M54 to M6 Link Road

Representations received regarding M54 to M6 Link Road

The list below includes all those who registered to put their case on M54 to M6 Link Road and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Arrow County Supplies
"The M54 /M6 link is absolutely vital for the free movement of goods and services to and from the people and businesses of Shropshire and mid Wales and rest of the country. My company is in distribution, employing over 60 people in Shrewsbury and this link is critical to our expansion plans. We therefore 100% support the construction of this link road and the sooner it is started the better for all. Nothing should be allowed to get in the way of this important infrastructure improvement which should be completed as fast as possible before there are more accidents, delays , hold ups and frustrations for every motorist/driver that uses this important route."
Other Statutory Consultees
Eversheds Sutherland on behalf of Severn Trent Water Limited
"This registration is submitted on behalf of Severn Trent Water Limited (“STW”), a water and sewerage undertaker appointed under the Water Act 1989, with statutory duties to carry out water supply and sewerage functions throughout its appointed area, including the area where the works are proposed to be carried out under the development consent order, if confirmed. STW operates assets which are located in close proximity to the proposed works. A number of STW’s assets, which consist principally of two categories, namely (1) public water mains and (2) public sewers, may require diversion or are otherwise affected by the proposed works. Such assets are owned and operated by STW pursuant to statutory powers. It is essential that these assets remain in continuous operation in order to ensure the provision of water supplies to, and the effectual removal of sewage from, household and non-household customers. Whilst Schedule 9 Part 1 of the draft DCO contains provisions for the protection of electricity, gas, water and sewerage undertakers, STW wishes to ensure that it will remain able to deliver its essential public services at all times during the implementation of the works. Any works required to be carried out on STW’s assets must be planned and implemented to avoid risk of supply interruption or contamination, damage to the integrity of the water or sewerage networks, or environmental damage. Further, it is essential to STW that in the event of any alteration to or relocation of its assets, such work is carried out pursuant to STW’s statutory powers, so as to ensure that both existing and new water supply and sewerage assets unquestionably form part of STW’s statutory undertaking. STW may therefore seek additions to the provisions contained in Schedule 9 Part 1, or alternatively to seek to conclude an agreement with Highways England, incorporating appropriate provisions to enable STW to ensure that delivery of its statutory functions and essential public services are not put at risk. Pending conclusion of such additional provisions or agreement, STW wishes to register its interest, in order to afford the opportunity to submit further representations to the Inquiry, if necessary, so as to safeguard the ongoing delivery of these essential public services"
Members of the Public/Businesses
Steven Lacey
"The new road would significantly reduce the time of my daily commute"
Other Statutory Consultees
Historic England
"M54 to M6 Link Road. Planning Inspectorate ref: TR010054 Section 56 Planning Act 2008. Notice of an Interest in the Application by Historic England. We note that the DCO was submitted on 30th January 2020 and accepted for examination by the SofS on 28th February 2020. We note the documentation submitted in support of the DCO, especially the Vol 6, 6.1 ES, Chapter 6, Cultural Heritage, 6.8 Mitigation and Enhancement Measures. We have liaised with the Highways agency to minimise the impacts upon the historic environment through the process of design development and considering aspects of good design (as set out in Chapter 3 Assessment of Alternatives), and by embedding mitigation into the overall design approach to the scheme. In our second non-statutory response consultation response to Highways England of 10th October 2017, we advised that Option B West would have a detrimental impact on Hilton Park and that we favoured option C East. On the balance of consultation responses overall however, Option B West was chosen as the preferred route. Following meetings with consultants in August 2019 regarding the Western options, we set out on 13th August 2019 , on the basis of information then available, that Option 2 would result in a lesser degree of harm overall compared to Option 4. At that time the final Cultural Heritage ES Chapter was not available and we confirmed that additional analysis was required in order for us to come to a view on an overall assessment of the level of harm (in NPPF terms), judged by the AECOM consultants at that time to be ‘less than substantial’ upon Hilton Park for both Options 2 and 4 West (6.9.41). Whilst the overall impact upon Hilton Park may be ‘less than substantial’, our view is that because of the direct physical impact upon parts of the western boundary of the historic Park, and especially upon the lower belt, the shrubbery, the lower pool and surrounding woodland, the impact would in these cases be locally ‘substantial’. We agree (6.9.12) that subject to appropriate mitigation being agreed, the impact upon Hilton Hall (listed Grade I), including the conservatory and the gate-piers may be ‘less than substantial’. Engagement between Historic England and Highways England will continue as set out in Vol 5, 5.1, Consultation Report and this will provide a mechanism to develop overall detailed mitigation strategies. This will include a planting and detailed landscape design proposals (as set out in 7.8.6 and 7.8.8) and this should be informed by an expert and informed understanding of the development and significance of the historic landscape. The mitigation strategy should also consider aspects of lighting as set out in (6.9.47) and noise (6.9.46). The mitigation strategy should also consider opportunities for enhancement that may offset impacts, especially direct impacts, of the scheme. We would especially ask Highways England to investigate opportunities for the repair of Portobello Tower, an important ornamental feature (6.9.21) within the Park that is in a dilapidated state. In terms of archaeological mitigation we support the development of an archaeological mitigation strategy (AMS) and archaeological management plan (AMP) led by the County Archaeologist, as set out in 6.8.3, 6.8.4 and 6.8.5. We note that field evaluation is to take place following submission of the DCO, and that the results will inform detailed design details to be agreed before construction commences. That discussion should also include the other aspects mentioned in this submission."
Members of the Public/Businesses
Four Ashes Limited
"I am a director of Four Ashes Limited, who are the promoters of the West Midlands Interchange (WMI) development consent order (TR0005) located close to the proposed M54 M6 link road. The M54 M6 link road will have an impact on our project and we would like to reserve the right to comment on the proposals, in particular the highways details."
Local Authorities
Staffordshire County Council
"As a Host Authority we wish to confirm that we will be participating in the Examination. We will be making submissions in relation to: - traffic impacts; - the long term future of the A460; - procedures for approving details under the Requirements; - responsibility for maintenance of newly constructed highway; - Ecology, heritage and rights of way; - Flood risk and drainage."
Other Statutory Consultees
The Canal & River Trust
"Your ref TR010054 Our Ref IPP-94 The Canal & River Trust have previously confirmed to the promoter that the proposal is unlikely to have an adverse impact on any of our assets, unless the proposal or limits of development significantly alters. As the proposal and limits of development do not appear to have altered our our earlier response is still applicable."
Other Statutory Consultees
Osborne Clarke LLP on behalf of Western Power Distribution (West Midlands) PLC (Western Power Distribution (West Midlands) PLC )
"Reference TR010054 1. Western Power Distribution (West Midlands) PLC (WPD) is the distribution network operator (DNO) for the electricity distribution network for the area in which the proposed development is situated. WPD is regulated as a licensed operator pursuant to Section 6 Electricity Act 1989. Under Section 9 Electricity Act 1989, WPD is under a duty to develop and maintain an efficient, co-ordinated and economical system of electricity distribution. 2. WPD's assets consist of high voltage electricity cables which are situated in the Order land. 3. Article 20 of the draft Development Consent Order (DCO) (Document Reference 3.1) provides power to the undertaker to compulsorily acquire the rights of WPD over any of the Order land and to extinguish or remove or reposition WPD's assets within the Order land. 4. Schedule 1 of the draft DCO sets out the authorised development. This includes the diversion of WPD's high voltage electricity cables (including an overhead cable) as referenced at works numbers 67 and 70 in the draft DCO. In addition to these works there are a significant number of plots over which WPD have an interest. The Book of Reference (Document Reference 4.3) records the plot numbers within which WPD's apparatus is situated. WPD are reviewing these plots to establish the extent to which their apparatus are affected. 5. Paragraph 7.4.1 of the Statement of Reasons (Document Reference 4.1) sets out the test that the undertaker must meet in order for the Secretary of State to be satisfied that the DCO may authorise the interference with WPD's equipment. 6. Protective provisions for the benefit of WPD have been included in Part 1 of Schedule 9 of the draft DCO. The applicant has approached WPD to discuss the terms of the diversions and WPD has engaged with the applicant to discuss an engineering solution to the diversions. The applicant has engaged with WPD on the terms of the draft DCO and the protective provisions. 7. As currently drafted WPD considers that the protective provisions are not in a form that is acceptable to WPD. Whilst WPD consider that it is likely that agreement on the applicability of the provisions can be reached, at this stage the test for the protection of serious detriment to WPD's assets as set out in the Statement of Reasons has not been satisfied. WPD cannot therefore agree at this stage that it will not suffer serious detriment to the carrying on of the undertaking as result of the compulsory acquisition of land rights or rights over land. 8. In particular WPD considers that the timing of the requirement to undertake the diversions and the obligations on WPD as set out in the protective provisions to complete diversions is uncertain. It is also uncertain whether the diversions can be completed by WPD without the need to acquire third party interests in land outside the Order land. The protective provisions place obligations on WPD to undertake works that places developer risk on to WPD. Without resolution therefore WPD objects to the form of protective provisions and the powers sought by the applicant to compulsory acquire its assets or interests in land over which they are placed. 9. WPD however intends to work with the applicant to resolve the issues of concern following which it should be in a position to confirm its agreement to the proposed development."
