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A417 Missing Link
Received 02 September 2021
From 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.”