10th November 2020 Your ref: TR010056/S42 A417 Missing

National Trust South West Region Unit 3, Hubbard Wing Leigh Court Business Centre, Pill Road, Abbots Leigh, Bristol, BS8 3RJ Tel: +44 (0) 1275 378440 www.nationaltrust.org.uk

President: HRH The Prince of Wales Chairman: Tim Parker Director-General: Hilary McGrady Regional Director: Rebecca Burton Regional Chair: Doug Hulyer

Registered office: Heelis, Kemble Drive, Swindon, Wiltshire SN2 2NA Registered charity number 205846

10th November 2020

Your ref: TR010056/S42 A417 Missing Link Supplementary Statutory Consultation Oct.- Nov 2020 Our ref: 20201110 A417 Suppl. Stat. Cons. response

A417 Missing Link Project Team Highways England Temple Quay House 2 The Square, Temple Quay Bristol BS1 6HA

Sent by email: [email protected]

Dear Sir/Madam

A417 Missing Link road improvement scheme

This letter and its enclosure are the National Trust’s response to the supplementary statutory consultation undertaken by Highways England in accordance to Section 42 of the Planning Act 2008 for a proposed Development Consent Order application.

The National Trust is Europe’s largest conservation charity with over five million members. Established over 120 years ago, the Trust is responsible for the protection of some of the most beautiful, historically important and environmentally sensitive places in England, Wales and Northern Ireland for the benefit of the nation. The Trust has a statutory duty under the National Trust Acts to promote the conservation of these places. Given the range of our activities, we are in a position to comment both from the perspective of a landowner (the Trust’s ownership of land at Crickley Hill lies adjacent to the current A417; on the Cotswold scarp within the Cotswolds Area of Outstanding Natural Beauty (AONB) and jointly managed and owned by the National Trust and Gloucestershire Wildlife Trust (GWT)) and as a major conservation organisation responsible for safeguarding the nation’s natural and historic assets.

In response to this supplementary consultation, we agree that measures are needed to address the issues associated with the 5km stretch of single carriageway between Brockworth bypass and Cowley roundabout. However, as we have stated in previous consultation submissions, in the National Policy Statement (NPS) for National Networks – there is a “strong presumption against any significant building of new roads” in protected landscapes such as AONBs, unless it can be shown that there are compelling reasons for the enhanced capacity and with benefits outweighing the costs “very significantly” (para 5.152). There are also requirements for “high environmental standards”, to have regard to the purposes of the AONB

mailto:[email protected]

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designation, and to avoid compromising the purposes of the designation and for projects to be “designed sensitively” (para’s 5.153 and 5.154). As stated in previous submissions, we consider that it is essential that the proposed highway scheme is a genuinely “landscape-led” solution, and we will continue to advocate for this. Alongside Strategic Stakeholder Panel members, we have also requested for Highways England to demonstrate how the scheme (re)design differs from a standard ‘engineering-led solution.’ We feel that this is becoming increasingly important for all parties, if broader support for the scheme is to be achieved. In addition to our continued advocacy for the landscape-led vision, we will also continue to emphasise the aims of conserving and enhancing the special character of the Cotswolds AONB, reconnecting landscape and ecology, bringing about landscape, wildlife and heritage benefits, and enhancing visitor enjoyment. We would also stress the importance of protecting the views and setting of heritage assets, and bringing about substantial benefits for the Cotswolds landscape and environment, including a clear net gain to wildlife and habitats, as well as delivering high quality mitigation that meets the objectives within the draft Environment Bill and impact of climate change. With regards to the specifics of the supplementary statutory consultation, we have engaged in collaborative sessions with Highways England during the summer/autumn alongside Cotswolds Conservation Board (CCB), GWT and others. Collectively, we have clearly articulated three key areas of concern:

1) How the scheme will strive to achieve biodiversity net gain

2) Ensuring the right mitigation is implemented to deliver landscape connectivity and reduce SSSI fragmentation, and

3) That all bridge structures within the scheme are designed and integrated sensitively

into the landscape. This response reinforces these three key priorities. Moreover, noting that the National Trust has been working collaboratively with GWT and CCB during this process, common themes and priorities should therefore be evident in our individual responses. Highways England, the National Trust, GWT and CCB have collectively committed a great deal of time and effort over recent months, working collaboratively and collectively to outline how the design of the scheme could be improved and the three priorities addressed. As the deadline for the Development Consent Order (DCO) application draws nearer, evidenced commitments are required from Highways England that improvements are being integrated into the re-design to build confidence that this collective investment of time and effort has yielded improvements and that stakeholder feedback and input is being listened to and taken forward. It is in the interests of all parties for this to be done in a timely manner i.e. prior to the final design fix, (and not at the time of DCO submission) – so that opportunities remain for further discussion and design refinement. We want to see a well-designed scheme succeed and we will continue to work collaboratively with Highways England, while continuing to strongly advocate the need for it to be sensitively designed and respectful to the landscape it sits within. Our current position is that more work is needed to reduce the impact of the new infrastructure on the surrounding countryside to deliver the landscape-led solution that has been proposed and that this special

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place deserves and we are fully committed to continuing to work with Highways England and other organisations to achieve this. We trust that Highways England will give full consideration to the National Trust’s comments as the scheme’s design develops and that a solution can be delivered which achieves broad support and a lasting, beneficial legacy for this special landscape. Yours faithfully, Sarah Cook Project Manager, Crickley Hill South West Landscapes and Infrastructure Enclosure: A417 Missing link feedback questionnaire response

Enclosure – National Trust response Page 1 of 24 10th November 2020

National Trust - A417 Missing Link Supplementary Statutory Public Consultation Response