Other Statutory Consultees
Public Health England
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project and can confirm that: With respect to Registration of Interest documentation, we are reassured that earlier comments raised by us on 2nd July 2020 relating to air quality and hydrogeology have been sufficiently addressed. We have no further comments to make with respect to health and wellbeing. In addition, we acknowledge that whilst the Environmental Statement (ES) has identified some residual public health impacts with respect to noise, a detailed explanation is provided as to why further mitigation was not deemed feasible. We welcome the detailed discussions on how the Scheme design has aimed to minimise noise exposure, how it achieves the three aims in the Noise Policy Statement for England (Chapter 11 para. 11.9.62 - 11.9.83), and the focus on noise mitigation at source (para. 11.8.1). We note that the Applicant has chosen not to present a quantification of the health effects attributable to noise in the Population and Human Health chapter. We are satisfied that the wider determinants of health have been adequately assessed, using a suitable methodology. On the basis of the documentation as reviewed, notwithstanding our comments, we 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."
Other Statutory Consultees
Ardent Management on behalf of Cadent Gas Limited
"Representation on behalf of Cadent Gas Limited (Cadent) to the M54 to M6 Link Road Development Consent Order (DCO) Cadent is a licensed gas transporter under the Gas Act 1986, with a statutory responsibility to operate and maintain the gas distribution networks in North London, Central and North West England. Cadent’s primary duties are to operate, maintain and develop its networks in an economic, efficient and coordinated way. Cadent wishes to make a relevant representation to the M54 to M6 Link Road DCO in order to protect its position in light of infrastructure which is within or in close proximity to the proposed DCO boundary. Cadent’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the order limits should be maintained at all times and access to inspect such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme have been reviewed in relation to impacts on Cadent’s existing apparatus located within this area, and Cadent has identified that it will require adequate protective provisions to be included within the DCO to ensure that its apparatus and land interests are adequately protected and to include compliance with relevant safety standards. Cadent has a medium pressure and a high pressure (major accident hazard) gas pipeline and associated below or above ground apparatus located within the order limits which is affected by the proposed link road. Highways England requires a section of Cadent’s high pressure gas pipeline to be diverted, but these diversions have not yet reached detailed design stage and so the positioning, land and rights required for the gas diversion included within the DCO may not be sufficient for Cadent. Cadent will not decommission its existing apparatus and/or commission new apparatus until it has sufficient land and rights in land (to its satisfaction) to do so, whether pursuant to the DCO or otherwise. This is a fundamental matter of health and safety. Cadent’s high pressure gas pipeline is affected in two sections by the proposed road scheme. The first section is covered by sheet 3 of the works plans and the pipeline would predominantly be within work no. 75 (hedgerow and species rich grassland). Hedgerow planting over or in close proximity to the high pressure pipeline would need to be carefully designed and agreed with Cadent to ensure it didn’t restrict access to maintain the pipeline. The second section is shown by sheet 4 of the works plans and the proposed diversion of the high pressure pipeline is indicated by work no. 68. A section of the proposed diversion runs through work no. 79 (woodland planting). It would not be acceptable to plant trees over the diverted high pressure pipeline as it would remove access and the roots could damage the pipeline. It is important that sufficient rights are granted to allow Cadent to maintain its gas distribution network in accordance with its statutory obligations. As a responsible statutory undertaker, Cadent’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. Adequate protective provisions for the protection of Cadent’s statutory undertaking have not yet been agreed between the parties. Cadent wishes to reserve the right to make further representations as part of the examination process but in the meantime will continue to engage with the promoter with a view to reaching a satisfactory agreement."
Parish Councils
Hilton Parish Council
"The applicants preferred route of the new road is in the Parish of Hilton, our objections are as follows: Very close to existing domestic dwellings Noise, air & light pollution Vibration from the volume of traffic Change of street scene - the properties will have a total change of view Loss of amenity - the properties now view the historic woodland park of Hilton Hall with it's trees, birds & nature Loss of natural flora & fauna Concerns about the on going M6 Diesel Garage on the A460 which HGV's use to fill up they are going to be exiting the new road and cutting through the village. Concerns that if there is a problem on the M6 the vehicles are going to exit and cut through the village. Concerns that there is no weight restriction on the A460 at Featherstone & Hilton."
Members of the Public/Businesses
BWB Consulting Ltd on behalf of M6 Diesel Services
"BWB Consulting Ltd are acting on behalf of M6 Diesel who operate the HGV filling station at Saredon on the A460, around ½ mile from M6 Junction 11. We have had some dialogue with Highways England (HE) prior to them making the DCO application, but we still have various key concerns unanswered. These concerns are: 1) Have HE allowed for traffic between the Saredon filling station and M6 Junction 11 and does their design of J11 have sufficient capacity for this (in particular the current A460 south arm) 2) Potential traffic regulations on the current A460 3) Signage at M6 J11 and M54 J1 Traffic A significant proportion are HGVs using the Saredon filling station are vehicles using the M6 and leave at J11 to use the site and then return to J11 and we are concerned that the revised J11, in particularly the existing A460 south arm, may have insufficient capacity. We met HE in August 2019 following which we agreed to obtain our own traffic data as there was no readily available data for the M6 Diesel site and HE had not undertaken their own survey. This was subsequently carried out at our expense and sent to HE in October 2019. HE had agreed when we met them that they would then review their traffic modelling to see if they have included for the correct level of traffic flow between the Saredon filling station and M6 J11. We are still waiting for HE to undertake this check and we have asked HE to confirm the following: • What traffic flows were assumed in the model between the M6 Diesel site and J11 • How this compares to the survey data which we sent in October • If there is a difference and our survey data is greater than what HE have modelled, we are seeking assurance that M6 J11 and in particular the A460 south arm, will have sufficient capacity based on the adjusted / corrected data. We will provide our traffic survey data with our Written Representation in due course. Traffic regulation on the A460 We are concerned that the powers sought in Article 16 are far reaching and whilst we could understand the need for these (which only apply to non-trunk roads) during construction of the link road, or indeed its maintenance, the powers could be used to introduce restrictions on the current A460 past our site that could be of significant detriment to our business (for example restrictions on HGVs). In our view, if permanent traffic regulation measures are required to mitigate the impact of the link road, then these should be identified early, consulted on, and express provisions made within the DCO. This would mean that they can be considered during the Examination process and not left to be dealt with afterwards via a process that on the face of it would offer less protection than should such regulations be proposed using standard traffic order processes. Signage Whilst we understand and support the wider objectives of the HE scheme, we clearly do not want to be at a commercial disadvantage as a result. Hence we request that signage from the roundabouts at both M6 J11 and M54 J1 to the Saredon filling station is provided. We appreciate that the facility is not a motorway truckstop or motorway service area and hence could not be signed from the mainline of either motorway, hence our request is for signage from the two junctions."
Members of the Public/Businesses
Nick Harris
"I am putting my views forward to seek an improvement to the current pedestrian control measure when crossing the A460 from the bottom of Hilton lane into the village of Shareshill. I have been in communication with representatives and all other responses have been answered fairly. I understand that it is perceived for traffic to be reduced following the implementation of the link road. However and regardless to this, the current crossing measures are not safe whatever the flow of traffic. The access to the current crossing bollards and the bus stop is not easy as a single pedestrian on foot let a lone when trying to maneuver a push chair, bicycle , dogs or a toddler. It should not take a serious accident or worse, a fatality for the crossing to be improved. Unless a driver takes pity and stops the traffic (normally in an unsafe way by breaking suddenly), you can stand there for a considerable length of time. I am not requesting an expensive upgrade, just a safer option with at minimum, improved access. The current pedestrian access is non existent with overgrown trees, uneven grass verge now and not a pathway with a range of unpleasant weeds sticking out. In addition to this, the local Councillor has been contacted on two separate occasions, within 12 months, for the access to be improved with no joy."
Other Statutory Consultees
National Grid Electricity Transmission PLC and National Grid Ga
"Representation by National Grid Electricity Transmission Plc (“National Grid”) to the M54 TO M6 Link Road Development Consent Order (“the Project”) National Grid wishes to make a relevant representation to the Project in order to protect its position in relation to infrastructure and land which is within or in close proximity to the proposed Order Limits. National Grid’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme have been reviewed in relation to impacts on National Grid’s existing and apparatus and land interests located within this area, and National Grid will require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. National Grid Electricity Transmission has a high voltage electricity overhead transmission line and a high voltage substation within/or adjoining the Order Limits. The overhead line and substation form an essential part of the electricity transmission network in England and Wales and are: • ZNB (275kV) overhead line route - Bushbury to Drakelow • Bushbury (275kV) Substation As a responsible statutory undertaker, National Grid’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. National Grid reserves the right to make further representations as part of the examination process but in the meantime is negotiating with the promoter with a view to reaching a satisfactory agreement."
