Representation by Think Again, Winthorpe Action Group (Think Again, Winthorpe Action Group)
- Date submitted
- 7 July 2024
- Submitted by
- Members of the public/businesses
Submission by Think Again, Winthorpe Action Group 1. Summary Think Again has been liaising with National Highways and their agents since the public consultation on the proposals since 2020. Many of the issues that we have raised have been addressed in the design iterations. A few impacts on our village remain and are described in this document. The principal issues that we have are the height of the road, embankment and bridge in the open zone between Winthorpe and Newark and the impact of these on noise and visual intrusion, the drainage design and impacts on the village’s watercourses and the safety of young pedestrians in the vicinity of the road. We would like the Planning Inspectorate to consider the issues raised in this submission when examining this project 2. Introduction When the proposals for the A46 Newark Bypass dualling were released in November 2020 residents in Winthorpe became concerned over the effect that the new road would have on their village. A small group, calling themselves ‘Think Again, Winthorpe Action Group’ determined to engage with Highways England (now National Highways) and their agents to realise the best outcome possible for Winthorpe. In the following period we have engaged constructively with the design team, evidenced in the several report submissions and meetings, and have had some success in meeting our goals. The Statement of Common Grounds, currently being agreed between ourselves and National Highways, summarises the various areas of concern and of agreement at this stage of the design programme. Nevertheless there remain some topics where we feel that adverse influences on our village and it’s residents need more attention and would like the Planning Inspectorate to address these in their examination process. Our concerns are set out below, following the topic structure of National Highways’ Environmental Statement. 3. The Scheme The element of the road design that remains the most intrusive on our village environment is the height of the embankment and bridges between Chainages 4650 and 5400. The impact on Winthorpe is felt not only in the realm of Landscape and Visual Effects, but also in Noise and Vibration and Cultural Heritage. Representation on this matter has been made to National Highways in our reports and in the Statement of Common Grounds. National Highways have explained their reasons for the height of the formation and have outlined mitigation features, however we would value the Planning Inspectorate’s views on this matter. In the same zone the walking and cycling route, including NR 64, will be diverted to pass under the new A46 in the same bridge as the northbound Brownhills roundabout access road. Engineering Plans and Sections Part 6 – Structures General Arrangements, provides a very basic view of the design here, which is described in the documentation as an ‘Open Design’, but we would like to know much more about the relationship between traffic and pedestrians. In particular the means of separation by barrier, different elevation or other proposals. We would also like to know something of the architectural or aesthetic design of the structures in this vicinity. We are particularly concerned in this area, including the proposed light-controlled crossing of the northbound A46 exit slip, as the traffic on this NMU route features cyclists, leisure walkers and, particularly, young children on their way to the Primary School in Winthorpe. In the Statement of Common Ground we asked how the Winthorpe ThroughAbout would operate in the event of a power failure or computer malfunction. It seems clear that, especially on the ‘through’ element, normal give way rules could not apply and vehicle collisions could easily occur. What ‘failsafe’ system can be applied? Examination of the General Arrangement Plan has revealed what we consider to be another traffic interaction hazard. At present traffic coming north from Brownhills Roundabout has the option of joining the mainline A46 via a left-turn filter lane. Such traffic then encounters traffic from the right exiting the Friendly Farmer Roundabout. Fortunately, the carriageway where they meet is dual-lane and there is space and time for merging, although this can sometimes be stressful as vehicles can be moving rapidly as the zone is subject to the National Speed Limit. The plan shows the retention of this left filter lane and, although the speed limit is now proposed to be 50 mph the merging situation is now much more dangerous as the carriageway tapers to one lane within about 100 metres. Is this in accordance with DMRB guidelines? 