Representation by Essex County Council (Essex County Council)
- Date submitted
- 4 November 2022
- Submitted by
- Local authorities
The Planning Inspectorate National Infrastructure Planning Temple Quay House 2 The Square Bristol BS1 6PN By e-mail only: a12chelmsforda120@planninginspectorate.gov.uk Our Ref A12/S.56 Your Ref TR010060/S56 Date: 4th November 2022 Dear PINS Casework Team, Planning Act 2008 – Section 55 Application by National Highways for an Order Granting Development Consent for the A12 Chelmsford to A120 Widening (TR010060) Notification of decision to accept an application for Examination for an Order Granting Development Consent I wite with reference above and in particular your request that interested parties register to participate in the forthcoming examination, In doing so we are conscious of the published Guidance that asks that at Registration we are asked to: “include a summary of what the local authority agrees and/or disagrees with in the application, what they consider the main issues to be, and their impact. The content of relevant representations is used by the Examining Authority (ExA) to help inform their initial assessment of principal issues for examination.” We are continuing to engage with the developer, National Highways (NH), and are progressing with discussions on a Statement of Common Ground, which remains a working document currently, with the aim of reaching agreement on as many issues as far as is possible in advance of the examination. ECC remain committed to work with NH on this significant proposal which has continued at speed. To assist the ExA and to bring the same up to date with our current position please be advised that we wrote to NH on the 31st October 2022 on the big issues we have at this time, and we set out the content of the same below: “As you will be aware we have had a lot of dialogue on the A12 widening project over the past few months, not least through the Statement of Common Ground (SOCG) working group that has been established, and it follows that the County Council’s position on the project has developed and continues to evolve in response to information that has been set out in the DCO application, undertakings that have been made by National Highways (NH) and changes that have been proposed to various aspects of the scheme. Having engaged with ECC Members and representatives from district and parish councils affected by the project, we are now able to update you on our position on a number of the points raised in your letter. It is our intention to ensure that this position is reflected in our joint SOCG and within the Local Impact Report that we will be submitting to the DCO examination as a host authority for the scheme. It is worth repeating that the County Council remains a strong supporter of the scheme overall, in recognition of the improvements it will bring to the A12 corridor between Junction 19 and Junction 25 and the wider benefits that are expected. We also welcome the engagement you have undertaken with us on the project which has enabled us to develop a much better understanding of the scheme and its anticipated impacts. We do however continue to have significant concerns about some aspects of the scheme and we continue to believe that material changes to the proposals are required to ensure the adverse effects are minimised and mitigated as far as possible, particularly on the local highway network for which ECC is the highway authority. Given the project is now at pre-examination stage and parties are preparing for the upcoming examination, rather than respond to all the points raised in your letter of 4th July this letter seeks to summarise key issues that ECC considers remain outstanding. There are other issues on which we wish to continue engagement but the issues set out below are where we believe we should focus our attention in the period up to the examination. Additional detail to be provided We welcome the additional information that has been provided to us since our last letter. We are continuing to review the DCO application documents; as you will appreciate there is a lot of information contained within the application, so we would be grateful for your ongoing support in signposting where specific information can be found. Clearly in reviewing the DCO application and other information that has been provided we will continue to have questions, and hence will continue to request clarifications or more detail on certain points as necessary. We are happy to use the shared actions tracker as a means of documenting where we believe further information is needed going forward. Junction 19 In our response to the statutory consultation ECC opposed the current design of Junction 19 partly on the grounds that the arrangement was not demonstrably compatible with wider development proposals in the vicinity of the junction, including the longer-term plan to dual the proposed Chelmsford North East Bypass (CNEB). While we appreciate that the dualling of the bypass is not committed we do believe it is required to support the growth planned in the area, and as such ECC is concerned that at this stage we simply don’t know what works would be required to the junction to accommodate this in future. We believe that a joint study is required to better understand the compatibility of Junction 19 with wider development proposals in the vicinity of the junction, including CNEB, and would appreciate commitment from NH to this given that NH is actively developing the design for this junction. To be clear, we are not asking NH to amend the design of the junction but to work with us to ensure we can collectively understand what further changes may be required to the junction in the future – post completion of the A12 widening project – and how these could be delivered. Boreham and the B1137, including Junctions 20a and 20b While the reasoning provided for the removal of Junctions 20a and 20b is understood, one of the consequences of this is a significant increase in forecast traffic flow on the B1137 and this naturally represents an area of concern for the local community and ECC. Fundamentally, while we support the proposed speed limit reduction on the B1137 through