Other Statutory Consultees
CT Planning on behalf of South Staffordshire Water Plc
"The proposed M54-M6 Link Road will conflict with one of South Staffordshire Water’s 24-inch potable water mains which is crossed by the proposed new link road. It is respectfully submitted that no consideration has been given, in the design of the proposed M54-M6 link, to the impact on the existing infrastructure. The proposed M54-M6 link would require South Staffordshire Water to divert a 24-inch potable water main. This would put at risk the supply of water to 4,700 properties within the Penkridge area and those committed within Development Plans. This could mean that Penkridge could be without water should South Staffordshire Water lose the water main; there is no substantial back feed currently available to support the village. Any loss of the main could also result in South Staffordshire Water taking Slade Heath borehole station out of supply. This would mean that 3.3 million litres per day would be lost and as a consequence pressure would be placed on Hednesford Reservoir and other feeds to the area. This may result in difficulties in maintaining supply during a summer period especially with committed housing coming forward through Development Plans in the area. It is the position of South Staffordshire Water that they cannot isolate the main to undertake the connections required to divert this asset without incurring a considerable cost and delay. South Staffordshire Water would have to undertake the diversion work in a way that allows existing and committed levels of service to be maintained using specialist construction techniques. However, these techniques are not risk free. Whilst South Staffordshire Water can attempt to mitigate these risks with suitable designs, there is still a chance that they would be unsuccessful, and the scenario listed above could still occur. There is no option that can be delivered where there is no risk to the maintenance of supply and levels of service to the 4,700 existing customers in the Penkridge area as well as those additional customers resulting from Development Plan commitments. Until a satisfactory design solution has been achieved for maintaining water supplies to the Penkridge area, South Staffordshire Water will object to the proposed M54-M6 link."
Members of the Public/Businesses
Elizabeth Whitehouse
"the land I am involved with south of the M6 I DISAGREE with the EXSESIVE tree planting that you have planed, the field is 14 acres and after the scheme could still be farmed or gain a rent off if only you would have put the access back. the compensation never covers the true amount lost and makes it impossible to purchase other land that come available. the land North of Junction 11 you are having under temporary ownership my only concern is maintained access and properly stock fence to enable me to continue to farm what's left why the scheme is going ahead."
Members of the Public/Businesses
Telent (NRTS) (Telent (NRTS))
"just interested to review design and to see what affect this will have on the HE NRTS network"
Local Authorities
City of Wolverhampton Council
"The Council wishes to participate in the Examination as and when it would aid the Planning Inspectorate in determining the proposal and will send either detailed written representation or relevant officers to the Examination discussions. We consider the proposal can make a significant contribution in terms of relieving traffic pressure around M54 Junction 2 and improving access opportunities for existing (i54, Four Ashes) and future development sites. Access to the M6 North would be significantly improved from the Wolverhampton area. The proposal will assist in keeping the right traffic on the right roads, improving safety which is largely within Staffordshire, and supporting the continued regeneration and economic growth in the City of Wolverhampton, by improving journey time reliability and connectivity. The Council will continue working with the Highways England (the applicant), South Staffordshire District Council, Staffordshire County Council to ensure that traffic management arrangements within Wolverhampton are fully assessed, and thereafter managed appropriately to minimise traffic disruption. Emergency diversion routes will need to be agreed. Prior to finalising the Traffic Management Plan, Wolverhampton would need to be included as a stakeholder. As cycling groups in Wolverhampton use the existing routes to the north around the Featherstone and Shareshill area, the Council will work with the applicant to ensure that good quality sustainable transport links are maintained outside of Wolverhampton. We would like to further understand the environmental implications if any adverse impact would arise on the WV10 – Pendeford, Fordhouses and Bushbury Landscape Character Area, and upon Bushbury Hill as it is within the area of Theoretical Visibility. Although the scheme will change traffic patterns to the north of the city, the scheme is unlikely to cause significant adverse effects in respect of Noise or Air Quality during construction or once operational upon residents within the Wolverhampton area. We note the Environmental Statement accompanying this application covers a number of key local impacts which are matters that will need detailed consideration predominantly by South Staffordshire Council and Staffordshire County Council, with some input from the City of Wolverhampton Council."
Local Authorities
Sarah Plant on behalf of South Staffordshire District Council
"South Staffordshire District Council supports the principle of the M54 M6 Link Road application for development consent, although would like the opportunity to highlight any potential impacts on local neighbouring amenity and heritage assets to ensure that appropriate mitigation is in place; and on that basis requests to register as an Interested Party."
Members of the Public/Businesses
Mr. B. G. Jones
"I do not want to sell this property, I have owned the property for 40 years. The land would only being used for drainage purposes, there is a stream at the bottom of the field that could serve the same purpose. The District Valuer does not pay the market price. He is renowned for paying lower than market price. REF: 20025358"
Members of the Public/Businesses
Mrs. V Jones
"I do not want to sell this land it has been in our family possession for 40 years. It is only being used for a drainage pool and not the motorway. If I did want to sell I feel the market value would be considerably more than the District Valuer pays, as you are notorious for undervaluing property and not giving a fair price. REF. 20025359"
Members of the Public/Businesses
Hinson Parry on behalf of Messrs Killingworth
"Messrs Killingworth's land appears to be taken completely for the scheme, and appears to be plot 6/15. Clients require early engagement with a view to potential land swap or redesign or early acquisition to enable them to relocate their horses, pigs and poultry."
Members of the Public/Businesses
Leslie Commins
"We have given all the assistance possible to the planners. Our concerns are the effects of this project on [] to assist in minimising any effect it may have on the property."
Members of the Public/Businesses
TDP(Property Development ) Ltd (TDP(Property Development ) Ltd)
"We act for one of the affected Landowners -Mr William Bibbey (ref: TR010054) We recognise the importance of this scheme to relieve local congestion and connectivity, so in principle this scheme is supported However, we have concerns that the amount of land and permanent rights to be acquired is excessive for what is needed to complete the scheme. In particular parcel 4/17a covers land that has development potential so any permanent rights acquired need to be kept to a minimum in order to minimise any sterilisation of that land"
Members of the Public/Businesses
Featherstone and Shareshill
"As the ward councillor for Featherstone and Sharehill, I would like to ensure that the local communities I represent in and around the proposed road improvement scheme receive the appropriate and necessary mitigation to minimise the impact of the development on them. Featherstone, Hilton and Shareshill will be directly impacted - both positively and negatively - by the M54/M6 Link Road proposal. I broadly support the principle of the M54/M6 Link Road application as it will bring much needed improvements to the A460 running through our villages, and these improvements will bring benefits to the wellbeing and amenity of the vast majority of local residents when the road is operational. There are however several points of contention that I wish to seek assurances that the section of the proposed link road that goes nearest to the residents of Dark Lane, would not be better placed further east and in doing so improve their living conditions and amenity of the residents of Dark Lane. I have concerns about the noise pollution and air quality levels affecting the nearest properties in proximity which are only a short distance from the link road. I also have concerns about the excess effect of traffic along the A460 from junction 11 of the M6 to the toll road towards Cannock, have the impacts of the cumulative development traffic of the West Midlands Interchange, the McCarthy Glen retail park at Cannock and the additional traffic coming off the link road been taken into account ? as the original link road proposal continued directly into the toll road thus avoiding what could now be potential congestion on the A460 north, leading to rat running along the adjoining country lanes. I would also like to be assured that my residents would still have access to the public footpaths already in existence in the area, we would need a green bridge over the link road in order to continue the pleasure of walking local designated footpaths. I have concerns about HGV vehicles accessing the M6 Diesel site on the A460, although I would not want to stop the legitimate fuel business on A460 near Shareshill I would want any HGV's being routed back to Junction 11 to join the motorways and beyond and not be allowed to continue along the becalmed A460 south through our villages Mitigation and agreements; Removal of the Mile Wall Featherstone, where this old mile wall is moved I would like it rebuilt using the existing stone at the other end of the mile wall near the Avenue in Featherstone. Restoration and stabillization of the Portobello Tower [Grade 2 Listing]. Removal of the unstable corrugated sheet fencing along Dark Lane and restored with new link road perimeter fencing. More woodland is needed along the perimeter of the link road between Hilton Lane rising up to Junction 11 on the western side in order to mitigate the noise and visual effect from the link road up on the village of Shareshill. It is my contention that Hilton Green environmental project should be considered for additional mitigation measures, given the scheme's environmental impacts. my understanding is that Highways England indicate that biodiversity impact can be offset within the red line of the scheme , by avoiding a significant net loss of biodiversity. however, the National Planning Policy Framework [NPPF] indicates that the schemes should strive to go further than this, seeking to provide "net gains" for biodiversity NPPF para 170 [d]. I'm not aware of any reason why the scheme can only feasibly avoid a net loss of biodiversity, rather than seeking to achieve net gains, and projects in the nearby area but outside of the red line could play an important role in achieving this. I understand that the scheme needs to achieve a satisfactory balance against all policy requirements to be granted consent, but that does not mean that opportunities to improve the scheme's credentials should not be ignored, particularly as the NPPF advocates achieving net gains against all strands of sustainable development. Ultimately, I want to ensure that the final scheme's design is the best form of development possible, and am strongly opposed to the notion that the scheme's demonstrable highways benefits offer any reason to unnecessarily dilute its compliance with other local and national policies on amenity or biodiversity/the natural environment. I would like the opportunity to highlight potential impacts on the local neighboring amenity to guarantee that appropriate mitigation is in place within and around the proposed scheme for the benefit of the local community, and on that basis I request to register as an Interested Party. ."