4. Air Quality Although there is a view to scope out smaller particulate matter (PM2.5) as initial analysis suggests that the larger PM10 particles are unlikely to exceed threshold levels, we support the view of the Scoping Opinion for A46 Newark Bypass and in particular the response from the UK Health Security Agency (UKHSA). The Environmental Statement should demonstrate in more detail how this approach will ensure the objective is not exceeded by the Development and that greater analysis of all pollutant effects are considered, even when below the thresholds described in DMRB LA105. As stated by the UKHSA “pollutants associated with road traffic or combustion, particularly particulate matter and oxides of nitrogen are non-threshold; i.e. an exposed population is likely to be subject to potential harm at any level…” Any negative effects on air quality irrespective of magnitude and threshold levels are not acceptable and further details of mitigation would be welcomed as part of the Environmental Statement. Two properties within the Winthorpe and Langford Parish are already amongst the 12 most impacted receptors in the analysis area. Furthermore, as indicated above regarding footpath usage, some walkways will be adjacent to road infrastructure. Every effort should take place to protect NMUs from air pollutants generated by the road. We note that “In accordance with Table 2.58a of DMRB LA 105, the construction dust risk potential of the Scheme is classified as ‘Large’, due to the Scheme being a ‘bypass improvement project’” and “Based on the ‘Large’ construction dust risk potential of the Scheme, and the proximity of the human health and ecological receptors to the Scheme, the construction dust risk is considered to be ‘high’.” We are particularly concerned about this for the areas around Winthorpe Primary School, where children will be playing outside during day times, and residential properties on The Spinney. We seek assurance that all practical steps will be taken throughout the construction phase to minimise dust and other air-borne pollutants, and suitable measurements be taken at frequent intervals to ensure this is the case. 5. Cultural Heritage Winthorpe Conservation Area borders the proposed scheme in multiple places and the new A1 overbridge and its environs are within the revised Conservation Area proposed in our Neighbourhood Plan. A number of Listed buildings are in close proximity to the scheme. We are pleased that details of mitigation are included in the latest plans to reduce the impact of the scheme on the Conservation Area. However, we believe there are further features necessary to give additional protection to Winthorpe. Document 6.3 Environmental Statement Appendix 6.3 Assessment of Cultural Heritage Effects During Construction of the Scheme, Section 1 lists Lowwood (MM053) as a Grade II Listed Building and says an “adverse effect is predicted. There is potential for development within the Order Limits to have an adverse impact on the value of the asset, through alteration to its setting”. This property will be affected by noise, vibration, dust and air pollution during construction yet the significance of this is not quantified. The new road will also have substantial impact on the setting of this significant property. Lowwood is mentioned in a number of places in the analysis acknowledging that there will be temporary moderate impact on Lowwood during construction with ‘slight adverse impact permanently.’, although further on in terms of landscape they do consider the impact to be less than ‘substantial harm’. We think that there will be substantial harm here. Similarly, they attribute temporary moderate harm on the conservation area with proposals for bunding and planting to reduce the permanent to less than substantial impact. The south of the village currently has no additional mitigating features detailed, and the effect of existing tree lines and other features are unlikely to give sufficient protection for the new road; we would welcome additional screening to reduce the impact to the Conservation Area, but also give benefits listed elsewhere in this report. National Highways make considerable reference to cultural heritage and many of the points we raised do seem to have been taken on board. Chapter 6 Cultural Heritage and associated appendices cover the issues well, acknowledging the need for noise mitigation and planting at Lowwood and for the Winthorpe conservation area to both reduce noise and reinforce the scrub and parkland character of the area. The analysis lists the other main heritage buildings in Winthorpe which are affected by the scheme ie Langford Hall, the Grove, and Church with an assessment of the impact on each. Non Designated heritage assets and landscapes are also considered with the conclusion that none are predicted to experience significant effects. The chapter also acknowledges that some non-designated assets have already been impacted by previous road schemes or 20th century development e.g. Molls Horn work, Bleaches cottages, and Two-mile house. Reference is made to possible pits, barrows and ditches to the north of Winthorpe roundabout and Langford Hall that will be impacted by the scheme. We hope the intention will be to investigate the heritage before the scheme is implemented. We would like National Highways to clarify • The type and layout of the landscaping proposed for the length of the stretch from the A1 over bridge to Winthorpe roundabout and Langford Hall • The height and level of bunding and noise reduction fencing designed to mitigate noise • Why Winthorpe House and associated Park land isn’t scoped in to the analysis. Our understanding is that its Grade II listed and impacted by the scheme. It is in the conservation area which is featured. • That any new archaeological or historical information revealed by the construction will be appropriately managed in accordance with the archaeology management plan in the proposal. They do acknowledge this but do say there will be a large adverse impact on this new material. 