November 2020 New crossings: Cotswold Way and Gloucestershire Way crossings Question 1a. To what extent do you support the Cotswold Way crossing? The National Trust supports the provision of a crossing in this location, to provide connectivity along the Cotswolds escarpment and providing a safe crossing point for walkers on the Cotswold Way, as well as for other non-motorised users and livestock (cattle) movement between Crickley Hill and Barrow Wake. The design, form and appearance of the crossing should respond to the natural and built character of this part of the Cotswolds and should make a positive contribution to sense of place. The National Trust has, along with Cotswolds Conservation Board (CCB) and Gloucestershire Wildlife Trust (GWT) recently submitted a bridges brief (at Annex A) that sets out our expectations as environmental stakeholders, regarding all four proposed access bridges and crossings within the scheme design using Highways England’s Aesthetic Appraisal Document (AAD) methodology and we would expect Highways England to refer to this document, and its recommendations, when developing the design for this crossing. With regards to the Cotswold Way crossing, it would be good to understand more about the detailed design and proposed materials of all parts of the crossing, as well as the approaches. It would appear that design work is well progressed for this element, so it would be beneficial to understand the decision making process that has come to the proposed concept design, as it currently does not appear to reflect the Cotswolds characteristics, or the landscape colour palette when observing the geological features or landscape characteristics in the immediate vicinity. As Highways England are aware, we do have concerns that at just 5m width, thought will need to be given to final design to avoid conflict between the different user groups (including disabled users) for walkers, cyclists, horse-riders and periodic movement of cattle. It is also important to consider how horse-riders and cyclists safely approach and leave the crossing to join existing bridleways and therefore minimise damage to priority habitats and wildlife. The structure’s aesthetics are important as the bridge will, for many users, be seen as a gateway to the Cotswolds National Landscape. This bridge will provide no ecological connectivity and therefore, increased fragmentation of the SSSI caused by widening of the road will need to be mitigated in another way/location. We are especially concerned about calcareous grassland connectivity and currently, the Gloucester Way bridge will be the only means to provide functional landscape connectivity. The Design Manual for Roads and Bridges (DMRB) CD 351:The design and appearance of highways structures, March 2020 suggests that: 'The design process of highway structures shall include an evaluation of all aspects that affect the aesthetic quality of the completed structure, its position in the landscape and its impact on social, cultural and


heritage sensitivities within the community.’ (para 2.1) The guidance also refers to the AAD which is the ‘means by which the key influences and decisions that shape the approach to aesthetics is recorded and agreed.’ (Para 3.1 Note). We therefore ask Highways England to provide the additional relevant information that should have been produced in developing the proposals for this structure and to continue the design of this structure in collaboration with stakeholders. When considering a response to the heritage impact assessment work using DMRB methodology, unfortunately it does not focus on the Cotswold crossing directly (but on the project as a whole) so it is difficult to give feedback with any certainty regarding the impact of the structure on the setting of key heritage assets. However, the key assets in this area would include Crickley Hill, Emma’s Grove, Barrow Wake and the Peak within the Neolithic landscape. More work is therefore needed to understand significance, setting and the impact using heritage values and best practice setting guidance (raised further under question 9). When design options for this structure have been developed further, photomontages from key locations will be essential, to check, test and ensure that the visual impact is mitigated as much as possible. Positively, the Cotswold Way access bridge will enhance people’s ability to physically connect Crickley Hill, Emma’s Grove and Barrow Wake. This will be a gain for landscape connectivity and present an opportunity to enhance people’s understanding of the historic environment and landscape setting. In respect of the Cold Slad lane link to the immediate north of the crossing, we consider that this should appear as a rural lane rather than an urban highway, with the potential to narrow to single carriageway where users of the Cotswold Way cross the lane, depending the type of crossing facility used. The function of laybys shown in the new Cold Slad lane also need to be clarified. Separate to this consultation response, we would also refer Highways England to our landowner land acquisition consultation response for this supplementary public consultation, concerning National Trust inalienable land and the proposed permanent and temporary land take required for the construction works within the red line boundary for the proposed new Cold Slad lane, Cotswold Way access bridge and Ullenwood junction. New crossings: Cotswold Way and Gloucestershire Way crossings Question 1b. To what extent do you support the Gloucestershire Way crossing? The National Trust supports the provision of an additional crossing in this location, to provide access connectivity for the Gloucestershire Way, and to provide vital landscape- scale connectivity with benefits for ecological networks. This is one of the most important design changes within the scheme; however, further consideration must be given to design, habitat and adjoining land management to ensure it delivers the intended and required outcomes. The bridges brief at Annex A sets out the expectations of the National Trust with respect to this crossing and the National Trust will continue to fully commit our time and expertise to ensure that the right design is delivered by Highways England. This bridge will serve two important purposes. First, to provide an access route (connecting the Gloucester Way to Cotswold Way). Second, and equally importantly, to mitigate the impact of the ecological severance of the landscape. The bridge needs to


