Back to list M3 Junction 9 Improvement

Representation by Winchester City Council (Winchester City Council)

Date submitted
13 March 2023
Submitted by
Local authorities
  1. As host authority Winchester City Council (WCC) wish to register as an Interested Party. Detailed representations will be made in the Local Impact Report however at this time following review of the published documents, WCC wishes to make the following comments and look forward to being involved in the process to discuss matters further. 2. Climate: 2.1 2,000 tCO2e per year is emitted compared to the status quo or ‘do nothing’ scenario. WCC has targets to become a carbon neutral district by 2030. The additional carbon is therefore in opposition to aims to achieve the Council’s target. 2.2 It is questioned why mitigation measures to offset the increase have not been presented. 2.3 Emissions will rise by 139,800 tCO2e over the lifetime of the scheme and the local impacts must be given deeper consideration. 2.4 The Climate Change Baseline conditions cease at 2010 and do not include the warmest years on record which are within the last decade. 2.5 Given interrelated impact of climate change on flooding, it is not acceptable to increase flooding risk in the locality and mitigation is required to remove risk. Submissions should take account of recent flood events in the city including significant events in 2014 and 2020 (flood records up to 2006 have been used; para 14.14.6) 2.6 Mitigation proposed for emissions during the operation of the scheme are currently inadequate. 3. Historic Environment: 3.1 Submission is comprehensive and professional and addresses the built heritage assets which could be affected by the proposal. 3.2 No direct result to built heritage is anticipated and impacts would be indirect resulting from a change in setting. Such impacts are minor in scale and severity. 3.3 The City Council would like to investigate wider road signage and street furniture further to ensure visual clutter in conservation areas are avoided and 3D visuals should be provided. 4. Archaeology: 4.1 Overall no significant archaeological concerns. Although permanent adverse effects to buried archaeological assets will occur these can be satisfactorily mitigated and wider benefits outweigh the harm caused. 4.2 There are clarification requests regarding inclusion of working zones, areas of fill, requirement to ensure archaeology is considered in the soil management plan, improvements to archaeological outreach and public engagement, archive deposition and on-going maintenance of information panels which have been communicated to the applicant. 5. Public Protection: 5.1 No high level objection in principle to the assessment methodology of the Environmental Statement. However these conclusions rely on the assumption that various mitigation measures will be implemented principally through commitments made in the draft DCO and delivered through the Environmental Management Plan. 5.2 The Environmental Management Plan requires further revision. Traffic diversions may not be a worst case scenario as the air quality and noise impacts modelled from these diversions make the assumption that these diversion routes will be followed. Reviewing the diversion routes, some may not be used as intended which moves the noise and air quality to other roads. WCC reserve the right to continue to assess noise impact during construction (particularly if smart motoway schemes proceed) and will feedback any concerns to National Highways. 5.3 Chapter 11 concludes that only with mitigation are construction stage impacts acceptable at identified sensitive receptors. It references that these will be delivered though measures identified within the Environmental Management Plan. It is noted that proposed conditions 3 and 14 of the draft DCO relate to such matters. However, the first iteration does not contain the referenced Noise and Vibration Management Plan. 5.4 In terms of air quality it is stated that construction dust impacts will also be mitigated through the Environmental Management Plan and it is acknowledged this is included as requirement 3 of the draft DCO. 5.5 The commitment to a Section 61 Control of Pollution Act 1974 prior consent is welcomed and early dialogue is requested so WCC can be satisfied that the mitigation this delivers will provide the level of mitigation assumed within Chapter 11 of the Environmental Statement. 6. Ecology: 6.1 Further information is required regarding protected species including bats, dormouse, badger and birds. 6.2 Confirmation required on bat surveys as transect surveys last undertaken in 2017. 6.3 WCC requires both the draft mitigation and compensation strategy and NE comments in order to be confident that the EPS mitigation licence will be granted. 6.4 WCC should be provided with additional Badger survey reports and the draft mitigation and compensation strategy. 6.5 Further bird surveys are required in accordance with current bird survey guidelines. 6.6 WCC supports the commitment to provide chalk grassland which is of local significance rather than using other types of grassland. 7. Trees: 7.1 Arboricultural Method Statement and Tree Protection Plan to be approved by governing authority before any works start on site. 7.2 There will be an impact on visual public amenity value due to the number of individual trees and groups of trees being removed, with the additional impact of removing Ash trees because of Ash dieback needing removal regardless of the development for public safety. 8. Landscape: 8.1 Concerns raised in 2021 consultations now appear to have been addressed 8.2 Confirmation required on compound locations and future maintenance strategies. 8.3 Further section requests have been made directly to the applicant and 3D views of gantry signage, bridges and tunnels are required. 9. General 9.1 Diversion routes need to be assessed in various weather conditions as this may alter their availability due to flooding and safety concerns. 9.2 Confirmation required as to whether variable speed limit technology will be installed on this section (regardless of all-lane motorway plans) 9.3 The construction of increased cycle pathways and passageways may need to be supported by cycling infrastructure such as bike stands. Moreover, the safety of cyclists and pedestrians should be considered, with data collection on collisions prior to and post construction.