6. Landscape and Visual effects There is a complete contradiction when it comes to summing up the impact of the A46 Scheme on Winthorpe, in relation to the landscape and visual responses. In 6.1 Environmental Statement Chapter 7 Landscape and Visual Effects 7.11.10 It states: “The magnitude of change to the Winthorpe Village and Farmlands LCA as a whole is considered to be Major Adverse” for up to four years during construction.” but, in Table 7-7, it summarises the effect on Winthorpe during construction and during year 1 of operation as “Large Adverse” and the effect during “year 15” of operation being “Moderate Adverse”. However, in the Environmental Statement Volume 6.3 Appendix 7.2 Visual Baseline and Impact Schedules: Ref No. 42 (Effect on Visual Receptor) sums up the effect on the visual receptors in Winthorpe as “Slight Adverse”. Why has “large adverse” become “slight adverse” in the visual receptor document? It also seems remarkable that Lowwood is not listed as a visual receptor in 6.2 Environmental Statement - Figure 7.4 - Visual Receptor Location. It is a Grade 2 listed building, and it is the closest residential building to the new bridge crossing the A1. It is also impacted to the south and the east. Similarly, there are no photomontages of the views from the Lowwood location even though it will directly overlook the new embankment and A1 bridge Throughout the planning stage, Think Again has asked for “acceptable levels” of re-planting of trees and hedges in areas of sound barrier bunds and NMU tracks. We are still worried by the lack of specifics when it comes to planting and bunding. Having examined the five Arboricultural Impact Assessments, we would like to see the specifics of the proposed mitigation. In document 6.3 Environmental Statement Appendix 7.2 Visual Baseline and Impact Schedules, when it comes to what will be done in Hargon Lane (ref no:47) there are a lot of references to “proposed planting plans” but we need specifics, both for planting and bunding. There are also serious worries about the light pollution for residencies at the south east end of Hargon Lane, especially in relation to lorries coming south from Lincoln. In Ref no. 49, it talks about “an intention to provide screening of the A46” by year 15. This is a major worry if it is going to take that long, and is not guaranteed. The residents of the Southfield estate and properties on the north end of Gainsborough Road are concerned about the style of lighting for the new Winthorpe roundabout as floodlighting the junction from very tall lamp standards would be exceptionally intrusive. Looking through the documents we can find nothing about this. 7. Biodiversity 8. Noise and Vibration The height of the A46 dual carriageway embankment between the A1 Winthorpe and Winthorpe Road Estate, Newark (as referenced in Section 3) is between 7.8m and 10.9m higher than the surrounding ground level as it crosses between the existing road to the Bridge House Kennels and the new A1 overbridge. This is higher than the existing A1 embankment in the vicinity of the existing Gainsborough Road underpass at its lowest (7.8m) and increasing in height over the A1 carriageway to facilitate the new overbridge. This will mean that although sight lines may be obscured to the new A46 at ground level from the end of Gainsborough Road, noise will be able to travel a considerable distance in all directions including over and combining with existing A1 noise levels. This change in the preliminary design is promoted as beneficial to noise levels as the alignment is marginally further away from Robert Dukeson Avenue in Newark, however this makes some elements of the embankment closer to the built-up area of Winthorpe. In addition, the remainder of the open break land is filled by the new Brownhills junction roundabout that is also likely to elevate noise levels further. Existing noise measurements (Appendix 11.2, Baseline Noise Survey Results tables 3.8 and 3.9) recorded in the vicinity of 79 Gainsborough Road and Lowood are above the daytime LOAEL [Lowest Observed Adverse Effect Level], and close to or above the SOAEL [Significant Observed Adverse Effect Level] criteria. Night-time noise levels at both locations clearly exceed the SOAEL by more than 5db meaning significant effects are already likely to human health and wellbeing. Other receptors in the village experience noise at or above the LOAEL during the day and night, but do not breach the SOAEL criteria. The village is already overburdened with noise levels likely to cause health related issues. ANY additional noise generated by the A46 would be unacceptable, never mind the changes in noise specified in Figure 11.10. This includes effects on a Noise Important Area and according to The Environmental Noise (England) Regulations 2006; “Where road schemes have the potential to affect the exposure of populated areas within an NIA, this should be assessed and measured to avoid adverse changes as a result of the scheme or opportunities to create beneficial impacts should be considered”. Figure 11.10 details the effects of the A46 and changes in the noise characteristics to affected receptors. It is not clear to the general public who make up these receptors where the adversely affected areas are located. The data is summarised in terms of number of receptors, not location thus downplaying the lived experience of both the construction and operation of the scheme. Which properties and receptors are