A556 Knutsford to Bowdon Project Team,Arun Sahni/Mohammed Swapan,

Highways Agency,A556 Project Managers,

Piccadilly Gate,3rd Floor, Lateral,

Store Street,8 City Walk,

Manchester,M1 2WD.Leeds,LS11 9AT.

Tuesday, April10th, 2012

Dear Sirs,

A556 KNUTSFORD TO BOWDON SCHEME: PUBLIC CONSULTATION

Since its inception in the late 1990s, the North West Transport Roundtablehas opposed the concept of either a new motorway connecting the M56 and M6 or an off-line dual carriageway solution as a means of addressing problemson the A556 where it lies between M56 junction 8 and M6 j.19in North Cheshire. We therefore do not support any of the options the Highways Agency is canvassing in its current consultation – all of which include a large amount of new highway infrastructure that is mainly off-line and all of which fail to offer a long term, sustainable solution, engender modal shift or reduce carbon.Nor, it should be noted, have the present proposals followed the instructions given to the Highways Agency nearly a decade ago by Alistair Darling,M.P., the then Transport Secretary, who told them to come forward with an on-line scheme.

The North West Transport Roundtable (NW TAR) acknowledges that problems exist on the A556 but we contend they call for a package of multi-modal and ‘smart’ measures - not a highways-only solution which we maintain will have more environmental disbenefits than benefits.

We would also point out that providing this type of infrastructure solution to the identified problems – which the Highways Agency themselves admit will result in more CO2 emissions overall – effectively fliesin the face of carbon reduction agreements that the UK is signed up to and the 2008 Climate Change Act. We note that major issues such as hard shoulder running, the Manchester Airport Enterprise Zone and SEMMMS have not been addressed or modelled and no wider economic benefit report has been produced. The published economic report relies totally on cost and benefit analyses and all options being consulted upon create new severance and other problems in the local communities whilst impacting on Green Belt, removing good quality agricultural land from production and promoting more traffic movements.

The proffered solutions are seriously flawed, run contrary to the thrust of the National Planning Policy Framework(NPPF) and the Department for Transport White Paper ‘Creating Growth, Cutting Carbon’ and should not be progressed.

The National Planning Policy Framework, March 2012

The National Planning Policy Framework (NPPF) came into force on March 27th 2012 and now sets the scene for allUK planning and transport policies. The Core Planning Principles include:

  • “…. protecting the Green Belts …, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”
  • “support the transition to a low carbon future in a changing climate ….”
  • “contribute to conserving and enhancing the natural environment and reducing pollution …”
  • “actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling …” (para. 17, pages 5 & 6)

The key transport chapter, ‘Promoting Sustainable Transport’, is very clear in establishing the sustainability credentials which plans and policies must have. It says:

“Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives … The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel” (para. 29, p.9)

“Encouragement should be given to solutions which support reductions in greenhouse gas emissions …” (para. 30, p.9).

The NW TAR contends that the A556 scheme is not in harmony with the NPPF.

The Department for Transport White Paper ‘Creating Growth, Cutting Carbon’, January 2011

The White Paper ‘Creating Growth, Cutting Carbon - Making Sustainable Local Transport Happen’ was published last year by the Department for Transport (DfT) along with the launch of the Local Sustainable Transport Fund. It was described as forming part of the government’s overall strategy to tackle carbon emissions from transport. Whilst the White Paper makes much of new technologies, it also emphasises the importance ofsustainable travel - public transport, cycling and walking - and it quotes the British Social Attitudes Survey of 2009 which said: “a substantial proportion of drivers would be willing to drive less, particularly for shorter trips, if practical alternatives were available” (para. 4, p.7).

In addition, the White Paper draws attention to the 2008 Climate Change Act which it describes as: “the world’s first national long-term legally binding framework” and which, it explains, “commits the Government to cut emissions by at least 80% by 2050” (para. 2.13). The connection is made between health and transport in relation to physical activity, road safety, air quality and noise in particular (paras. 2.17 - 2.30, inc.) and it discusses the need to plan for transport which takes into account the requirements of older people, the mobility impaired and those who live in rural areas (para. 2.13). It lauds the success of the ‘Sustainable Transport Towns’ initiative which ran from 2004 to 2009, noting that it represented very high value for money (highlighted boxes, p.34 & p. 38/39), and it commends approaches to transport planning that include smart choices (para. 4.5) and “a package of interventions” (paras. 4.7-4.9, inc., and figs. 4.1 & 4.2). It goes on to list a whole series of interventions and case studies which have worked well around the U.K.

NW TAR contends the A556 scheme runs contrary to the thrust of the 2011 White Paper and the approach to the scheme has been deficient because it has not considered packages of measures.