provide a connection for calcareous grassland, help reconnect the SSSI and reduce habitat fragmentation. In this location, it needs to mitigate the impacts of the widest section of highway corridor (at least eight lanes of traffic*) within the context of the highly valued Area of Outstanding Natural Beauty (AONB) landscape. We have low confidence that, as currently designed, the crossing can achieve this second purpose and further design modifications are required. There is a strong case for a wider crossing, at least akin to the c. 30 metres width of the Scotney Castle green bridge on the A21 in Kent. A more substantial crossing at this location is required, as although the current proposed bridge responds to the bat survey data (with more crossings and a higher proportion of Annex II species), the crossing appears further north than the severed commuting routes so there is a risk it will not be used by bats. The same issue applies to badgers and barn owls. However it is recognised that moving the crossing further south would impact the Ullenwood ancient woodland key wildlife site (KWS) and there needs to be a compromise whilst still providing the essential north/south landscape scale connectivity and habitat stepping stones that can connect to the Barrow Wake SSSI. The Preliminary Environmental Information Report (PEIR) should recognise this constraint in the mitigation design and ensure a robust monitoring strategy is included in the Landscape and Ecological Management Plan (LEMP) including provisions for additional mitigation if the crossing points are ineffective. More information on the bridge design is needed to comment on its efficacy for the target species but the design shown in the fly-by suggests people will be zoned to one side of the bridge which is key to minimising interaction if mobile species are to use the bridge (hence the requirement for increased width). The target species identified are mostly nocturnal so conflicts are likely to be limited, but it is also important to consider that this bridge will be the only method for less-mobile flora and fauna to cross the road. It is important that the proposed bridge, essential mitigation and enhancements, create opportunities to restore (ecological) connectivity across the landscape. It will be important that there is a robust long-term management plan not only for the bridge, but that it incorporates the land management practices either side of the bridge to provide a resilient habitat corridor in the landscape. Based on the Gloucestershire Nature Recovery Network (NRN) map, this area has high potential to link existing areas of calcareous grassland priority habitat and to strengthen the SSSI network. The scheme, and this crossing, provides an excellent opportunity to deliver this but is currently falling short of its potential. This can be achieved by including a high proportion of calcareous grassland on the bridge and by creating a calcareous grassland corridor between the bridge and the Barrow Wake SSSI unit, sufficient to mitigate the habitat severance. We would re-iterate the importance that mitigation must be guided by Professor Lawton’s report, ‘Making space for nature’ which underpins Defra’s Natural Environment White Paper, 2011, taking a collaborative approach to create areas that are “better, bigger, more and joined up” positively and proactively restoring a healthy, beautiful, natural environment within this special landscape. We acknowledge that Highways England are looking at how this can be achieved within the scope of the redline boundary, but also by offsetting mitigation and through wider landscape opportunities and we are pleased to see that approach being taken. However, at this stage in the planning application process, with the submission deadline approaching, we need to be reassured of Highways England’s commitment to delivering priority habitats, connectivity and ultimately, biodiversity net gain through land management commitments along this section of the strategic road network.


Regarding the architectural design and external appearance of the crossing, it will be important that it fits in with the landscape character and local vernacular of the Cotswolds AONB. Referring to good practice from other schemes such as the A354 Weymouth relief road scheme in Dorset, we are pleased to see this crossing having ‘splayed’ ends as it joins the land on either side of the cutting, providing a funnel effect and will have benefits in terms of how it fits in with the local landscape and guide mobile wildlife across the crossing. However, this crossing may also be favoured by horse riders and cyclists, including off-road cyclists, and it could be more intensively used by these users in preference to the Cotswold Way crossing. For habitats to be able to establish on the bridge, zoning people from the wildlife corridor will be key, if it is to withstand heavy use. This re-iterates the point for the need of a substantive green bridge type crossing at this location. As mentioned in Question 1a we provided more detail on bridge design principles in the bridges brief document at Annex A and we look forward to collaboratively developing the design of this bridge with Highways England, their consultants and key partners. The Highways England heritage impact assessment work completed using DMRB methodology, does not focus on the Gloucestershire Way crossing directly (but on the project as a whole) so it is difficult to give feedback with any certainty on the impact of the structure. However, more work is needed to understand significance, setting and the impact using heritage values and best practice setting guidance (discussed further under question 9). Positively, the Gloucestershire Way will enhance people’s ability to physically connect with Crickley Hill, Emma’s Grove, Barrow Wake and other notable sites, which will increase understanding of historical assets and how human activity has, over millennia created the living landscape we currently enjoy. This will certainly be a gain for landscape connectivity and presents an opportunity to enhance people’s understanding of the historic environment and landscape setting if the bridge is designed appropriately and sensitively. One last point is that on the general arrangement sheet 2 of 6, it shows a significant construction compound in close proximity to the bridge location, close to the SSSI, Emma’s Grove and in the direct migratory path of bats. We would want to understand the assessment, mitigation measures that will be taken to minimise the impact of its presence and management plan to restore and monitor the habitats once construction works have been completed. [* Note: eight lanes of traffic would pass under the Gloucestershire Way crossing according to the scheme plan, although the artist's impression in the consultation booklet and video show nine lanes – A436 three lanes, A417 five lanes and a northbound slip lane]. The change in gradient of the A417 as it climbs the escarpment near Crickley Hill Question 2: To what extent do you support the change in gradient of the scheme? The proposed change in grade would result in multiple benefits to the scheme overall and appears to remove the extent of some harmful impacts, including visual impacts, effects on the water environment and in terms of wider environmental impacts. If this reduced depth of excavation means less land/habitat loss, then this is indeed beneficial. Therefore, the National Trust broadly supports a higher gradient than the 7% proposed in the Autumn 2019 consultation.