the ones who experience a deleterious effect from noise from construction or operation of the proposed scheme? A number of Winthorpe properties are likely to be within the distance limits described in Chapter 11 section 11.8.1 for construction noise, for example. The UK Health Security Agency in their response to the Environment Scoping report state that the LOAEL and SOAEL levels and noise analysis described and undertaken in accordance LA111 of the DMRB is not sufficient to characterise the effect of noise on human health and wellbeing. In addition, the statistical data and numbers presented do not enable the general public to understand and experience the changes in noise they would experience as a result of the proposed scheme. We would support and advocate immersive experiences for people to hear first-hand the noise effect experienced in the Winthorpe Conservation Area. Chapter 11 section 11.5.1 states that Operational Vibration has been ‘scoped out’ of the environmental analysis as ‘a maintained road surface will be free of irregularities as part of project design and under general maintenance’. This is an idealised picture and, in practice, as the experience of anyone using the A46 between Newark and Lincoln can testify, the road surface is rarely free of irregularities, and is consistently undergoing maintenance. The nature of the low noise surfacing proposed is that it has a shorter service life and is likely to need maintenance more often than other options. This will bring periods of vibration associated with surface defects e.g. fretting and potholing, and maintenance generating often night time noise on a semi-regular basis (every 5 to 8 years). National Highways have a responsibility for noise insulation if façade levels exceed 68Db. They conclude no properties will be eligible for noise insulation following results from receptors. LT6 Lowwood area assessed just below 68Db (67db in the day time). Hargon Lane assessed as 53db. National Highways accept that during construction there is potential to result in noise level changes. National Highways state that one of the design parameters of the scheme is to minimise noise and vibration. They propose: • 3 landscape bunds 2 to 2.5 m north of the A46 between A1 and Winthorpe roundabout (ref 11.10.3) • 2 noise barriers from Esso garage to Winthorpe roundabout (ref 11.10.4) • Thin surface course applied to new carriage way to reduce noise • Restrictions on construction hours from 7 to 18 during the week and 7 to 13 on Saturdays. No Sunday or BH working. • Limit the number of days of construction work to prevent vibration • But we would still like clarity on: • Plans to minimise vibration impacts on Hargon Lane properties adjacent to the road. Are there any proposals to upgrade the road surface of the existing carriageways? • The type and layout of the landscaping proposed for the length of the stretch from the A1 over bridge to Winthorpe roundabout and Langford Hall • The height level of bunding and noise reduction fencing to mitigate noise. • What proposals are they making to minimise light pollution from both vehicles using the new Winthorpe roundabout and A1 over bridge and street lighting plans? 9. Population and Human Health The health issues related to air pollution, water pollution and noise impacts are addressed in other sections of this submission. Our other concerns in this category, as expressed in the Statement of Common Grounds, relate to the accessibility and viability of Winthorpe Primary School. We note that, in the Environmental Statement Chapter 12 Population and Human Health, the significance of the construction process on this receptor is noted as Slight Adverse (not significant). However it can be seen that this is assessed only in terms of motorised access and takes no notice of the many pupils who walk to school from Newark via the A46 and A1 underpasses. The significant work around the new embankment and Brownhills roundabout will have an important impact on this route. We also note that the impact on the access to the school via this walking route during the operational phase of the scheme is not considered even though pupils will then have to negotiate the live slip road from the A46, albeit with a light controlled crossing, whereas at present they do not have to deal with motorised traffic. Think Again have pressed for improvements to local WCH (Walking, Cycling and Horseriding) provisions in our locality in support of the leisure and health provision for our population. Document 7.4 Transport Assessment Report Appendix C – Walking, Cycling and Horseriding Assessment and Review section 3.17.2 refers to our proposals, a number of which have been accepted. Section 3.17.1 suggests that we were also party to the Newark Active Travel Partnership Submission. We were never invited to any of the meetings although we support all of their suggestions. One suggestion that we would like to support is the extension of BW6, the bridleway on the east bank of the Trent from the Winthorpe A1 bridge to Holme Lane adjacent to the rail crossing. We note that this is referred to in Table 8: Equestrian Opportunities as E1*** of the Appendix C and it is suggested that this is being reviewed for support from Designated Funds. 