The Key Scheme Objectives/ The Need for the Scheme

According to the Highways Agency, the key over-arching scheme objectives are:-

  • Improve the local environment in Bucklow Hill and Mere
  • Improve road safety and journey time reliability
  • Reduce conflicts between long distance and local traffic
  • Minimise environmental impacts on the scheme, during construction and once open to traffic

Our view of these is as follows:

Improve the local environment in Bucklow Hill and Mere

Moving the alignment of the road merely results in a depreciation of ‘the local environment’ somewhere else – in this case Millington, Mere Halland Over Tabley in terms of settled areas but it also has significant impacts on biodiversity, wildlife, agriculture and landscape as is apparent from the Preliminary Environmental Information. Not to mention the need to provide for new ‘run-off’ facilities alongside the new road space. There would also be impacts from increased traffic flows beyond the immediate scheme – notably in Bowdon and Altrincham to the northand in communities along the A556 and the B5391to the south.

Improve road safety and journey time reliability

Both road safety and journey time reliability would have been improved some years ago if HA plans to introduce G junctions had gone ahead. The same aspirations could be achieved with a far more modest on-line improvement scheme, brought forward along with a package of other measures that included a network of quiet lanes and greenways for cyclists and walkers and crossing facilities for them plus improvements to the services on the Mid Cheshire Railway Line and introducing an important recommendation from the final MIDMAN multi-modal study report. This suggested establishing a parkway station near to where the railway crosses the M6 (just south of junction 19) where traffic from north, west and south wishing to travel towards Manchester could park up and either catch an improved heavy rail service or a light rail one provided by the extension of the Metrolink out to the same point (probably making dual use of the heavy rail line). Better rail rolling stock with space for cycles would also make a difference.

Reduce conflicts between long distance and local traffic

This could be best achieved with an improvement to M6 junction 20, but not an over-engineered solution such as that previously tabled by the Highways Agency and rejected by Alistair Darling when he was Transport Secretary. Traffic modelling at the time showed that an improved junction 20 would encourage more traffic to make the direct motorway to motorway connection between the M6 and the M56 and vice versa.

Minimise the environmental impacts of the schemes, during construction & once open to traffic

If one of the currently canvassed off-line schemes is built, it will be almost impossible to prevent pressures for building to take place on the unfarmable pockets of land that will be created – even though they are in Green Belt. This happens time and again with road scheme after road scheme up and down the country. The resulting new development itself then generates traffic.

A556 Preliminary Environmental Assessment

Our comments on the Preliminary Environmental Assessment (PEA) are as follows:

Chapter 2: Para. 2.2.5 states that most of the traffic is strategic. However, it is unclear whether or not a recent Origin and Destination study has been carried out or on what evidence this statement is based. (It should be referenced). It is also unclear what is regarded as ‘strategic’.

2.2.8It is important to note that the entire length of the scheme is already an Air Quality Management Area (AQMA).

2.2.9The existing road has a poor accident record – 118 injury accidents between Jan. 2005 and Dec. 2009 – 14 serious, 1 fatal (although it should be noted that this includes part of the A50 and A5034). However, the Highways Agency inexplicably withdrew previous safety schemes it had evolved for ‘G’ type turning arrangements at dangerous junctions similar to that which currently exists a little further to the south on the A556 at The Smoker Inn at Plumley.

2.3, 3.1 & 3.2The scheme history makes no reference to alternatives to road building having been assessed. Also, there is no mention in Chapters 2 or 3 of hard shoulder running having been taken into account in the design for the A556 scheme. It is only referenced in para. 16 under ‘Other relevant highway projects’ where it is acknowledged that hard shoulder running on the M6 between junctions 13 and 19 and on the M56 between junctions 6 and 8 do appear in the addendum to the Comprehensive Spending Review. But para. 16.3.7 attempts to dismiss this with the argument that it only has a “hypothetical likelihood of being implemented before 2030”. However, road schemes are now required under WebTAG to plan for 60 years ahead. (N.B. The New Approach to Appraisal – NATA – is not mentioned anywhere in the document and WebTAG – the DfT’s appraisal system – is only mentioned once in relation to air quality).

[Note: The ‘Advanced Motorway Signalling and Traffic Management feasibility study’ which was presented to the Secretary of State for Transport in March 2008 recommended hard shoulder running on the parts of the motorway system that had previously been considered for widening. In order for hard shoulder running to be introduced, physical alterations are required at junctions because hard shoulders disappear where slip roads leave and enter. This needs to be addressed - with landtake implications. Whilst NW TAR does not endorse hard shoulder running because it still generates more traffic and causes more greenhouse gas emissions, it considers it preferable to adding extra lanes and to new roads. If hard shoulder running is in the offing - and it seems it is - it would be illogical (not to say, poor value for money) for M6 j19 and M56 j8 to be re-built to serve the A556 scheme but for them not to be designed to incorporate the alterations necessary to accommodate hard shoulder running. (They would have to be re-built again at a further cost to the public purse). The Environmental Statement should cover the extra land that would be involved. Traffic modelling and emissions predictions should also take the impacts into account and the costings should be amended accordingly. The scheme needs to be judged - as a holistic whole - includingmaking provision for hard-shoulder running].