Boreham to 30mph we do not believe that a reduction in the speed limit alone will be sufficient, and we consider that a package of measures is required to discourage strategic traffic from routeing through Boreham to access Junction 19. These measures could include new pedestrian crossings, village entry treatments and potentially speed cameras, and a commitment to delivering suitable measures is required from NH. As we have stated previously we do not currently support the proposed speed limit reduction on the stretch of the B1137 between Boreham and Hatfield Peverel, because the nature of this road is such that we think compliance with a lower speed limit is likely to be an issue. We believe retention of the existing speed limit along this stretch of the B1137 should be modelled so that we can better understand the impacts. Junction 21 We have reviewed the assessment NH have provided on the impacts of the scheme on B1137 The Street / B1019 Maldon Road (Duke of Wellington junction). Whilst we appreciate that the assessment indicates the scheme will not materially worsen the performance of this junction, we believe the new junction (coupled with the closure of Junctions 20a and 20b) will attract more traffic and are not convinced that the modelling is accurately reflecting current and future congestion on the network and it may, therefore, be underrepresenting the impacts. The Duke of Wellington junction currently operates close to or above capacity at peak times, and the performance of the junction is expected to deteriorate as demand increases in the future. The arrangement of Junction 21 is such that all traffic from Hatfield Peverel will route to/from the A12 via the Duke of Wellington junction, and we believe there is a need for a Maldon Road bypass in future to accommodate forecast growth and ensure local communities can fully benefit from the A12 widening project. We welcome the planned widening of the verge platform at the on-slips to enable the slip roads to be more easily widened in the future to accommodate a future bypass, however in practice widening of these on-slips at a later date will still represent a significant, disruptive and costly endeavour that will represent a major challenge to delivering a bypass. Our ask of NH on Junction 21 is twofold. Firstly we believe there is a good case for NH providing widened on-slips at the junction from the outset, to ensure a future bypass could be constructed off-line and with minimal disruption to the SRN, and request that NH amend the design of Junction 21 accordingly. Secondly, we want to build on the feasibility work that ECC and NH have undertaken to date to the point of jointly identifying the preferred option for a bypass. We are currently scoping this work and would like a commitment from NH to contribute towards the cost of this work and to providing technical design input on the connectivity with Junction 21. De-trunking In our view the issue on which ECC and NH remain furthest apart is on the approach to the sections of the existing A12 which will be de-trunked and transferred to ECC as local highway authority to operate and maintain. We are disappointed that there has been little movement on this and put bluntly continue to believe that the approach to the de-trunked sections put forward by NH is unacceptable and represents a significant missed opportunity. Since April we have looked at options for the de-trunked sections, drawing on best practice and examples from elsewhere. Based on this we believe the most pragmatic solution is to retain one side of the dual carriageway as highway (likely to be the current southbound carriageway, tbc) and to repurpose the other side with green infrastructure and provision for pedestrians and cyclists. We believe there are many benefits to this, not least of which is the opportunity for the project to increase green infrastructure in support of the Government and ECC’s ambitions for net zero, biodiversity and flood control. This approach also presents options to simplify the proposed junctions which may provide some cost savings which in turn could go some way towards offsetting the costs of repurposing one of the carriageways. We strongly urge NH to work with us and other stakeholders to develop the options and build on the initial work we have undertaken. I would add that information on the condition of the assets which NH are proposing will be transferred to ECC is still required. This has been requested since March and the continued absence of this data is affecting our ability to form a full and informed view on de-trunking. Junction 24 ECC retains concerns about the proposals for Junction 24 in their current form; in particular we believe that further design development of the proposed new Inworth Road roundabout is required, additional measures are required to help ensure the B1023 is able to safely accommodate the expected increase in traffic and measures are required to reduce the potential for rat-running on local roads. On the first point, based on the review we have undertaken on the proposed new Inworth Road roundabout to date we have identified several potential design issues such as the proposed design speed and the tie ins with the approach roads including Kelvedon Road. Furthermore, it is unclear currently how existing accesses to Inworth Road in the vicinity of the roundabout will be maintained or how cyclists are expected to navigate the roundabout. It is not clear what optioneering has been undertaken in arriving at the current design and we believe further design development is required to provide assurance that the roundabout will operate safely and satisfactorily and ultimately be suitable for its intended purpose. This should include providing clarity on the horizontal alignment and forward visibility on the approaches to the roundabout. On the second point, while we welcome the proposals to widen pinch points on the B1023 to a minimum carriageway width of 6.1m there are several pinch points which are not currently proposed to be widened. We believe this approach is inconsistent and that the scope of these localised widening works should include the pinch points south of the garden centre, to the junction