With the cutting being much reduced, it presents a lesser risk to the scheme as it will avoid digging into less stable materials, has a reduced impact to the SSSI geological features (notable rock exposures), ancient woodland and Emma’s Grove. Decreasing the amount of spoil by approx. 1m cubic tonnes is another significant environment outcome (potentially reducing 50,000 lorry movements that would have been required to take the waste material off-site). However, it will be important to ensure that any areas of greater landscape impact (for example because fast moving vehicles are physically closer to public rights of way) are fully understood and ameliorated where appropriate. This also applies to any greater noise impact on the users of Crickley Hill and public rights of way leading to it. Sound, light, air, NO² pollution are still of concern and we will want to further discuss the data and proposed mitigation (for example choice of road surface, noise barriers etc) to address these issues and associated impacts for Crickley Hill SSSI. We also want to understand and discuss the design detail of how the dual carriageway will actually tie into the verges, woodland edges and agricultural fields along the escarpment, whilst being sensitive to the geological rock exposures and water courses, but at this time, we believe that the 1% gradient change will have minimal impact on heritage or landscape. The design of Cowley junction Question 3: To what extent do you support the changes to Cowley junction? In principle we have no objections to the proposed change at Cowley junction and the National Trust is supportive of this location as it provides mitigation for a severed bat commuting route. Hedgerow and standard tree planting also provide mitigation for bats and have the potential to strengthen the Nature Recovery Network by linking a woodland to the east with the wider landscape. However, the current statements of significance and the settings assessments do not focus on the impact of the Cowley junction directly (but on the project as a whole) so it is difficult to give feedback with any certainty on the visual impact on setting. Further work is needed (discussed under question 9). Photomontages of the design options from key locations will be essential when undertaking reviews, to check and ensure that visual impact is minimised. We do however understand that there is a significant Roman settlement in the location of the Cowley junction where discussions are being had directly with Historic England and so, we will not add further comment, other than it is a real opportunity to understand human activity in this area, connecting via the Roman road to Birdlip village, Barrow Wake and beyond. Utmost care must be taken whilst trenching, following the stringent methodology. Lastly, on the general arrangement sheet 4 of 6, it shows that a significant construction compound will be in the vicinity. We would want to understand what measures will be taken to minimise the impact of its presence and management plan to restore the area once construction works have been completed.


The rerouting of the B4070 to Birdlip via Barrow Wake Question 4: To what extent do you support the rerouting of the B4070 to Birdlip via Barrow Wake? The National Trust is broadly supportive of the revised scheme design as it is now using part of the existing highway. The proposed change would reduce both the length of new highway that is required and agricultural land take and therefore, on balance, may represent a beneficial change to the scheme. We also appreciate the aspiration to address the known and persistent anti-social behaviours currently associated with the Barrow Wake car park and this revision will go towards deterring this behaviour. We would however want to ensure that the landscape and visual impacts (and effects within the context of the 'Neolithic bowl') of traffic using the proposed roundabout and new stretch of highway along the top of the escarpment are fully understood and appropriately mitigated and reduced where necessary. This includes any wider visibility of traffic within the landscape and associated effects such as noise or light pollution. Whilst new Cotswold stone walls are referred to, these would not screen the upper parts of vehicles, nor much of the noise and light pollution associated with them. Impact on the SSSI is still a concern. The realignment misses the opportunity to either reduce the size or remove the road surface and car park completely from the Barrow Wake SSSI unit to a more suitable location. However, we understand that although this was not part of the 2019 proposal, that this is being explored separately. The area of land currently taken up by the car park has the potential to increase the amount of habitat within the SSSI and we would encourage Highways England to continue to explore this proposal. Removing the A417 from this location is certainly a major benefit. Against the baselines there will be a reduction in nitrogen deposition, but this remains above the critical load for calcareous grasslands for which the SSSI is notified and we would want to discuss what other measures could be considered to reduce this further. When referring to the PEIR, it does not compare the changes between the two consultations in this location and so it is difficult to see what benefits or otherwise there are for habitats and species. The proposed Barrow Wake roundabout will result in a loss of road verge habitat (scrub and semi-mature trees) within the SSSI but these are considered secondary fabric and their loss will not affect site integrity. However compensatory habitat of a higher distinctiveness (e.g. calcareous grassland) should be provided in a location where it strengthens the SSSI's resilience. This reflects our response for question 1b for the need to provide habitat connectivity between the Barrow Wake SSSI and Gloucester Way bridge. It is also important that robust mitigation is provided to protect the SSSI from dust (and other pollution) during the construction phase, especially the musk orchid bank east of the car park and we would want to see the mitigation strategy for the Barrow Wake SSSI for each phase of the construction works. Lastly, separate to this consultation response, we would also refer Highways England to our landowner land acquisition consultation response for this supplementary public consultation and our points raised regarding conservation grazing on the Barrow Wake SSSI (as tenants on GWT land ownership) and safety measures for the herd both during the construction period and once scheme is open to traffic.


Improvements for walkers, cyclists, and horse riders, including disabled users Question 5: To what extent do you support the changes to public rights of way? The National Trust has been involved as a stakeholder, alongside many representatives of user groups and local community groups in the Highways England Access (walkers, disabled users, cyclists and horse riders) technical working group and collectively, have been working through the proposed revisions to the various rights of way to ensure there is a good network across the proposed road scheme landscape into the local communities and wider. Providing good access into the landscape is not only one of the objectives for the scheme, but the ability to connect and immerse ourselves with nature, green spaces, our heritage and culture has become ever more important for our health and wellbeing. Equal access to nature and fresh air is what the founders of the National Trust set out to achieve 125 years ago. We support the proposed improvements, being mindful that they must accommodate different user groups, whilst still protecting the mosaic of habitats, designated sites and differing land uses across landownerships. As presented in the public consultation materials, we support the provision of the two crossings (Cotswold Way and Gloucestershire Way) and the re-purposing of the existing A417 route. As well as the benefits and opportunities for these user groups, it will be important that the route has a ‘rural’ rather than an ‘urban’ character. There is also a need for further thought as to how northbound users of the route and the Cotswold Way crossing would be guided (e.g. signage), to manage any potential effects on the ecological value and integrity of the SSSI at Crickley Hill in particular. The other concerns relate to increased visitor pressure and impacts on the Crickley Hill SSSI units and the Cotswolds Commons and Beechwoods Specials Areas of Conservation (SAC). Consideration has clearly been given to providing multiple routes (including circular options), road crossing points and car parks which will spread the impacts, and these are welcomed. However, the PEIR does not include the expected assessment of visitor impacts on the SSSI and the resulting embedded or essential mitigation. The Cotswolds and Commons Beechwoods SAC Habitats Regulations Assessment (HRA) has not been submitted with the PEIR so we cannot comment on its conclusions. However, the effects are not thought to be significant given the distance from the scheme and the relatively small-sized car park which will be built at the Golden Heart. To reconfirm, we do support the repurposing of the A417 and it is an exciting opportunity to deliver a green corridor that helps to connect a severed area, but we have expressed there are lessons to be learnt from other road schemes, including the A3 Hindhead tunnel, Surrey. The A3 Hindhead road scheme is a particularly good example as the scheme directly impacted the Trust’s land at the Devil’s Punch Bowl, and the same methodology to repurpose the road to reconnect the landscape was undertaken there. The recently published five-year post-opening evaluation raised concerns regarding the strategic objective to provide environmental mitigation that would minimise predicted adverse environmental impacts. It identified issues that remain around maintenance, lack of establishment of heathland and the gorse growth which is impacting new planting. Issues with the A3 road scheme must not be repeated regarding using topsoil spoil and not taking sufficient measures to monitor and manage the healing process of habitats and grasslands along this escarpment.