Members of the Public/Businesses
Atchams on behalf of Mr and Mrs Byard
"Client is Mr & Mrs Byard. They own land - plot ref 6/10 and referred to in correspondence with ref: TR010054. The property is identified as marginal land to be used for tree planting/eco mitigation ancillary to Link road construction. Landowner does not want to relinquish ownership and is happy to engage through a Statement of Common Ground (SoCG) to agree means of facilitating HE requirements without the need for HE to use powers to acquire."
Members of the Public/Businesses
Paul Simkin
"I am a land owner directly affected by the scheme and feel that Highways England have little to no regard to the devastating impact it will have on our farm. We feel the road is not required and land that has been farmed for generations in our family will be destroyed. The impact it will have on our lives, home and business will be catastrophic."
Members of the Public/Businesses
Roythornes Solicitors on behalf of Persimmon Homes Limited (FAO Alastair Stewart) (Persimmon Homes Limited (FAO Alastair Stewart) )
"This representation is made on behalf of Persimmon Homes Limited who have just been advised that land that they have an interest in is proposed to be acquired as a result of the proposed scheme, both permanently and for carrying out of works. Persimmon do not appear to have been served with requisite notice but have been informed by the freehold owner of the land. The land in question is land being promoted by Persimmon for residential development. There are concerns as to the extent of the land take proposed by the Acquiring Authority and the justification of the inclusion of the said land, which potentially may be excessive subject to clarification by the Acquiring Authority. While this is not an objection to the principle of the proposed scheme, constructive dialogue with the Acquiring Authority will be required before Persimmon can have the relevant comfort they would require as the land is earmarked for housing delivery, which of course has significant wider implications. Persimmon would therefore like to reserve the right to make representations in respect of the above matters if they are unable to be satisfactorily resolved with the Acquiring Authority in advance of any Examination proceedings."
Members of the Public/Businesses
i-Transport LLP on behalf of St Francis Group
"These representations are prepared on behalf of St Francis Group (SFG) who has owns the Royal Ordnance Factory (ROF) at Featherstone in South Staffordshire. The ROF site is close to the scheme which is the subject of the proposed DCO. SFG is one of the UK’s leading regeneration specialists and is an expert in brownfield development; the Group’s development pipeline covers all market sectors but with a particular emphasis on commercial and residential brownfield opportunities. The ROF site is allocated in South Staffordshire Council’s 2018 Site Allocations Document as a key employment development that will deliver a significant level of jobs, in an employment cluster that includes the i54 site, of regional significance. SFG wishes to express overall support for the M54-M6 Improvement Scheme (the Scheme) which will increase the overall attractiveness of the ROF site by providing enhanced strategic access from the motorway network. However, SFG has concerns regarding two matters related to the detailed traffic modelling and forecasting that has been conducted to support the Scheme: 1. That the ROF allocated site has not been included in the Core Scenario used in the traffic forecasts of the Scheme. SFG considers it is vital that the traffic generated by the ROF site (and other strategic sites/allocations) is included in the design of the Scheme and the assessments of its effects on the wider highway network. SFG notes that the Transport Assessment Report submitted to the Examining Authority for the Scheme (TR010054 Volume 7 document 7.4 TAR) identifies the ROF site on its Figure 4.3 as ‘More Than Likely’ and that its following paragraph 4.3.13 notes “the development sites with the higher certainty levels of Near Certain (NC) and More Than Likely (MTL) were included in the Core scenario traffic Forecasts”. However, SFG now understands that this is not the case and is concerned regarding the implications of this, which are yet to be evaluated (as the position has only just been made clear). 2. It is not clear that the full impacts of the Scheme on changes in traffic flows resulting from it have been fully assessed and therefore whether its impacts have been appropriately mitigated. In particular, SFG has concerns regarding the potential impacts of the Scheme at Junction 2 of M54 and whether the Scheme itself results in the need for improvements in capacity. SFG wishes to work with the Scheme’s promoters, Highways England, to resolve these matters and is confident that they can be resolved in advance of the examination of the Scheme’s proposed DCO but wishes to register these representations such that SFG can be represented at the examination if this is necessary."
Non-Statutory Organisations
Staffordshire Chambers of Commerce
"Mr Andrew Kelly – Project Manager M54 M6 Project Team Highways England 2 Colmore Square Birmingham B4 6BN Dear Mr Kelly M54 to M6 Link Road – Planning Act 2008 Section 56: Notifying Persons of Accepted Application. The Infrastructure Planning (Applications Prescribed Forms and Procedure) Regulations 2009: Regulation 9 Thank you for your letter of 9th March 2020, concerning the above. Staffordshire Chambers’ of Commerce is the voice of the business community in Staffordshire. With more than 1,200 member businesses across the county and beyond, we represent our members’ views on the local, regional and national issues affecting their business. In response to your letter of 9th March 2020, we have asked our Stafford Chamber Local Area Advisory Board and our Transport Forum, to provide an overall response to proposals to build a new road, which will link the M54 and M6 North, in the south of Staffordshire. We feel that the proposed road is a much-needed link road and would certainly benefit the whole of the Staffordshire Chambers' area. The proposed road would help to create a new link from the M54 onto the M6 North and this would help to reduce traffic on local routes including the A460 in and around the village of Featherstone and also along the A449 through Penkridge and as far as north as its junction with the M6 near Stafford. This will serve to improve connectivity between Stafford/mid Staffs and the M54 Corridor to the north of Wolverhampton. Further afield, the proposed road would also help to reduce traffic heading between Staffordshire and Shropshire along the A53 and A519. A significant proportion of this traffic is made up of HGVs and such a reduction will bring much needed relief and improvement to environmental quality of life in rural communities in places like Eccleshall & Woodseaves. The proposed road will serve to reduce congestion on local roads but we would like to suggest that consideration is given to creating access onto the M6 Toll. This would allow traffic from Wales and Shropshire to feed onto the M6 Toll, offering a route which would completely by-pass the congested M6 stretch through the West Midlands conurbation, particularly at times when congestion is increased by road closures. In addition to the previous points, we would like to suggest that any structures would need to be designed to be considerate of National Grid heavy loads. We would like to be kept posted of any proposed changes to structures at M6 (junction 11) and M54 (junction 1), which may be re-aligned. As a dual carriageway link, we would welcome any updates to be confirmed, prior to final design. If you would like to discuss any of the points raised in this letter, my colleague Declan Riddell, would be happy to hear from you : [email protected] Yours sincerely, Sara Williams, CEO, Staffordshire Chambers of Commerce"
Members of the Public/Businesses
FieldFisher LLP on behalf of Allow Limited
"M54 to M6 Link Road Planning Inspectorate Reference: TR010054 1. Introduction Allow Ltd (“Allow”) is the owner of interests in land which the applicant seeks to acquire by compulsion. Allow is an interested party falling within the definition set out at section 102(1)(aa) of the Planning Act 2008. 2. Objection 2.1 Allow objects to the compulsory acquisition of its rights, interest and property in respect of all its rights and interests identified in the Book of Reference. 2.2 Allow objects, in particular, to the acquisition of plots 4/20a, 4/20b, 4/20c, 5/2 and 5/4 and of permanent rights over plot 4/20g. It is Alllow’s case that the conditions set out in section 122(2) and (3) of the Planning Act are not met in respect of those parcels of land. A brief outline of Allow’s case in relation to each plot is set out below. 2.3 Allow notes that the Applicant for the DCO seeks to acquire 17.61 ha of its Hilton estate. Of that land 2.9 ha is required for the construction of the proposed link road and 14.71 ha for mitigation measures. Allow do not accept that it is necessary to take 14.71 ha of land to mitigate the impact arising from constructing a road on 2.9 ha of land. In addition the acquisition of the land will adversely affect Allow’s farming business which is accessed off the A460 and Hilton Lane. The access to Allow’s equestrian business, from Hilton Lane, is also likely to be adversely affected. Allow let the ponds on the land for fishing. Access to the ponds is from the A460. The fishing business will be adversely affected. Those ponds that remain will no longer offer the tranquil environment currently enjoyed. (a) Plot 5/2: i. Among the purposes for which Plot 5/2 is said to be required (as set out in Annex A to the Applicant’s Statement of Reasons) is “……….the establishment of environmental mitigation to the West of the Link Road Including habitat creation (Woodland planting and ecology ponds to mitigate for biodiversity loss)”. ii. The land to the west of the proposed road is not required for the development to which the development consent relates, namely the construction of a highway. iii. The land is not required to facilitate and is not incidental to the construction of a highway as it is not accepted that the extent of the mitigation proposed is required. If it were established that such mitigation is required: 1. It is not necessary to take the entirety of plot 5/2 to provide woodland planting to integrate the development into the landscape (as referred to in the description of Work No.81). 