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 18 May 2020
From Daniel Williams

Representation

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.