Representation by High Peak Borough Council (High Peak Borough Council)
- Date submitted
- 16 September 2021
- Submitted by
- Local authorities
This representation has been jointly prepared by Derbyshire County Council (DCC) and High Peak Borough Council (HPBC). For context, both authorities have engaged with Highways England throughout the Development Consent Order process, including attendance at the stakeholder meetings organised by Highways England. Nevertheless, the two Councils submitted holding objections in response to the public consultations held by Highways England in both 2018 and 2020. Fundamentally, the objections were due to the lack of supporting information regarding the traffic and related implications of the scheme. In relation to the DCO application as submitted to the Planning Inspectorate, unfortunately, our current position is that our holding objection should be maintained. In spite of our previous request for further information, the Environmental Statement and supporting documents do not address our concerns. Having reviewed the submission, the two Councils have identified a number of gaps in the transport assessment data and subsequent queries and requests for information have been made to Highways England. In the context of the above, a summary is provided below of the Member and Officer comments of both authorities on the scheme. Member Comments Derbyshire County Council Consultation on the DCO application and supporting Environment Statement has been undertaken with Derbyshire County Council’s Elected Members Becki Woods (Etherow Electoral Division), Jean Wharmby (Glossop and Charlesworth Electoral Division) and Daniel Greenhalgh (Glossop and Charlesworth Electoral Division) for their comments on the scheme. At the time of writing no comments have been received from Derbyshire County Council’s Elected Members. Any Member comments subsequently received will be submitted to the DCO examination at a later date, particularly as part of the two council’s joint Local Impact Report. High Peak Borough Council Further comments from HPBC members will be included within the next phase and the Local Impact Report. Highways Impacts • DCC, as Highway Authority for that part of the scheme that falls within High Peak Borough within Derbyshire, fully recognises the severe impacts of existing traffic flows on the highway network on the A628 and A57 and the associated adverse implications for the residents of Woolley Bridge in Derbyshire and Mottram Moor in Tameside and the wish for Highways England to address these issues. However, DCC is also concerned about the wider impacts of the Scheme on the highways network, particularly on the A57 through Glossop and A628 through Tintwistle. • This is because the Scheme and its likely improvements to connectivity and reduction in travel times to and from the Manchester conurbation could potentially make it more attractive to road users in Derbyshire and consequently increase traffic flows with a corresponding reporting of future accidents on both the A57 through Glossop and A628 through Tintwistle. • Liaison is on-going with Highways England and their consultants to fully evaluate the likely highway and highway safety impacts of the scheme on the Derbyshire road network through the transport modelling evidence submitted as part of the Environment Statement. • Issues have recently been raised by the two local authorities regarding the transport evidence that has been submitted with the DCO and further information sought from Highways England. A57 Junction Design • DCC’s Officers have been liaising with Highways England’s consultants regarding the detailed design and layout of the highway scheme, particularly the new signal-controlled junction between the new link road and the existing A57 at Woolley Bridge. This includes consideration of a proposed new consented housing development adjacent to the junction over which liaison has also taken place between Highways England’s consultants, DCC’s officers and the applicant for the housing development. • With regard to the proposed design of the signal controlled junction on the A57 at Woolley Bridge, in discussions with Highways England’s consultants, DCC’s Network Management Officers have expressed some significant concerns about the design of the scheme, particularly the proposed inclusion of two lanes on the new link road that approach the new junction to turn right to head southwards on to the existing A57 which then also has two lanes that merge into one on the A57 after a relatively short distance. DCC’s Officers consider that such a design raises safety issues with the merging of traffic down to one lane on a relatively short distance of highway and have requested that Highways England’s consultants give this issue further thought as the County Council would prefer to see a more traditional one lane design solution for traffic turning right off the new road to head south towards Glossop, particularly if the County Council is being requested to adopt the new junction following completion of the scheme. Although these concerns remain, it is noted that Highways England has amended the junction design in the DCO submission so that there is now a longer stretch of two lanes heading southwards on the existing A57 before they merge into the single lane. It is Highways England’s position that a two-lane design solution is required for capacity reasons. • With regard to the proposed access to the consented residential scheme to the east of the new junction on the A57, discussions between each of the parties has established the principle of a mutually acceptable design solution for the junction, approval has now been given for the adoptable estate street, including its link to the new junction. A57 Street Lighting Design and Location • DCC’s Officers have been liaising with Highways England’s consultants regarding the detailed design, specifications and location of street lighting for the scheme. Discussions are on going although the principle of the design, specification and location of the street lighting for the scheme has been agreed. Air Quality • HPBC has designated Air Quality Management Areas on sections of the A57 at Dinting and on the A628 in Tintwistle. • Our response to Highways England’s public consultation in 2020 raised concerns about the impact of the scheme in the AQMA, particularly given that the PEIR had not considered the implications for these designations. This omission appeared to be on the basis that the changes in traffic flows with the scheme