It is clear there has been some early thinking and on the general arrangement sheet 5 of 6, it proposes the existing A417 to be de-trunked and replaced with 3m hard paving, 2m soft surface and additional planting. We have requested for further discussions to be had on this key element of the scheme to ensure it is seamlessly integrated into the landscape and that lessons are learnt from other schemes – especially in relation to surface type and not for it look like an abandoned road or an afterthought. We understand that it will be important that the right surface is provided for all users, but it must not appear as compacted tarmac, nor an urban ‘road’ in the landscape. The surface needs to blend into the surrounding grasslands and allow easy transition for wildlife. It will also be important to understand anticipated users and vehicle access and the legal status of the Air Balloon Way. It will be important that the right balance is given between access and protecting SSSI, priority habitats, species and heritage assets and we look forward to further discussions with Highways England on this. Replacement of common land Question 6: Do you agree with our proposals for replacement common land? We support the re-provision of common land in principle but have a few observations. The proposed location for the new common land would necessitate a short detour for cyclists and horse riders (off the former A417 route and via the Barrow Wake car park), and it appears that a restricted byway is being proposed through the replacement common land and all other means of access would be through the Barrow Wake car park or via an access route up on to the repurposed A417 near the proposed Barrow Wake roundabout. All of this could certainly help reduce the number of cyclists and horse riders heading northwards and limit the visitor pressure on the SSSI at Crickley Hill, but we would wish to discuss this further with Highways England. We also understand that the repurposed common land will be transferred to GWT. Ideally the common land would be calcareous grassland and could provide compensation for habitat lost within the Barrow Wake SSSI unit. Consideration will need to be given to the management and maintenance of the area and how visitor spill from the repurposed Air Balloon Way may affect its viability as compensatory habitat. As stated in Q5, the resurfacing of the former A417 and the addition of common land in this area has real potential to be an enhancement for Barrow Wake. At other National Trust properties, The National Trust has been involved in discussions of how to reintegrate roads into landscapes (for example the A3 Hindhead, Surrey road scheme) and we welcome the opportunity to discuss lessons learnt with Highways England and their consultants to achieve the best solution for this scheme. Environment Question 7: Do you have any comments on the likely environmental effects that have changed since the previous consultation? There are two main issues we would wish to see addressed within the scheme design. Firstly, our concern on how this scheme will deliver biodiversity net gain, to be a landscape-led scheme and the second, concerning the SSSI fragmentation (which includes the north/south landscape connectivity via Gloucester Way crossing).


We acknowledge that Highways England have no legal obligation to deliver Biodiversity Net Gain (BNG) within this scheme, as quantified by the Defra metric. However, Highways England’s Biodiversity Plan sets out the strategic aims of no net loss by 2025 and biodiversity net gain by 2040 along the Strategic Road Network (SRN). We would be extremely disappointed if a net gain in Priority Habitat area were not achieved in this scheme, as this would contradict Government commitments to deliver nature’s recovery, particularly in National Landscapes e.g. 25 Year Environment Plan, the draft Environment Bill, Glover Report and the Prime Minister’s recent announcement to get 30% of land in good condition for wildlife. It would also not be consistent with the statutory purpose of conserving and enhancing the natural beauty of the AONB (with biodiversity being one of the factors that contributes to the area’s natural beauty). At this stage of the process, we wish to see a commitment from Highways England to enhance existing calcareous grassland and to work with key stakeholders to identify and restore new areas of calcareous grassland that will help to protect the future of this part of the Cotswolds AONB (in the 1930s, around 40% of Cotswolds was covered in calcareous grassland, yet today it is less than 1.5%). It will be crucial that plans are implemented to continue the management of the downland characteristics and to improve habitat connectivity long after the road scheme is opened to traffic and we would want to understand how Highways England intends to deliver against their own Biodiversity Plan objectives of no biodiversity net loss by 2025 for this scheme. We note provisional estimates of biodiversity net loss of approx. 20% in relation to the current design, which Highways England will need to improve ahead of the DCO submission. We accept that the Defra tool is still being developed and that Highways England have proposed an approach that will deliver higher quality habitats in the long-term (but delivers lower calculation scores) but clearly, this raises a concern in how the scheme can therefore achieve its ‘landscape-led’ ambition solely within the red line boundary. We are encouraged by revised proposals being presented to deliver net gain for priority habitat creation that includes an increase in lowland calcareous grassland, lowland mixed deciduous woodland and over 2km+ of hedgerows; however, it is important that quality and quantity and connectivity are all given appropriate priority and that the collaborative discussions being had with ourselves and key stakeholders continue. Highways England’s approach to BNG needs to be supported by the publication of a coherent ecological masterplan which delivers a sufficient quantity of Priority Habitats in suitable locations. The scheme must implement the mitigation hierarchy and provide adequate mitigation and compensation for protected species, designated sites and other features of material consideration (i.e. other priority habitats and species). Highways England net gain approach must be supported by a Landscape and Ecology Management Plan (LEMP) which details specifications for habitat creation, aftercare, long-term management and monitoring. This should include details of the authorities/landowners responsible for long-term management and how this will be enforced (e.g. Section 106 agreements). With regards to the SSSI fragmentation, with the original proposed green bridge removed from the scheme, the Gloucester Way bridge is now the only alternative solution that can provide any form of north/south landscape connectivity and provide the habitat stepping stones between the Crickley Hill and Barrow Wake SSSI. We have already given our response in Q1b regarding the importance of the Gloucester Way bridge, but this is a once


