Representation by Surrey County Council (Surrey County Council)
- Date submitted
- 6 September 2019
- Submitted by
- Local authorities
SURREY COUNTY COUNCIL - RELEVANT REPRESENTATION SEPTEMBER 2019 M25 JUNCTION 10/A3 WISLEY INTERCHANGE Planning Act 2008 – Section 102 PINS Reference: - TR010030 1 EXECUTIVE SUMMARY 1.1 The proposed scheme is within the administrative boundary of Surrey County Council and so the County Council is a host authority and statutory consultee in the Development Consent Order (DCO) process. 1.2 This Relevant Representation reiterates the County Council’s support for the principle of the scheme. We wish, however, to ensure that the development does not result in unacceptable impacts on the residents, businesses and environment of the affected local area or in additional maintenance/management liabilities to meet Highways England’s stated key objective to “Minimise impacts on the surrounding Local Road Network.” We have therefore taken the opportunity to highlight issues to be considered by the Examining Authority. 1.3 This response takes into account the County Council’s statutory responsibilities and functions and is intended as a summary which will be further developed and detailed within the Written Representations, Local Impact Report and Statement of Common Ground. It is understood the submitted DCO scheme will change, as detailed designs are completed and as such the County Council views may also evolve. We require provision within the wording of the DCO for the County Council to approve the remaining detailed design elements and agreement of associated fees associated with this from Highways England as at present it is considered that such a commitment is not yet contained within the DCO. 1.4 The majority of these comments have been previously made by the County Council in its response to each of Highways England’s consultations (the Statutory consultation and the two Non Statutory targeted consultations) as such we would ask that our response letters (dated 23rd March 2018, 13th December 2018 and the 7th May 2019) are taken into account in our representations. The County Council have also submitted detailed comments on Volume 3.1 Draft Development Consent Order (on 20th May 2019) to Highways England. 1.5 In a number of cases technical information has only been made available at the date of the publication of the DCO and so the County Council have made additional comments where possible. 1.6 At the time of drafting this Relevant Representation the County Council’s main areas of concern and position are as follows: 1 Impact on the Local Road Network (LRN) • Transport Assessment concerns - data provided and associated impacts • LRN areas affected by the scheme - in particular re-routed traffic through Ripley, Bridge End, Martyr’s Green and the lack of mitigation. Request Highways England confirm approval in principal for Burntcommon north facing slip roads, confirm feasibility for Ockham Roundabout south facing slip roads and fund a comprehensive mitigation package in Ripley. • Heavy Goods Vehicles (HGV) - loss of existing HGV parking and impacts on the LRN • Drainage & Structures – concerns on adoption, commuted sums and maintenance access • Request for Variable Message signs to improve interaction between SRN and LRN • How the wider community will be engaged on the final scheme upon DCO completion • That Protective Provisions for Local Highway Authorities are included either in the main DCO or a commitment given by Highways England to enter into a separate agreement 2 Impact on Non-Motorised Users (NMU), Public Transport and Public Rights of Way (PROW) • The proposed parallel NMU route should be maintained by Highways England as it is a replacement for the current NMU route adjacent to the A3 and the current legal right to cycle on the A3 which Highways England are removing under the proposed scheme • Concern regarding the proposed surface treatment of the NMU routes. • The need for further measures/funding to compensate for removal of the A3 bus stops 3 Impact on Road Safety • Speed Limits – the County Council agree with the proposals except for Elm Lane • Road Safety Audit (RSA) – the County Council considers the current RSA to be too limited as it does not cover all of the affected LRN • Traffic Regulation Orders (TRO’s) – that all TRO’s required as part of the scheme (e.g. speed limits, banned movements, rights of way) are advertised and made by Highways England 4 Impact on Surrey County Council’s financial position • Adoption of new/proposed scheme components – there are elements of the scheme that the County Council is not prepared to adopt. • Commuted Sums – Highways England has not, to date, committed to provide commuted sums (via a separate agreement) to cover the maintenance burden that would fall on the County Council for additional infrastructure. • Funding to cover County Council costs – Highways England has not followed through with their initial offer to enter into a Planning Performance Agreement to meet the County Councils staff costs in respect of input to the development of the scheme 5 Impact on Surrey Land Interests • Concern that Highways England has not to date concluded historic exchange land from the original M25 (1979 & 1982 CPOs) which is ongoing with the County Council • That Highways England set out as early as possible their financial offer in respect of land acquisition and compensation in respect of the County Council’s retained land which is adversely impacted/blighted. 6 Impact on Landscape, Environment, Biodiversity and Archaeology • Highways England has shared a draft SPA Management, Landscape & Ecology Management, Outline Construction Environmental Management Plans and programme of archaeological investigatory works but, until these are finalised, the County Council cannot confirm its agreement • Specific concerns to be addressed regarding the Green Bridge 7 Impact on Lead Local Flood Authority • The County Council has submitted comments on Protective Provisions for Watercourses / Drainage Authorities it wishes to see incorporated 8 Impact on Waste Authority • Concerns on distribution of material consumption and waste generation, source of construction materials, materials and waste capacity assumptions, facilities to deal with excavated hazardous waste and the need to refer to the January 2019 Submission of the Draft Surrey Waste Local Plan. 9 Impacts during construction • Concerns regarding impacts to the LRN during construction including fatigue on the existing LRN as a result of traffic diversions with no Highways England commitment to provide funding to mitigate these impacts and maintenance burden. A copy of the County Council's full Relevant Representation has been sent to M25Junction10@planninginspectorate.gov.uk and the County Council would ask that this is read in conjunction with the above executive summary. ---------------------------- Please see attached