2. It is not necessary to locate mitigation measures for biodiversity loss on plot 5/2. There are alternative sites on which to provide such mitigation. (b) Plot 4/20a, 4/20b, 4/20c, and 4/20g i. The Applicant seeks to acquire all interests in plots 4/20a, 4/20b, and 4/20c, and temporary possession and permanent rights over plot 4/20g. ii. Allow objects to the application to acquire all interests in plots 4/20a, 4/20b, and 4/20c, and rights over plot 4/20g. iii. Among the purposes for which Plot 4/20c is said to be required (as set out in Annex A to the Applicant’s Statement of Reasons) is “……….the establishment of environmental mitigation areas to the west of the Link Road. Habitat creation (ecology pond creation, hedgerow, marsh and wetland grassland and species rich grassland} to mitigate for biodiversity loss and integrate the Scheme into the surrounding landscape. Woodland planting to screen views of the scheme”. iv. The land to the west of the proposed road is not required for the development to which the development consent relates, namely the construction of a highway. v. The land is not required to facilitate and is not incidental to the construction of a highway as it is not established that the mitigation proposed is required, and if it were established that such mitigation is required, it is not necessary to take the entirely of Plot 4/20c to provide such mitigation, and/or there are alternative sites on which to provide such mitigation. Allow has offered to make land to the east of the proposed alignment available to provide for mitigation. Such land could be used for mitigation without any undue impact on the historic parkland. vi. It is not necessary to take plots 4/20a and 4/20b for the construction of the road or to facilitate or as incidental to the construction of the highway. Insofar as it is established (which is not accepted) that it is necessary for the Applicant to retain a right of access for construction or maintenance of the proposed temporary or permanent rights would suffice. Acquisition of plots 4/20a and 4/20b would prevent Allow from gaining access to its land from the A460. (c) Plot 4/20g i. Permanent rights over plot 4/20g are not required for the construction of the road, or to facilitate or for purposes incidental to the development. (d) Plot 5/4 i. Plot 5/4 includes land in close proximity to the dwelling house known as ‘The Shrubbery’. ii. One of the reasons relied upon for acquiring this parcel of land (as stated at Annex A to the Statement of Reasons) is to provide for the construction of a re-aligned Hilton Lane. iii. It is not necessary or appropriate to take land close to The Shrubbery in order to construct a re-aligned Hilton Lane. (e) There is no compelling case in the public interest to take the entirety of plots 5/2, and 4/20c, as the land is not required for the development for which the order is sought and as there is no requirement for any mitigation measures which may be established to be necessary to be carried out on these parcels of land. (f) There is no compelling case in the public interest to justify taking the entirety of plot 5/4 as it is not necessary to acquire the land to the north west of The Shrubbery for the purposes identified at Annex A to the Statement of Reasons. 2.4 Allow has registered as an Interested Party to reserve its position in relation to all its land which the applicant seeks to acquire, and to make representations about the Application in the Examination. 3. Previous Representation Allow has previously made representations to the draft DCO during the statutory and non-statutory consultation on 4 July 2019 and 11 December 2019. Notwithstanding the contents of those letters the Applicant has failed to provide any justification for the proposals to acquire Allow's land identified in plots 5/2, 5/4, 4/20a, 4/20b, and 4/20c and to acquire rights over plot 4/20g. 4. Applicant's justification for ecological mitigation on Allow's land 4.1 On 24 April by email timed at 15:32 the Applicant provided its technical assessment of its justification for laying out the ecological mitigation on Allow's land. Allow remain of the view that the approach taken by the Application in respect of the ecological mitigation is flawed and the proposed mitigation on Allow's land is unreasonable and unjustified. Given that Allow have been requesting the information since 4 July 2019 and it has only been provided on 24 April 2020 Allow has not yet had an opportunity to commission its own full expert reports. The lack of timescale has been further compounded by Covid-19 movement restrictions which have only been eased on 13th May 2020 and simply have not provided enough time to have these expert reports carried out. These reports will support and provide evidence of the flaws, inaccuracies and incorrect mitigation assertions included in the Applicant's technical assessment. For these reasons Allow reserves the right to submit technical evidence at a later time and asks for an agreed timescale to carry out its technical assessments. 4.2 The Applicant has failed to justify the rationale behind why the Applicant has placed all of the ecological mitigation it considers necessary to alleviate the impact of its scheme on Allow's land and not any other parties land. This justification has been requested as early as June 2019 and has failed to be provided. 4.3 Allow notes from the request for access from the Applicant's agents that the Applicant proposes to carry out further bat surveys on Allow's land and those surveys are required to be carried out on dates up to and including August 2020. In the circumstances it is unreasonable for Allow not to be able to commission its own experts to review these later surveys the Applicant proposes to carry out. 5. Flawed and inaccurate assessment of woodland planting by the Applicant 5.1 The Applicant advises in its technical assessment that the Scheme will result in a loss of 20.4 ha woodland planting and proposes to provide 25ha of woodland planting (largely on Allow's land) to compensate for the loss of woodland planting. 5.2 Allow's position is that the Applicant's analysis of the proposed woodland that will be lost i.e. 20.4ha is flawed and as a consequence the quantum of woodland planting the Applicant propose to lay out on Allow's land is fundamentally inaccurate. Allow requests that the Applicant provide detailed and clear evidence including overlay plans of the proposed Scheme forthwith. There are no plans available as part of the Application that demonstrate where the existing woodland the Applicant purports will be lost is located. The legal test is that there has to be a compelling case in the public interest to take Allow's land and the land is required for the development to which the development consent relates and is required to facilitate that development. It is not an opportunity to take land that is not required to facilitate the development consent relates. 5.3 The fundamental basis on which the Applicant is purporting to take Allow's land by compulsion is flawed and the Applicant has repeatedly failed to provide clear and accurate information despite requests. The Application documents do not contain any adequate information that demonstrates that there is a loss of 20.4ha of woodland planting and therefore the proposed mitigation cannot be necessary. Nor can it be the position that the Application contains no clear evidence of the amount of ecology that will be lost as a consequence of the Scheme. 6. Statement of Common Ground Allow wish to make clear that they do not consider that it has any common ground with the Applicant at present. Allow have requested justification for the proposed ecological mitigation on its land in its statutory and non-statutory consultation responses and at meetings with the Applicant and its agents in August and November. There has also been no formal response to the offers made by Allow and as set out the justification requested since 4 July 2019 was only provided on 24 April 2020 and in any event is inadequate."
Members of the Public/Businesses
Daniel Williams
"I would like to contribute to this DCO assessment as I wish to better understand what appear to be a number of errors and inconsistencies within the proposed scheme which will substantially reduce its potential effectiveness. The applicant’s Transport Assessment (TA) for the proposed scheme states in its opening sentence: …“The M54 to M6 Link Road aims to reduce congestion on local / regional routes, particularly the A449(T), A5(T) and A460 and deliver improved transport links to encourage the development of the surrounding area.” The overarching proposal objective is further explained in Paragraph 2.2.1 of Chapter 2 of the submitted Environmental Statement. Here two of the proposed scheme’s four primary objectives are stated as: - Keeping the right traffic on the right roads and improve safety by separating local community traffic from long distance and business traffic. - Reduce volumes of through traffic in villages, improving local community access. The A449 north of the M54 (J1) is the current signed route between the M54 eastbound and the M6 northbound (and M6 southbound to M54 westbound). This route experiences AADT of approximately 18,800 vehicles. Those vehicle movements pass through the villages of Standeford, Cross Green and Coven Heath. These three A449 settlements contain over 100 residential dwellings which reside within 50m of the A449 carriageways. Tables 11.13 and 11.20 of the submitted TA completely misrepresent the numbers of affected dwellings in the A449 corridor. Understanding the numbers of affected dwellings is a very basic and important starting point for the necessity of the proposed scheme. My family home is captured within the road section defined as []. How far south of Standeford this ‘section’ of the A449 extends is unknown and needlessly ambiguous on the part of the applicant. Submitted Figure 11.2 shows a sizable section of the southern A449 between J2 of the M54 and the A5 has been ignored by the applicant’s modelling assessment. Why this would be the case is a matter that needs urgent clarification. Table 11.20 of the submitted TA advocates that on the ‘A449 Stafford Road – South of Standeford’ vehicle derived nuisance noise will drop by 0.7 dB in the long term to 69.5 dB during the daytime. The extent of this reduction can hardly be considered a noticeable or particularly successful end result. The application’s Table 11:20 projections also do not appear to take account of various factors and built form that the 1988 ‘Calculation of Road Traffic Noise Manual’ (CRTN) advocates should be included in a highway sound modelling exercise. Inclusion of these variables would almost certainly leave the projected sound reductions at levels above 70dB in the village of Standeford and the other A449 villages. The submitted modelling for this scheme does not include an understanding of the night time flow regime along the A449, nor does it include or understand the full effects of the West Midlands Rail-freight Interchange (WMI) on the strategic road network around the proposed link road. Consent for the WMI scheme was given after the initial submission of this application and its technical appraisal and data. Given that that WMI scheme will induce a profound, adverse 180% increase in HGVs’ usage between the WMI site and the West Midlands conurbation along the A449, that usage is a variable that needs to be fully understood and considered by this scheme. The WMI site will also introduce a new link road between the A449 and M6 – effectively removing the A5 Gailey junction from the current M54-A449-M6 connection. The effect this new road will have on de-incentivising the usage of the proposed link road is also not fully understood or explained by the applicant. If the applicant fully apprises the 1988 CRTN variables it is highly probable the A449 route will be far more harmful (70dB plus levels) than is anticipated for residential receptors both with and without the proposed scheme. It is reasonable to assume that the A449’s sound pollution levels will be fractionally less harmful if the link road being proposed is built, nonetheless that assumption begs the question what more can be done to increase the effectiveness of the proposed link road to get it from 70dB plus to sub 55dB? If the A449 settlements are left with a reduced level that is still greater than 70 dB, the proposed scheme will have failed to achieve two of its four primary objectives. De-trunking the A449 so that it becomes a road that serves local traffic and slow moving HGVs serving the WMI should form a significant part of this proposal. Hoping the scheme will do something for the A449 but not knowing what that something really is, is not an acceptable approach. For the benefit of the Examining Authority and the viewing public the applicant needs to redo its patchy, out of date and inaccurate modelling of the surrounding road network as matter of urgency."