in a lifetime opportunity to get this right. We need this scheme to deliver the right solution, to deliver the landscape-led vision. At the moment, it is questionable whether the overall design and mitigation of the scheme addresses the extent of severance and land take within the context of a highly valued AONB landscape. Continued dialogue is crucial to work towards significantly improving this current position and Natural England will be a key organisation to advise and support this goal. We are however, encouraged by discussions being had with Highways England around opportunities outside of the redline boundary which combined, would have the potential to deliver BNG, a mosaic of diverse habitats, landscape connectivity, resilience and increase calcareous grassland (a key characteristic of the Cotswolds landscape), whilst providing access for people and wildlife to move freely across this special landscape. General commentary Question 8: Do you have any comments on any of the other design changes that have been introduced since the previous consultation? We have no comments. General commentary Question 9: Do you have any other comments?

With this surface solution, Highways England are promoting a landscape-led scheme that will need to conserve and enhance the special character of the Cotswolds AONB. Highways England have stated in the consultation materials that “landscape is a primary consideration in every design decision that we make”. At this point in the process, we request Highways England to provide assurances of how they will meet the scheme design principles and objectives and confirm the approach that will be taken to deliver a landscape-led scheme in the Cotswolds AONB. Our remaining comments refer to the PEIR. Overall, the amount of calcareous grassland creation is a positive outcome for the scheme. We are pleased to see that Highways England have maximised habitat creation opportunities within the red line boundary and are seeking to create high distinctiveness (priority) habitats where possible. The calcareous grassland creation would deliver greater benefits if it were located in the north of the scheme (between Barrow Wake and Shab Hill) where it would contribute to the Nature Recovery Network (NRN) and enhance the SSSI's resilience. However, we will need to see the detail and evidence within the LEMP to have confidence for habitat creation methodologies, long-term management, monitoring and remedial actions. Having reviewed the PEIR, we believe there are some gaps in the mitigation and compensation sections and some of the proposals could be more creative (for instance, para 8.10.43 states it is not possible to mitigate the loss of veteran trees but no proposals are made to compensate for their loss (e.g. management to extend the life of existing veteran trees, veteranizing retained mature trees, etc.). Other points include:

• Methodology

- PEIR does not include valuation of land within regional nature recovery networks (e.g. Cotswolds NIA and Gloucs NRN) as per guidance in Table 8-2.


- Reassessment of habitats based on their value to species groups would be helpful (e.g. arable land and breeding/wintering birds)

- Some calcareous and neutral grasslands have been incorrectly mapped and valued, which in turn will affect the mitigation strategy. This may affect the assessment of significant effects, the Defra metric and the compensation requirements. For example, an area of MG5 (lowland meadow Priority Habitat) has been classified as semi-improved neutral (contrary to the botanical assessment report) and likewise two CG3 fields (near the Air Balloon pub) have been classed as semi-improved calcareous. We have previously raised our concerns on this and would value a discussion.

- There is no mention of severance impacts on the SSSI. - There are no conclusions on the effects of ground water change on Bushley Muzzard

SSSI. This is concerning as there is text about modifying ground water flows, which the SSSI is reliant on to maintain its existence

• Mitigation

- No construction mitigation has been provided to prevent dust from effecting Crickley Hill & Barrow Wake SSSI Units 3 and 4 which are within 50m of the construction site

- No discussion on impacts of increased visitor numbers on Crickley Hill and embedded mitigation for this

- No details on construction mitigation methods to prevent dust effecting Barrow Wake SSSI Unit

• Compensation

- Environmental Masterplan appears to show tree planting on northern tip of Barrow Wake SSSI unit which we would like to have further clarification on.

- No compensation proposed for loss of nine veteran trees or Annex I tufa habitat - No specific compensation proposed for the loss of (potentially) irreplaceable ancient

woodland at Emma's Grove • Enhancement

- No discussion on how the enhancements achieve connectivity with existing Priority Habitats and contribute to the NRN

- No discussion on viability of creating woodland and grassland Priority Habitats in areas which exceed the critical nitrogen loads for these habitats.

• Monitoring

- No details on monitoring regime has yet been provided. There are opportunities to study the efficacy of standard mitigation which would benefit Highways England (and others) in the future.

On the following pages, further detail has been provided in a table – predominantly concerning Chapter 8 but other points have been raised across the PEIR for review and response from Highways England.