10. Road Drainage and the Water Environment Winthorpe is the location of two of the watercourses referenced in the Environmental Statement – Chapter 13 Road Drainage and Water Environment, the Slough Dyke and The Fleet. Examination of the plans in Engineering Plans and Sections Part 5 – Drainage Engineering Plans reveals that these water courses are the recipients of the proposed road drainage from 40% of the Bypass, from the ECML rail bridge to Winthorpe Roundabout. Our issues relating to these watercourses was expressed in general terms in the Statement of Common Grounds, but now that the drainage strategy and design has been published our concerns are more focussed. We would like to first address the geography of these two watercourses and the confusion which arises within the DCO submissions where the names Slough Dyke, SloughDyke/Fleet, the Fleet Tributary of the Fleet and Unnamed Watercourse 1 are used randomly. The Slough Dyke is a river under the management of the Environment Agency, its origin is in the Bowbridge area of Newark and it outfalls to the Trent near Cromwell Weir. The Environment Agency clearly reference it as The Slough Dyke and not as The Fleet. It is proposed that all the road drainage on the west side of the A1 up to the rail bridge will drain this watercourse. The Fleet, referred to in the DCO submission as ‘Tributary of the Fleet’, Unnamed Watercourse 1 and occasionally as the Fleet which is managed by the Trent Valley Internal Drainage Board and referred to by them as ‘the Winthorpe Airfield Drain’ rises in Coddington and flows via a culvert under the A46 to outfall to the Slough Dyke in Winthorpe. Virtually all of the new road surfaces east of the A1 are scheduled to drain to this water course. Reference to Ordnance Survey maps via https://parishonline.xmap.cloud/maps#map=16.450700198477726/482337.78/358813.93/0 reveals that this watercourse is named The Fleet in Coddington. Appendix 13.2 Flood Risk Assessment para 2.4.4 actually clearly names the Slough Dyke as a Main River and The Fleet as a tributary but on Figure 2.1 calls it the ‘Winthorpe Airfield Drain’. Why is it so confused in other areas? In our opinion this lack of precision has resulted in impact on the Fleet being dismissed. For instance in 6.3 Environmental Statement Appendix 13.1 Water Framework Directive Compliance Table 2 which selects watercourses for examination the Slough Dyke is ‘screened in’ because of the diversion works near Brownhills Junction, but the Fleet is not even mentioned though it is significantly affected by road and culvert construction at the Friendly Farmer roundabout. Furthermore, in the same table there is reference to ‘The Fleet Upper Catchment not being hydrologically linked to the works’! Surely this is some other ‘Fleet’. In Chapter 13 the Fleet gets a very perfunctory review in comparison to the Slough Dyke, which does not accord with our view. An examination based on the Environment Agency’s catchment map https://environment.data.gov.uk/catchment-planning/WaterBody/GB104028053111 with some approximation of internal boundaries shows that the catchment areas of the Fleet upstream of the confluence with the Slough Dyke is about 750 ha. This is almost the same as the catchment area of the Slough Dyke above the confluence. Although the Slough Dyke catchment in Newark is clearly less permeable that of the Fleet the Fleet catchment it is becoming more industrial, containing the major warehouse developments around Long Hollow Way and Godfrey Drive. Further developments are expected in this zone. Furthermore, the Fleet is a particular flooding threat in Winthorpe where it is constrained by an old culvert passing under the village green and Hargon Lane. The ground here is low and the adjacent Lord Nelson public house is particularly affected. This culvert is quite often at capacity and any increased in peak flows could be extremely damaging. We note that, in their submission to National Highways as Statutory Consultees the Trent Valley IDB stated ‘Surface water run-off rates to the Board maintained Winthorpe Airfield Drain must not be increased as a result of the development. The culvert carrying this drain under the A46 at NGR 481553 – 356044 is known to be at or around capacity added to which existing and further committed development on the airfield site will further exacerbate this situation. Enhancements to this culvert should be considered as a part of the scheme. Any surface water from the Northern section of the scheme, which discharges into the Winthorpe Airfield Drain should take into consideration the potential impact downstream within the village of Winthorpe.’ The Slough Dyke, whilst more on the edge of the village, still has the potential to flood in the low ground of Hargon Lane adjacent to Severn Trent’s pumping station. The more concerning issue is water pollution as the watercourse flows through the area of the village featuring the allotments, the Community Centre, the recreational field and the cricket ground. It is in this area that villagers are most likely to come into contact with the water. The proposed road drainage strategy is set out in 6.3 Environmental Statement Appendix 13.4 Drainage Strategy Report. In section 1.3. Design Parameters Agreed it states that attenuation storage and outflow rates to watercourses will be assessed as those relating to a I in 30 year Return Period (RP) or 3.33% Annual Exceedance Probability (AEP) event and flows in excess of these levels would overflow to the receiving water course. Plans in Appendix B of this Appendix show the paths that excess water would take from