Members of the Public/Businesses
Bagshaws LLP on behalf of Messrs I & A Simkin
"Ian and Adrian Simkin are owners of interests in land which the applicant seeks to acquire by compulsion. Messrs Simkin are an interested party falling within the definition set out at section 102(1)(aa) of the Planning Act 2008. Objection: The permanent acquisition of plots 5/26, 5/27 and 6/25 for environmental mitigation is objected to, as the comprises an arable field parcel of Land Classification Grade 3a. The loss of good quality agricultural land is contrary to scheme guidelines and the NPPF. The permanent acquisition of plots 5/26, 5/27, 6/25 and 6/23 for environmental mitigation is objected to as it is considered excessive for the offsetting of only approximately 0.79 ha of arable land being taken for the road construction and we do not accept that the extent of the land proposed to be taken for mitigation, at 3.504 ha, is necessary and proportionate for environmental mitigation. It is considered that the extent of land taken for mitigation puts an excessive burden upon Messrs Simkin and that the mitigation should be reduced or located elsewhere. Messrs Simkin object to the acquisition of 6/23 where there is the proposed acquisition of the entire road frontage of the field parcel along the A460 with no provision for access and turning agricultural vehicles or for any other future uses. Messrs Simkin object to the acquisition of plot 6/31, for the provision of a bridleway, Saredon BW13. As part of the Environmental Statement (ES), the 2017 walking, cycling and horse riding (WCH) survey results showed no recorded users of this particular public right of way for the duration of the data collection period (Environmental Statement Chapter 12 [TR010054/APP/6.1]). The Environmental Statement Chapter 2 [TR010054/APP/6.1] sets out that the Environmental Masterplan includes measures to ‘ensure the connectivity of PRoW and other routes used by pedestrians and cyclists are maintained’, this is in opposition with the survey results. The route, Saredon BW13 is not used, as evidenced in Chapter 12 of the ES and therefore should be removed, as opposed to realigned, as part of The Scheme. The bridleway reaches a dead end at the southern end of 6/31 and does not offer any connectivity. Messrs Simkin object to the acquisition of plots 6/29 and 6/30 as we consider them to be surplus to the scheme and they are not being acquired for the development, or incidental to, the construction of the highway. They are situated to the Eastern side of the hedge from the highway and upon reference to the Works Plans will not be impacted by, or necessary for, the scheme. A narrow strip of land will be acquired for species rich grassland Environmental Mitigation which will be impractical (and virtually impossible) to manage on an ongoing basis. Previous Representation: On behalf of Messrs Simkin, Bagshaws LLP previously responded to Highways England on the 28th January 2020 following a meeting on 2nd December 2019. Permanent acquisition of plots 5/26, 5/27 and 6/25 was formally objected to in our response. The area comprises a grade 3a arable field parcel which we continue to request retaining. Additionally, we previously objected completely to the acquisition of plot 6/31 for the provision of a bridleway, Saredon BW13, which terminates at M6 Junction 11. It is not used, and has been unused for many years, it is considered dangerous and therefore, we feel unnecessary to be reinstated within the road scheme, especially as the increased road noise and proximity to traffic will not be expected to increase its use. No evidence has been provided to justify the acquisition of these rights. Losses to the Business: 1. The loss of land represents a significant loss to Messrs Simkin’s farming business, with the land representing nearly 8% of their arable land across their holding. 2. Acquisition of plots 6/23, 6/31 and 6/37, will negate the ability of the remaining field area to be used for arable production. Following commencement of the scheme works, this field may be only suitable for grazing due to the significant reduction of the field parcel and creation of an unworkable shape for arable operations. 3. If permanent acquisition of plots 5/26, 5/27 and 6/25 is pursued by HE then due to the number of approaches received by Messrs Simkin from developers interested in this land, compensation would be sought to claim hope value for development which brings into question the cost of the proposal to use this land for environmental mitigation. Proposal: If it is held that land has to be taken for environmental mitigation, then we would welcome the opportunity to discuss terms of the retention of the freehold, but subject to a management agreement for the management of the land in an environmentally beneficial way to help satisfy environmental mitigation requirements of the scheme."
Members of the Public/Businesses
Bruton Knowles LLP on behalf of Messrs Nigel and Paul Simkin
"We are instructed by Messrs Nigel and Paul Simkin who own land at Shareshill, affected by the M54 to M6 Link Road Project. We feel we should point out that there has been a lack of consultation by Highways England and our clients feel they have not received meaningful responses about their concerns (letters sent by Bruton Knowles - 3rd July 2019 and the 11th December 2019). The lack of proper engagement has made our clients feel as if their concerns are of little importance, with Highways England’s priority being Project delivery. This is a summary of our clients concerns again raised at a meeting with Highways England on the 27th February 2020; 1. Why did ecologists in undertaking their technical work not approach The Simkin’s? The Simkin Family have farmed this land for more than 100 years and therefore the Project could have benefited from their knowledge and in turn this could have mitigated the impact on land take. 2. Despite it being promised, The Simkin’s have not received a Statement of Common Ground (SOCG). The fact that a SOCG has been agreed with other parties such as Natural England disappoints our client. 3. Excessive ecological mitigation exacerbates the Projects effect on our client’s land as follows; - loss of good quality arable land/severed fields/access routes. - impact upon fishing and clay pigeon businesses. - impact upon riding routes used by their equestrian business. - loss of income/increased costs. As an example, during the meeting Nigel Simkin expressed his surprise that increased mitigation is required because of an area of existing ‘ancient woodland’ to the north of his land ownership. Through his own knowledge, this is an area of relatively young trees and furthermore is not designated as ancient woodland on the Natural England website. 4. A combination of excessive ecological mitigation and resultant boundaries for land take has left small sections of land that cannot be farmed effectively. 5. The Simkin Family have several vehicular access routes severed by the Project, not all of which have been acknowledged or replaced by the Project. 6. As mitigation for land access and footpath severance, the Project proposes to provide an accommodation bridge to allow access for farm vehicles and pedestrians. It was highlighted in the meeting by Nigel Simkin that this bridge will also be required for equestrian use as part of a diversion for a bridleway, a point which Highways England would have been aware of had they consulted fully. The proposed specifications for this bridge are important. In our client’s opinion, the proposed carriageway of 4.5 metres with a 1.25 metre verge either side is inadequate and unsafe, given that various uses of the bridge can occur simultaneously. This bridge also needs to be future proofed, as the proposed width is barely sufficient for the existing combine. As agricultural equipment is becoming larger, our client’s view is that the current design of the bridge is inadequate to accommodate both current and future use. In short, the bridge needs to be wider. 8. Our client’s land is being promoted for commercial development by Nurton Developments. We understand that the Promoter feels (as our client’s do) that there has been a singular lack of positive engagement in relation to Nurton’s plans, which is a pity in that constructive dialogue would have been in everyone’s best interests."