Para. Scheme Location Comment

8.7.20 Whole scheme

Table 8-2 states that any habitat identified as suitable for Priority Habitat restoration in local restoration plans (e.g. Gloucs NRN, Cotswolds Nature Improvement Areas, etc.) should be listed as of Regional Importance. In this section there is no analysis of the scheme, where it overlaps with the NRN/NIA and how this affects the biodiversity value of these habitats

8.7.41 Crickley Hill & Barrow Wake CG described as species-rich with abundant Upright Brome. If so, this should be classed as CG3. This is part of the lowland calcareous grassland HPI and of National Importance

8.7.43 Shab Hill Only a very small patch of CG but it is CG4c. This is part of the lowland calcareous grassland HPI and of National Importance

8.7.45 Air Balloon roundabout NVC report describes these fields as CG3c and CG3d which are part of the lowland calcareous grassland HPI and of National Importance

8.7.46 Bushley Muzzard SSSI Only a very small patch of CG but it is CG4c. This is part of the lowland calcareous grassland HPI and of National Importance

8.7.47 Various

In the report the semi-improved CG habitat has not been defined. Where descriptions are given in paragraphs 8.7.41-46, or are referenced in the Botanical Assessment report, they qualify as lowland calcareous grassland HPI and are of National Importance. Other areas mapped as SI CG with supporting Target Notes (e.g. TN12) also appear to qualify for NVC CG communities, making them lowland CG HPI and of National Importance. This is potentially the case for all areas mapped as SI CG as all NVC CG communities belong to the lowland CG HPI.

8.7.50 Shab Hill MG5a is a lowland meadow HPI (see Botanical Report). This should be mapped as unimproved neutral grassland and of National Importance.

8.7.51 Crickley Hill MG5 area is very small but is lowland meadow HPI and of National Importance. 8.7.52 Shab Hill See comment for 8.7.50

8.7.88 Norman's Brook The tufa report concludes that feature G231 supports Annex I habitat qualifying vegetation. Therefore, it should be considered at least of national importance.

8.7.90 Various

The tufa report states that there are other locations with tufa and associated vegetation. Due to the rarity of this habitat type, both nationally and regionally, all occurrences should be considered at least of regional importance. NB, JNCC website states: Cratoneurion tufa formation is a relatively rare phenomenon in the UK. Petrifying springs occur as small, scattered flushes, and the total area of this habitat type is small.

8.8.13 Bushley Muzzard SSSI

Ground water modelling has not been completed to assess the impacts on the site. Chapter 13 (13.18.09 and 13.18.40) includes more detail. Full details will be provided in the ES but are not given here. This is a concern considering the potentially significant effects.

8.9.13 Barrow Wake and Crickley Hill SSSI Will dust protection measures be employed adjacent to SSSI units during excavation?

Table 8-16 Air Balloon cottages T171 and T172 will have root zone and canopy protection. How big will these be, and will they be sufficient?


8.9.29 Ullen Wood No mention of proposed woodland planting on southern edge of wood meadow field. Is this necessary or can it be reduced to maximise CG area?

8.9.29 Barrow Wake Env Masterplan appears to show tree planting on SSSI CG at northern end of Barrow Wake unit.

8.9.35 Barrow Wake Loss of 0.7ha of CG within SSSI. Do we have any info on condition of grassland? Env Masterplan appears to show tree planting on remaining area (8.9.29)

8.9.61 Whole scheme

Reference made to reptile translocation habitat within scheme. Where will this be and is it proposed as limestone grassland? Proposal should be clear that reptile habitat and (botanically) good condition limestone grassland are not compatible and need to be clearly marked on the Environment Masterplan

8.9.73 Whole scheme Annex D EMP will include details of management and monitoring of created habitats. This is relevant to all species groups and should include target condition/structure.

8.9.97 Whole scheme

Enhancement section is weak especially in relation to calcareous grassland. There is no justification for the locations of grassland creation. Also, no discussion of how this maximises opportunities generally or the potential (untaken) opportunities to increase the habitat around the SSSI and link to existing Priority Habitats as part of the NRN. Justifications referencing the NRN would strengthen the case for enhancements.

8.10.13 Barrow Wake "the extent of impacted habitat is small and will not affect the integrity of the SSSI". How has this conclusion been reached? E.g. % of lost habitat in relation to SSSI area

8.10.14 Barrow Wake

The paragraph states that degradation due to dust etc will be mitigated by best-practice techniques which will be detailed in the EMP. With mitigation in place the integrity will be maintained. What are the best practice techniques and how effective are they? How can a conclusion be made that there will be no effects when the mitigation has not been given?

8.10.05 - 13 Barrow Wake and Crickley Hill SSSI

There is no discussion on the increased severance of the SSSI units. HE should acknowledge the potential impact on the SSSI and provide justification that there will be no adverse effects.

Table 8-17 Whole scheme

What is the viability (and likely success) of creating habitats within 200m of road where NOx levels exceed critical and levels and loads? According to the Air Quality chapter the levels across the scheme are almost double the critical loads for grassland and woodland habitats.

8.10.32 Emma's Grove Suggests the section of Emma's Grove that will be lost is the oldest area and potentially qualifies as ancient woodland. No specific mitigation is given for the loss of this (potentially) irreplaceable habitat

8.10.43 Whole scheme Loss of irreplaceable veteran trees is a major adverse impact. What compensation is provided for their loss?

8.10.56 Whole scheme 0.5 ha of SI CG will be lost at the Cotswold Way crossing. 8.10.54 states that 1.83 ha will be lost in total. Where is the remaining area(s)?


8.10.57 Shab Hill

MG5 (neutral) topsoil will be used to create grassland elsewhere on scheme, potentially the Gloucs Way crossing. There are no mapped areas of neutral grassland creation in Fig 7.9 and Gloucs way is proposed to be limestone grassland. What is the evidence that translocating topsoil will be effective?

8.10.59-60 Whole scheme Is there soil pH and nutrient data that supports limestone and neutral grassland are viable in the areas proposed?

8.10.68 Whole scheme Loss of tufa and vegetation is assessed as large adverse effect, but compensation has not been developed.

8.10.95 Whole scheme

Loss of low (botanical) quality grassland and arable wintering and breeding bird habitat has not been addressed. There is a loss of 95ha of these habitats in the scheme (Table 8-17) with no mitigation or compensation. Additional limestone grassland will offset some losses but not fully. Potentially the effects will be much greater than suggested (i.e. slight adverse effect and not significant). This ties in with previous discussions about the impact assessment not being coherent. A reassessment of habitats based on their importance to species groups would resolve this.