open were not sufficient to meet the screening criteria • Unfortunately, the assessments submitted in support of the Development Consent Order application also omit consideration of the impacts on the AQMAs. The Council is keen to explore the basis for this by examining the underlying assumptions and projections in the traffic modelling. Seemingly, traffic is projected to avoid the A57 through Glossop town centre by taking alternative routes such as Shaw Lane. Heritage Impacts • DCC’s Heritage Officers have reviewed the Heritage Chapter of the Environment Statement. DCC’s key concern is the potential impact of the highway scheme on the setting of Melandra Castle, a Scheduled Monument that sits on high ground overlooking the proposed development to the south-west and the need to ensure that the potential impacts are adequately mitigated. Although DCC’s officers have raised a number of issues regarding statements made in the Environment Statement relating to the potential impacts, notwithstanding this, Officers are supportive of the proposed mitigation measures set out in Table 6-5 of the Heritage Statement to help reduce the level of visual impact in the immediate setting of the castle. Landscape Comments • DCC’s Landscape Architect has reviewed the DCO submission and considers that he has no substantial comments to add at this stage having been involved in this submission as part of an ongoing process. DCC’s Landscape Architects considers that he is satisfied that the relevant documents have been referenced as part of the Landscape and Visual Impacts Assessment (LVIA) and that additional viewpoints he identified previously as being required during the PEIR consultation, specifically from residential properties at Woolley Bridge and from locations near Melandra Roman Fort, have now been included in the formal assessment. Ecology Comments • DCC’s Ecologist considers that there are no ecological sensitivities immediately apparent, at least within the Derbyshire area relating to the scheme. Comments were made on the PEIR, when it was concluded that the ecological assessment appeared to be adequate in scope, robust in approach, and suitable with regards to the surveys undertaken. In this context, no further comments are provided on the Environment Statement submitted in support of the DCO application. Climate Change • DCC’s Climate Change Officer has reviewed the Climate Change Chapter of the Environment Statement. A number of comments are made regarding the need for further detail or clarification about the potential impacts on climate change and proposed mitigation. These include: • There is a lack of reference to, and acknowledgement of, the Government’s strategic priorities of reducing emissions, and increasing modal shift to active travel. • The assessment does not take account of any potential opportunities for renewable energy installations and generation within the Scheme’s boundary, which seems like a missed opportunity to explore options. Furthermore, there does not appear to be any mention of electric vehicle charging infrastructure and it is considered that there may be an opportunity for EV Rapid Hubs to be located along any proposed route. • Vehicle emission factors take account of Department for Transport fleet projections including conventional vehicles (petrol and diesel) as well as hybrid and electric vehicles, but do not take account of government commitments to changes in fleet makeup, for example the phasing out of conventional fuel cars and vans by 2030. • The assessment around road user impacts and traffic numbers does not appear to take into account changes to travel and work patterns brought about by the COVID-19 pandemic over the past 18 months, some of which are likely to be sustained in the long term, leading to more home working and flexi-time travel. Flood Risk • DCC’s Flood Team Officers have reviewed the Environment Statement and consider at this stage they are not able to fully comment on the flood risk implications of the scheme as there is no drainage strategy available to assess and it is too early in the process for the developer to have designed this. Officers will therefore provide fuller comments later on in the DCO process. Accessibility / Public Rights of Way Issues • DCC’s key concerns relate to the connectivity of the highway scheme with the surrounding Public Rights of Way network, particularly the Trans-Pennine trail that runs close to the eastern boundary of the scheme adjacent to the River Etherow and existing A57 Wooley Bridge. Officers welcome and support the proposed design of the link road, which includes provision of a new footpath/cycle path running alongside the south-side of the new highway link road to Mottram Moor. Clarification is required, however, whether the footpath / cyclepath would also be used for horse riders. • Officers also welcome the connection of the new footpath / cyclepath with the Trans-Pennine Trail where it emerges alongside the River Etherow adjacent to the existing A57. This was an issue raised with Highways England on its PEIR consultation in 2020 and has now been addressed in the DCO submission. Waste Matters • DCC’s Officers consider that, overall, the scheme and its supporting documentation makes sound provision with regards to waste infrastructure and waste management issues and makes appropriate reference to the waste hierarchy. The waste hierarchy is key as the scheme is likely to involve a large amount of earth works and aggregate and stone excavation and usage as the scheme progresses. As much of this material should be utilised on site and as part of the scheme as possible - if this is carried out then only minimal amounts of residual waste should need to find a home within local waste infrastructure. Economy and Regeneration • We are keen to determine the implications of the scheme to the local economy. This theme will be considered as part of our Local Impact Report. HPBC has commissioned a Masterplan for the Glossop Gateway corridor from Woolley Bridge into Hadfield and Glossop town centre along the A57 with a view to maximising any potential opportunities and benefits which may arise from the scheme. However, as outlined above, this work cannot conclude without further consideration of the traffic flows. Land Interests • For the record, HPBC has land interests which are relevant to the scheme, namely land on the western side of the A57 at Brookfield, Glossop. The land in question forms part of the gateway to the Trans Pennine Trail. The applicant is aware of this interest.