2.4 Environmental Objectives of Scheme. These are:

  1. To improve air quality in the Chester Road Air Quality Management Area (AQMA)
  2. To eliminate existing potentially adverse effects of highway drainage on Rostherne Mere and The Mere RAMSAR/ SSSI sites.
  3. To reduce traffic-related noise and vibration for local residents and
  4. To relieve community severance caused my heavy traffic on the existing A556.

Our responses to these objectives are as follows:

  1. The new line of the A556 would become the worst AQMA, bringing poor air quality to other areas such as Millington, Hoo Green and Mere Hall. However, the prevailing wind would ensure that the communities of Mere and Bucklow Hill are only marginally relieved of the air quality problems they suffer now, especially bearing in mind the fact that emissions from the new road would be higher than those from the existing road.
  2. This environmental objective begs the question – why are there no alternative plans in place in any event to ensure that highway run-off does not reach the SSSI sites? It should not be the case that a proposal has to come forward for new highway capacity before an issue such as this is dealt with.
  3. Traffic related noise and vibration could be significantly reduced if the existing road (or a slightly widened version of it, which accommodated a central dividing barrier), was re-laid with a low noise surface
  4. Community severance would still exist with the new proposals and there would in fact be new severance issues for communities such as Millington and Over Tabley

Chapter 5: Approach to Assessment refers to the Design Manual for Roads & Bridges but not to NATA or WebTAG. It is not clear why this should be the case.

5.4The ‘do minimum’ scenario is in effect is ‘do nothing’ and almost certainly does not take into account the flattening out of traffic growth that has occurred for several years now.

Chapter 6: The Air Quality chapter claims that properties on the existing A556 would have better air quality if the off-line A556 ‘Improvement’ were built. However, this may not be the case when they are up-wind of the scheme. This chapter actually admits that the new road would attract more traffic than the existing one. It also admits that emissions of greenhouse gases would increase and that other AQMAs exist within the study area (6.1.6) but detailed assessment is only being carried out within 200 m. of the centre of the new road. It is not clear why this is the case.

Chapter 7: Noise. The PEA claims reductions in noise for many people/ properties but an increase in noise for others. It assumes a low noise surface road. (Para. 7.3.1 assumes traffic noise will continue to increase and be a greater problem for those already affected if the new road is not built but offers no explanation as to why the existing road could not be re-surfaced with a low noise material).

Chapter 9: Landscape. This has a very understated approach. It fails to admit significant impacts in the executive summary. Para. 9.3.3 admits that all the land involved is Green Belt and merely provides the recognised definition of the purpose it serves. Para. 9.4.4 erroneously claims that the impact on Green Belt would be short term (repeated in 9.6.1 & 9.6.2) and 9.4.5 maintains the scheme would not undermine the purposes of Green Belt – a statement which takes no account of the likely gradual development of unfarmable pockets of land that nearly always occurs when new roads are built.

Para. 9.3.7 (Land Use) merely says that some of the land is agricultural. It does not explain that some is grade two land, although Chapter 14 – Community & Private Assets – does admit that 80% of the land to be taken is agricultural and most of it is good quality land. However, figure 14.4 showing agricultural land classification does not separately highlight grade 3a land.

Para. 9.4.14 admits that Millington would be sub-divided and ‘severed’.

Paras. 9.4.28 & 9.4.29 are vague on the amount of lighting that would be used on the road and therefore the subject of light pollution in the countryside is not properly addressed.

Chapter 10: Ecology - admits there would be fragmentation and the loss of sensitive habitats, including ponds and woodland. There is a much evidence of otters (10.3.46) and great crested newts (10.3.43), 11 ‘Red List’ species of birds (11.3.52) and many sightings of barn owls (10.3.50 & 10.3.51). Thirteen of the 67 wintering bird species identified are on the ‘Species of Principal Importance in England’ list (10.3.54). A lot of badger activity is recorded (10.3.49) and “at least” six species of bats (10.3.48) but, despite the plethora of important wildlife all over the study area, the ecological impact assessment in respect of every single species is “not significant”. This is clearly a very questionable conclusion.

The report claims that there are no ‘important’ hedgerows which would be affected (10.3.24) and it maintains that the RAMSAR sites and SSSIs (including Rostherne Mere) would be hardly impacted (10.4.6). This, despite admitting (in Chapter 11 – Road Drainage and Water Environment) that some run-offs from the present road system discharge into Rostherne Mere and Tabley Mere and these would be added to by the new road. However, Chapter 11 does come to the conclusion that there would be moderate adverse impacts on some water courses.