the attenuation basins into the Fleet. The justification for accepting this level of risk, instead of the DMRB specified 1% AEP, is an agreement with Notts County Council that, since excess flows above the 3.33% AEP level could overflow onto existing designated flood plains without causing damage to property and life, the expense of providing drainage infrastructure appropriate to the higher risk is not justifiable. This is probably reasonable in these circumstances and, to justify this approach, calculations have been produced showing estimates of the extra volume of water discharged to the flood plain. However, the attenuation basins serving catchments draining to the Fleet are not in any designated flood plain and any excess of flood water would drain directly into the Fleet and immediately into Winthorpe. It seems that this derogation of risk level will have a deleterious effect on the Fleet in Winthorpe. This design philosophy is echoed in appendix 13.2 Flood Risk Assessment 4.7.5 to 8 and 3.4.5 which also states that ‘Basins are designed to outfall to watercourses in the vicinity, including the Fleet’ and ‘Basins outside the floodplain also have an extreme event overflow area’. No such area for the Fleet discharges is shown on any plan. See also 8.3.5 of this appendix and various other places. Only in ONE paragraph, Appendix 13.4 Drainage Strategy Report 5.3.13 does a statement occur that ‘Outside the flood plain the attenuation areas (presumably including swales, filter drains etc) would be designed to store runoff from all storm events up to and including the 1 in 100 year event’ It is difficult to judge which principle has prevailed in the design process as calculations of the excess volumes resulting from this derogation as listed in Table 1 of the Volume Impact Assessment Appendix B (of Appendix 13.4) do not show any values for discharge flows or storage volumes for the Fleet zone basins. The area of road and associated infrastructure draining to the Fleet and Slough Dyke have been divided into various sub-catchments as shown in plans TR010065/APP/2.6. For the most part the drainage route is clear; via swales, filter drains, attenuation basins and outfalls. The section from the service stations to Winthorpe roundabout is less straightforward. This section dates from the construction of the A1 bypass in 1963/4 although it has been updated since then. What is not clear is the state of the drainage provision. On the western, Lincoln bound carriageway there are some lengths of combined drainage kerbs which National Highways consider to be inadequate as they propose an additional filter drain, along this section, to conduct flows to the attenuation basin. The eastern carriageway has an existing system of gulley gratings and pipe drain which probably outfalls to the Fleet (Winthorpe Airfield Drain) near to the Shell service station and upstream of the Bleach House Culvert. A reasonable inference is that the western carriageway is the old pre-1960,s A46 and the eastern is the new section with formally designed drainage infrastructure. Are National Highways aware of the design parameters of this system, designed over 60 years ago? It seems that the new Friendly Farmer Link Road will also drain to the same outfall as the eastern carriageway and, being of almost the same catchment area, will double the flow into the Fleet. There is no indication of the drainage system design for this road. A crude estimate of the peak flood flows at this culvert shows an increase of between 5 and 8% over the existing levels into a culvert which is known to be near or at full capacity already. The Drainage Plan, sheet 5 of 7, showing the proposed infrastructure in this area seems to propose that these catchments will drain to Outfall 015, which is on the Winthorpe side of the road, the opposite side to these carriageways. Appendix 13.4 makes a very confused statement on how this will be arranged:- ‘6.17.3 The surface water run-off from this catchment outfalls to a culvert under the A46 which discharges to an existing outfall to the Fleet via an existing culvert.’ Is the culvert under the A46 the existing culvert (the Bleach House Culvert) or something new, in which case this isn’t indicated on any plan? The most likely interpretation of situation is that the two road carriageways will discharge their flood flows into the Fleet upstream of the Bleach House Culvert and hence probably overload the capacity of the culvert and also the one in Winthorpe village. The reasons given by National Highways for not attenuating these flows is lack of space in the vicinity of the outfall. However, it is surely possible that a more holistic view of the water system here, including the Fleet, the culvert, the road drains and local developments could produce some system of buffer storage and flow control to attenuate these flood flows. At the very least, a more rigorous modelling of flow hydrographs from the whole catchment upstream of the Bleach House Culvert might demonstrate competence in the system to handle the outflows. 11. Conclusion Although, as previously noted, correspondence between Think Again and National Highways has dealt with a significant number of the issues which were of concern to us a number of details within the design proposal are still worrying. We would ask the Planning Inspectorate to include some of the issues raised in this submission during their examination process.