Members of the Public/Businesses
Bruton Knowles LLP on behalf of Mr and Mrs B Jones
"We are instructed by Mr and Mrs B Jones who are the owners of land directly to the []of the M6 Junction 11, which is affected by the M54 to M6 Link Road Project. We set out below a summary of the principal submissions we intend to make on behalf of our clients in relation to the application; We feel that there has been a lack of consultation with our clients by Highways England and we have not received any meaningful response to the issues in our Consultation Response Letters sent by us on the 3rd July 2019 and the 11th December 2019 other than a basic acknowledgement and an invitation to a meeting. This highlights the point we make in terms of a lack of proper engagement and why our clients feel that their opinions and concerns are of little importance to Highways England with delivery of the project being their sole priority. Given our clients concerns, at the very least we expected Highways England to have prepared a detailed response in readiness for the meeting which was held on the 25th February 2020. However, it soon became apparent during the meeting that the onus appeared to be on ourselves to lead the conversation. Notwithstanding this we raised the following points in the meeting; 1. The Project has an excessive area of land take for Ecological Mitigation with no justification provided. 2. Our clients’ land is included within an area of land being promoted for commercial development by Nurton Developments. We understand that the Promoter feels (as our clients do) that there has been a singular lack of positive engagement, which is a pity in that constructive dialogue would be in everyone’s best interests as well as use of the land. 3. We have been promised a Statement of Common Ground (SOCG) on several occasions by Highways England but this has not been received. The fact that a SOCG has been agreed with other interested parties including Natural England and not with a landowner whose livelihood is being affected is both a surprise and very disappointing. 4. Our clients stand to lose all their land because of an area of existing ‘ancient woodland’ on their neighbours’ property. The fact that ancient woodland had been identified in this location is a surprise to our client. Firstly, through their own local knowledge and secondly because this area is not designated as such on the Natural England website. We understand this area has only recently been designated ancient woodland through the course of consultation meetings between Highways England and Natural England. Such a decision with no input from our client, particularly given the impact this will have on them, is considered irresponsible."
Members of the Public/Businesses
Bruton Knowles LLP on behalf of Mrs E Whitehouse and Mrs S L M Arblaster
"We are instructed by Mrs Whitehouse and Mrs Arblaster who are the owners of land directly to the south of the M6 Junction 11 and which is affected by the proposed M54 to M6 Link Road Project. We set out below a summary of the principal submissions we intend to make on behalf of our clients in relation to the application. We feel that there has been a lack of consultation with our clients by Highways England and we have not received any meaningful response to the issues in our Consultation Response Letters sent by us on the 3rd July 2019 and the 11th December 2019 other than a basic acknowledgement and an invitation to a meeting. This highlights the point we make in terms of a lack of proper engagement and why our clients feel that their opinions and concerns are of little importance to Highways England with delivery of the project being their sole priority. Given our clients concerns, at the very least we expected Highways England to have prepared a detailed response in readiness for the meeting which was held on the 25th February 2020. However it soon became apparent during the meeting that the onus appeared to be on ourselves and the client to lead the conversation. Notwithstanding this we raised the following points in the meeting; 1. The Project has an excessive area of land take for Ecological Mitigation with no justification provided. 2. This ecological mitigation takes all our clients land which as Mrs Whitehouse confirmed in the meeting, will cause hardship, with a very significant impact on her farming business. Furthermore, given the location this land will be irreplaceable due to the fact that there is both limited alternative land for sale in the area and where land does become available there is a very high demand from non-farming interests. 3. Given that our clients have farmed this land for many years and have long term knowledge of this location, why have they never been approached to add value to the ecological/technical work that has been undertaken? This surely must be an oversight on the part of Highways England. 4. Our clients’ land is included within an area of land being promoted for commercial development by Nurton Developments. We understand that the Promoter feels (as our clients do) that there has been a singular lack of positive engagement, which is a pity in that constructive dialogue would be in everyone’s best interests as well as use of the land. 5. We have been promised a Statement of Common Ground (SOCG) on several occasions by Highways England but this has not been received. The fact that a SOCG has been agreed with other interested parties including Natural England and not with a landowner whose livelihood is being affected is both a surprise and very disappointing. 6. Our clients stand to lose all their land because of an area of existing ‘ancient woodland’ on their neighbours’ property. The fact that ancient woodland had been identified in this location is a surprise to our client. Firstly, through their own local knowledge and secondly because this area is not designated as such on the Natural England website. We understand this area has only recently been designated ancient woodland through the course of consultation meetings between Highways England and Natural England. Such a decision with no input from our client, particularly given the impact this will have on them, is considered irresponsible."
Other Statutory Consultees
response has attachments
Natural England
"Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Natural England confirms that we wish to be registered as an interested party in respect of this Nationally Significant Infrastructure Project. Our relevant representations (submitted separately by email) cover a range of themes and issues within our remit, as follows: • European Sites • Sites of Special Scientific Interest • Protected species • Ancient woodland and veteran trees • Biodiversity net gain • Soils and agricultural land classification (including best and most versatile land) Natural England is co-operating with the applicant by means of a statement of common ground. We propose to continue in dialogue with the applicant in the run up to the examination so as to address the following Issues: Please see attachment • Air quality assessment in the context of recent case law addressing in combination effects and the assessment and mitigation of air quality impacts on designated sites already deemed to be ecologically failing. Similarly with regard to ancient woodland, veteran trees and related compensatory habitats. • Soils, the conservation of soils resources, together with the conservation and restoration of best and most versatile agricultural land. • Biodiversity net gain – Notwithstanding the applicant’s ‘no net loss to biodiversity’ approach we would welcome a wider consideration of the scope for net gains through a review of the proposed mitigation and compensation proposals."
Members of the Public/Businesses
response has attachments
Shoosmiths LLP on behalf of Nurton Developments (Hilton) Limited (Nurton Developments (Hilton) Limited)
"Please see attachment"
Members of the Public/Businesses
Parliament
"As Member of Parliament for South Staffordshire, I would like to register as a interested party so that I can continue to represent the views of my constituents on these proposals going forward. While the link road will help to take traffic off the A460 - something which is long needed - I know that a number of constituents in Featherstone, Hilton and Shareshill have concerns about the plans, particularly in relation to noise pollution, the proximity of the road to homes, the effectiveness of the proposed noise mitigation measures and overall closeness of the current design to the village of Hilton. These are issues that I have previously raised with Highways England and I believe that it is vital to make sure that the impact on residents is minimised both in the long and the short term. Recent approval given to the West Midlands Interchange and HGV control measures stemming from this development will also need to be taken into account."
Other Statutory Consultees
BNP Paribas Real Estate on behalf of Royal Mail Group Limited
"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 this should not be affected detrimentally by any statutorily authorised project. The Government imposes financial penalties on Royal Mail if its Universal Service Obligation service delivery targets are not met. These penalties relate to time targets for: • collections, • clearance through plant, and • delivery. 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. Wolverhampton NE and Landywood DO are within 2 miles of the project and a further eight operational facilities within 9 miles: • Wolverhampton NW DO • North West Midlands MC/MED/LAN/DO • Cannock DO • Wednesbury DO/HUB • Walsall DO/DMB/PAR • Bliston DO • Brewood PAR • Alderidge DO The M6 and M54 are both strategically important distribution routes for Royal Mail services, important to mail handling and delivery at the regional and national levels. All Royal Mail vehicles / services that use Junction 1 of the M54 and Junction 11 of the M6 are at risk of delays during the proposed 3 year construction period. In exercising its statutory duties, Royal Mail vehicles use all of the local roads that the proposed new Toll Link Road will cross or be constructed adjacent to on a daily basis. Royal Mail wishes to ensure the protection of its future ability to provide an efficient mail sorting and delivering service to the public in accordance with its statutory obligations that may be adversely affected by the construction of this proposed scheme. In order to do this, Royal Mail requests that: 1. the DCO includes information on the needs of major road users and service providers (such as Royal Mail) and acknowledges the requirement to ensure that they are not disrupted though full consultation at the appropriate time in the DCO and development process. 2. the final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network. 3. Royal Mail requests that it is fully pre-consulted by Highways England on any proposed road closures / diversions/ alternative access arrangements, hours of working and the content of the CTMP. As well as, where possible provide potential alternative access arrangements for impacted Royal Mail sites and other business road users. Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed."
Members of the Public/Businesses
Ruth Shepherd
"I support this proposal - a much needed extension of the M54 and removing motorway/commuter and transport vehicles away from the A460 and the A449/A5 routes which are already congested. As a business owner in Shropshire, with significant travel required, I experience the congestion impact having the wrong traffic on the wrong roads. As a local councillor and board member of several organisations, I understand the impact this also has on the economy and this investment project will benefit not only those communities where the link road is proposed, but further afield."
