are likely to represent an underestimate of the impact of the road on climate change. Cumulative impacts with other nearby road schemes and the rest of the roads programme have also not been addressed. These increases in emissions will make meeting the UK’s target of a 78% reduction in emissions by 2035 and its Nationally Determined Contribution (NDC) of a 68% emissions cut by 2030 under the Paris Agreement, even more challenging than they already are. With respect to assessing the carbon emissions arising from the new road, it is worth pointing out that the Government has now accepted the need to review the National Policy Statement for National Networks because there have been significant changes in circumstances and policy since it was published in 2014. The requirement within it to compare emissions arising from the whole of the UK’s carbon budget is clearly out of date. No other metric is assessed in this manner. For instance, comparing the purported economic benefits of the scheme against the entire GDP of the UK would likely render those economic ‘benefits’ even less significant. 2) It runs entirely within the Cotswolds Area of Outstanding Natural Beauty (AONB), and would introduce a new dual-carriageway into a sensitive and protected landscape. There is a very strong presumption in planning policy (NPPF and NPSNN) against building in an AONB unless there are overwhelming benefits. This scheme does not meet this threshold. 3) It severs two Sites of Special Scientific Interest (SSSIs) and will have a significant and permanent impact on rare and protected wildlife (including Barn Owls, bats, rare invertebrates, Red and Amber listed birds, and badgers), despite the proposed mitigation. 4) It impacts on the settings of Scheduled Ancient Monuments (SAMs), particularly Crickley Hill iron-age hill fort, and Emma’s Grove round barrows. 5) There is no evidence that National Highways have adequately considered non-roadbuilding alternatives to the proposed scheme, nor is there any indication that they have revised their plans in light of travel changes due to the COVID19 pandemic or the need for traffic reduction to meet carbon targets quickly enough. 6) The scheme will lead to an increase in air and noise pollution along the route and in the wider area due to the extra traffic it will generate, impacting on health and the enjoyment of the countryside"