The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

A417 Missing Link

Received 31 August 2021
From Fisher German LLP on behalf of Alexander & Angell Ltd

Representation

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.