Non-Statutory Organisations
Staffordshire Wildlife Trust
"NET BIODIVERSITY GAIN There is no table summarising the value, impact significance and mitigation for each ecological receptor and the residual impacts from construction and operation. We request this is provided for clarity, and all residual impacts are mitigated to achieve overall net gain. The results of the biodiversity metric calculations currently show a combined net loss of 61.89 biodiversity units. This is considered in the EIA to be no net loss. We do not agree- this is a large net loss which needs to be mitigated fully, to provide an overall net gain in line with the current NPPF and 25 year Environment Plan. The result is surprising given that significant areas of new diverse habitats are proposed. Defra Metric 2.0 has not been used to calculate the biodiversity impact. We consider this to be the most accurate method currently available, as it reflects more detailed impacts and includes connectivity. The assessment does not appear to include restoration of retained habitats. This could contribute a significant number of units in a shorter time than habitat creation from scratch. Avoiding the small direct impact on ancient woodland would also mean more habitat creation could be counted. We recommend the Defra metric 2.0 is used to re-calculate the figures, restoration of retained habitats is included, and any deficit of units resulting is mitigated off-site via agreements with landowners. Off-site mitigation should prioritise habitat restoration of existing ancient woodland or LWS and habitat creation that expands or links existing habitats. Outline Environmental Management Plan This looks to cover most aspects- a detailed management plan will be needed. DESIGNATED WILDLIFE SITES Local Wildlife Sites (LWS) Lower Pool SBI Has been assessed as no longer meeting LWS criteria, however is stated as being of county value. The scheme would result in direct permanent loss of 1.83 ha of woodland and 0.55 ha of standing water which is 37.7 % of the SBI Mitigation of 25.13 ha of new woodland, 0.7 ha of standing water and 1.04 ha of wet and species rich grassland, with improved habitat connectivity. This appears adequate, although no restoration of the retained SBI areas is mentioned- this should be included. Brookfield Farm (north-east of), Shareshill SBI The site was assessed as still meeting the SBI criteria, and part has been assessed as ancient. There would be a loss of 0.75 ha of woodland, 15% of the SBI, and temporary impacts to the Latherford Brook (Watercourse 5). Mitigation includes new woodland habitat around the SBI (see ancient woodland comments below) and 0.39 ha of new pools to the south, with habitat links along new embankments. This appears adequate, although no restoration of the retained SBI areas is mentioned- this should be included. Potential Local Wildlife Sites We welcome use of the Staffordshire LWS criteria to assess some habitats such as hedgerows, However as assessments were undertaken in July 2019, this is likely to have underestimated the value of hedgerow and woodland ground flora. We are concerned that not all high value habitats as listed in Appendix 8.4 Designated Sites and Habitats appear to have been assessed adequately against the criteria; many are considered county or local value. No raw data for the Phase 2 / NVC surveys or LWS assessments is provided. Several woodlands and some important species-rich intact hedgerows would warrant re-assessment at the correct time of year. The swamp at TN49 has not been assessed, despite it supporting nine grassland scoring species. Although of small size it is adjacent other habitats that should be assessed together. HABITATS Figure 8.3 Phase I Baseline Habitat Survey does not show habitat survey data for the area. Ancient woodland and Veteran Trees Within Brookfields Farm SBI – 0.0015 ha direct loss; 0.04ha assumed loss due to incursion into the 15 m buffer zone and a further 0.078 ha assumed lost as a result of the change in air quality. Provision of 3.08 ha of broad-leaved plantation (7:1 ratio) has been agreed with Natural England. Direct losses should be avoided by amending the road embankment to a retaining wall adjacent the site. Will any soil translocation occur? Woodland creation should include addition of dead wood and ground flora sowing from local sources. Oxden Leasow (Whitgreaves Wood) adjacent the M54 – This warrants SBI designation. No direct loss would occur and habitat improvement is proposed. Detailed management should be agreed with stakeholders. We are concerned that areas of potential ancient woodland may have been missed. There is a remnant of Oxden Leasow/ Whitgreaves Wood on the north side of the M54 which has not been investigated. Areas of ‘The Belt’ woodland adjacent to the A460 could possibly be ancient, as they appear on old maps and support some indicator species such as bluebell, dog’s mercury and wood melick. No veteran trees will be directly affected by the Scheme. Other Irreplaceable Habitats The EIA does not appear to have assessed whether any other habitats, such as important and species-rich hedgerows, may be ancient and meet the definition of irreplaceable habitats. This should be assessed, as any such habitat will need bespoke mitigation. Priority Habitats Swamp habitat- TN49 is a diverse swamp habitat supporting a diversity of wetland plants; there is no specific mitigation proposed. This habitat would translocate well and could be used to establish other wetlands on the site. Grasslands- no species-rich grassland would be impacted. We request that new species-rich grassland is created with seed or hay from local diverse meadows, not a seed mix, so that these areas are able to reach LWS quality in future. Hedgerows- There would be a net gain of 1.36km of hedgerow. However there is no mention of translocating any important or species-rich hedges- this should be considered as translocation provides faster establishment, reducing temporal effects and gaining biodiversity units. Semi-natural woodland- There would be a loss of 1.18 ha, although overall a net gain of 4.59 ha of non-ancient woodland types. New planting should emulate existing LWS woodlands and include topsoil inversion and ground flora establishment. Ponds and watercourses –a net gain is proposed in ponds and watercourse length which is welcomed. Nitrogen deposition Given that the scheme will increase local NOx deposition upon receptors that are already beyond their critical load, the scheme should contribute to the management of sensitive sites such as ancient woodlands nearby to off-set this impact. SPECIES We welcome the assessment of species populations against the Staffordshire LWS criteria. Where populations have been assessed to be of county importance, including Noctule, Myotis sp and Soprano pipistrelle bats, otter and watervole and GCN metapopulations, we request that Highways England works with the Staffordshire Wildlife Sites partnership to further investigate the need for designation. Birds There would be a direct loss of breeding territories of notable bird species during construction: one dunnock, five skylark, two song thrush and one lapwing. While new habitats would eventually mitigate for this, no short term mitigation is provided. A temporary off-site mitigation area should be provided particularly for ground nesting species. Hedgerow translocation and use of brash pile/ dead hedges as temporary nesting features would also reduce short-term impacts to nesting birds. Barn owl are at risk from vehicle collisions, although scheme design has sought to minimise this- monitoring of bird fatalities should be undertaken and if barn owl casualties are found, measures should be taken to compensate via provision of habitat and nest sites in safe areas away from the scheme Otter and water vole Presence has been confirmed within the Latherford Brook. Water vole should not be considered common in Staffordshire- they are potentially facing extinction. Therefore any watervole population may merit regional importance. Watervole evidence and otter resting sites are unaffected by the brook crossing, and adequate monitoring and habitat enhancement is proposed."
Local Authorities
Telford & Wrekin Council
"M54-M6 Link Telford & Wrekin Council Representation Telford & Wrekin Council welcome the proposals brought forward by Highways England for a north bound connection between the M54 and the M6. Although the proposals are located outside of the Councils administrative area the works will improve access to the M54 corridor, generating significant economic benefits for Telford & Wrekin. Telford is a key destination for inward investment and economic growth in the region and a significant destination for Foreign Direct Investment into the UK. It is located approximately 14 miles from Junction 1 of the M54 and benefits from excellent access to the motorway network south bound. North bound access through Featherstone has never been a feasible or suitable long term solution and the proposals for direct access onto the M6 and M6 Toll are very welcome. The central position (nationally) that Telford occupies, in relation to road / rail networks and port infrastructure, provides an ideal location for manufacturing, logistics and export potential. The continued investment potential of Telford can only be achieved through investment in strategic infrastructure such as the M54-M6 link. This needs to be part of a comprehensive strategy to open up access to and improve the capacity of the M54 strategic growth corridor. The Council are actively promoting better connectivity to the M54 through the proposals for ‘Queens Way Link’ which would see a direct connection between the M54 and the north / south A442. This is a critical piece of infrastructure that will enable direct access to two of Telford 3 strategic employment areas. This needs to include investment in rail infrastructure such as the electrification of the Shrewsbury – Telford – Wolverhampton rail line. A balanced approach to transportation investment will open up markets and attract inward investment. It would also increase the resilience of the strategic highway and rail networks and allow freight / passenger flows to switch between road and rail. The completion of the motorway network around the West Midlands with the construction of a link between the M5 and M54 / M6 is strongly supported by the Council. This will open up the M54 corridor and Telford for inward investment and improve access to export markets via ports of Bristol and Southampton. The route will also cement Telford’s position as the central point for manufacturing investment in the UK serving the home market. There is strong demand for sites in Telford and this has been seen in the large amounts of employment land brought to the market through the ‘Telford Land Deal’. This has seen, for example, investment in supply chain for the JLR engine plant such as the £78m investment by Magna Cosma in Telford. Telford plays a key role in providing employment sites for supply chain businesses that support many of the regions tier one manufacturing companies, there is further opportunity ‘scale up’ this role with the on shoring of supply chain as part of national and regional economic recovery plans. Telford has also seen high levels of housing growth delivering around 1,300 homes in the last year and remains one of the most affordable locations with the best range of employment and leisure opportunities in the country. Improved connectivity to the national motorway network will also be a welcome boost to existing businesses in the borough especially those in the leisure and hospitality sectors such as Ironbridge Gorge Museums, Telford International Centre and Telford Shopping Centre which together generate around 12 million visitors annually. In summary the Council are very supportive of the proposals and welcome the programme which would see a completed link in place by 2024. The need for this infrastructure was formally identified in 2001, there can be no further delay in this process given the need for a robust economic recovery. The proposals will bring a short term boost to the construction industry but will act as a long term accelerator for economic growth for Telford and the wider corridor."