with the B1022 and Hinds Bridge, to the north of the A12. A knock-on effect of widening pinch points on the route may be that vehicle speeds increase and for this reason measures for encouraging compliance with the proposed speed limits may be necessary. In any case, we believe further walking and cycling improvements should be included in the proposals to offset the impacts of increased traffic on this route. Finally, we are currently in the process of scoping a range of measures that we think could help to reduce the likelihood of vehicles rat-running on local roads and particularly through the village of Messing to access the new junction. We will share details of these measures shortly and would welcome a commitment from NH to funding their implementation. We are grateful for the work that has been undertaken to consider the case for a bypass of Inworth Road as a means of addressing some of the concerns held about the junction arrangement. Having reviewed this work we largely concur with NH’s assessment that while the alternative proposal for a bypass of the B1023 put forward by the local community would have some benefits including reduced traffic through Messing, it would increase the attractiveness of the junction and lead to increased traffic overall and through Tiptree. Walking, cycling and horse-riding We welcome the improvements that have been made to walking and cycling infrastructure, including the level of provision at Junction 19 and the changes that have been made to Paynes Lane bridge. Notwithstanding this we believe some further enhancement is possible, such as rationalising some of the ramps for new walking and cycling bridges, in line with best practice (LTN1/20). The walking and cycling matrix that NH have produced is welcomed. In some cases further justification for why LTN1/20 cannot be achieved is required. Confirmation is also required of the proposed arrangements for and impacts of the new pedestrian and cycling crossings. We will revert with detailed comments on the matrix shortly. As a general point, wherever possible provision should also be made for horse riders. Monitoring and mitigation There are some locations on the local highway network that are particularly sensitive to changes in traffic flows and patterns, whether that be because they are already operating close to or above capacity or because the scheme is expected to have a significant impact on traffic flows and/or network performance. Given current levels of uncertainty we believe that NH should commit to monitoring the actual impacts of the scheme in operation for an agreed period after opening and reporting the data collected, at a small number of locations to be agreed (likely to include the B1137 through Boreham, the Duke of Wellington Junction and the B1023). It could be that this monitoring can be utilised as part of a wider benefits management exercise and/or post-opening project evaluation that will be undertaken by NH. Importantly, if this monitoring were to indicate that the scheme was having a material, unanticipated adverse impact on the local highway network we believe NH should commit to working with ECC to investigate, develop and implement suitable mitigation. While we appreciate that any such commitment would need to be clearly defined, there are precedents for such approaches and this would go some way towards providing ECC and stakeholders with assurance that in the event the scheme does have significant adverse impacts on the network these would be identified and, if necessary, addressed. We believe this should be secured via a DCO requirement and would like to discuss how this could work with your team. Construction impacts We recognise that the construction impacts of this scheme will be significant, and we share your desire to minimise and mitigate these impacts as far as possible and ensure local communities and users of the A12 are kept informed about the works. To that end we are largely supportive of the approach set out in the Outline Construction Traffic Management Plan, and welcome NH’s commitment to continue engaging closely with us on the development of the Construction Traffic Management Plan. One area we would like clarity on is the proposed speed limits on the A12 during the works, as we believe this could have a significant impact on the use of local roads as an alternative. Conclusion In conclusion this response provides a summary of the key outstanding issues on the project where we believe we should focus our engagement over the coming weeks. ECC remains supportive of the project, and our intention is to ensure that the benefits of the scheme to Essex are maximised and we collectively minimise the adverse effects on the local network as far as possible. We look forward to continued close working on the project in the run up to the DCO examination. “ In addition to the comments as made to NH and as set out bov the following is also considered to e of relevance at this time. Caveat The ExA is remined that other significant environmental issues (ecology/heritage/flooding/design etc) are still under discussion with NH, either in the form of how they fit as agreed within the SoCG or as not agreed. Hence whist this is a snapshot of the issues as they are at the time and ECC reserve the right to raise additional substantive issues that require consideration within the ExA. In addition, ECC remains committed to seek to influence the betterment of the scheme beyond the DCO, should consent be ultimately granted. In some cases, NH currently wish to reserve the consideration of many issues post consent, ECC needs to be assured of its role in the discharge of any requirements is secure as these are material to the success or otherwise of the scheme, its impacts and its function once delivered. As is stated above ECC looks forward to continued, positive, and lengthy engagement with NH. Yours faithfully, Mark Woodger Mark Woodger Principal Planning Officer (National Infrastructure) Enquiries to Mark Woodger [Redacted] Essex County Council are the Highways and Transportation Authority and will host the route in its totality and hence have a material strategic and key interest in the project, mitigation and its legacy