M54 to M6 Link Road

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

M54 to M6 Link Road

Received 23 March 2020
From Historic England

Representation

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.