8.10.123 Whole scheme Terrestrial invertebrates will also be affected by habitat degradation (dust pollution, etc.) during construction phase

8.10.170 Crickley Hill

No mention of potential effects and mitigation of increased visitor pressure from the Cotswold Way crossing into Crickley Hill. At WCH meeting on 29 Sept HE/Arup said this would be included in the ES but it has not been included here.

8.10.171 Crickley Hill No mention of NOx deposition on Crickley Hill Unit 3, except that the road will be moved away, and air quality will improve.

Table 2-2 Whole scheme Wildlife crossing points - what evidence is there that the crossing design/type will be beneficial for the target species?

Appendix 7.3 Crickley Hill

Arb reports classifies T171 and T172 as high value and to be retained. Gives recommended root protection zones. Beech potentially affected as RPZ is overlaps with existing road so will probably need to be excavated. Will these roots already be damaged? What mitigation will be used?

5.10.39 Crickley Hill With best practice construction phase dust effects will be minimal. No measures are proposed for Unit 3 at Crickley Hill therefore this cannot be assumed.

Figure 5-7 Barrow Wake & Crickley Hill SSSI Shows SSSI areas within construction dust zone map but measures have not been proposed to protect all these areas. Notably the CG in Unit 3.


3. Assessment of Alternatives

We have previously stated that in addition to the choice of (and conception of) a surface route, it is important that any alternatives involving a lower footprint of new road infrastructure, including in relation to number of lanes in new roads being proposed, and the design of road junctions, have been considered, and that the environmental merits of the scheme as currently conceived are made clear. However, the selection of alternatives for the A436 link road (para 3.6.5 Assessment of Alternatives chapter and appendix 3.2 Option 30 Alternatives Technical Note) and the assessment did not appear to consider that the selected Alternative 2 would be three carriageways wide for its whole length (one northbound, two southbound). This may not have influenced the choice of route, but the additional lane, described as a climbing lane to deal with the 8% gradient of part of the link route, adds to the overall width of the proposed highway corridor (5 + 3 = 8 lanes in total, plus cutting slopes). This is a significant width of landscape severance in the context of a nationally designated landscape - and at the very least suggests that robust mitigation measures are needed. 4. Environmental Assessment Methodology

The Trust made several comments in relation to assessment methodology in response to the Scoping Report in 2019, which we trust will be incorporated into the drafting of the Environmental Statement. For example, we noted that the focus in respect of cultural heritage was to treat it as an agglomeration of material assets, whereas attention must also be given to the wider intangible value of cultural heritage in a more holistic matter. We have also previously raised concerns about over-reliance on the Design Manual for Roads and Bridges (DMRB) in assessment criteria and methodology

5. Air Quality

Please refer to our 2019 Consultation response – our points remain the same. 6. Cultural Heritage When considering cultural heritage and historic environment, there is a concern regarding the piecemeal approach to assets, and the absence of a holistic landscape approach. The approach taken to date may be following the theoretical process, but with minimum baseline information, there is a concern regarding the justification for decisions being made. Within the industry, the approach being taken is considered outdated and not regarded as best practice, nor environmentally (Nature and Culture) sensitive practice and in this respect, considered a failure in delivering a ‘landscape-led’ scheme. Whilst the individual chapters follow established methodology the separation into individual themes with no overarching or interlinking analysis leads to a tendency to downgrade the ‘local’ (e.g. in Tables 6.3.1 and 6.4.4 of Chapter 6) that is after all the very warp and weft of our landscape. To act as an effective baseline understanding of significance it must be presented as an analysis of heritage assets as part of their historic landscape, rather than separately. The inter-relationship of historic land use and other aspects of the landscape, such as the


development of woodland and the management of trees that has led to significant mature and veteran specimens, has been missed. Alongside the DMRB approach there has to date been an absence of evaluation using Historic England methodology, breaking significance down into its values or interests. Similarly, the lack of settings assessments, connecting to these values or interests has been missing. As referenced in our 2019 response, there is still a lack of evidence concerning:

• a landscape-scale approach and the focus on individual assets outside of their landscape context;

• an assessment of historic landscape impacts; • an explanation of how the value of identified sites has been assessed information on

how undesignated sites of schedulable value have been identified (i.e. what criteria has been used)

• detailed information about heritage sites The statements on historic settlement and enclosures (Cultural Heritage 6.7.24, Landscape 7.5) downplay the extent to which the Escarpment enclosures are much earlier than those around the villages of the vale or the mostly post-1750 enclosures of the High Wold. Ridge and furrow is a rapidly diminishing resource which indicates a long history of pastoral use on these scarp edges, much more so than in the vale. There is frequent reference in Table 6.6 to the sense of hiddenness and discovery as a key element contributing to significance, which seems to be largely based on present-day circumstances. Whilst this may be true as one moves along the scarp, the images in the landscape chapter shows the clear inter-visibility of sites when seen from the vale. There has been a considerable amount of work on the archaeology of Iron Age and earlier landscapes and settlement in the vale and the Cotswolds in recent years, but it is by no means certain how the scarp-edge forts were experienced in relationship to each other and to burial and other ritual and settlement sites; they would probably have been more visible in the landscape than they are now, certainly when seen from the vale. It is also clear that whilst Crickley Hill exploited dramatic views westwards across the vale, views from it are otherwise far more intimate and constrained than from other sites such as Leckhampton Camp and the Iron Age ritual site to its east. Crickley Hill: The assessment of effects on its setting and significance is weak. For the Scheduled Monument of Crickley Hill (High Value) the preliminary magnitude of impact is noted as minor adverse, with a preliminary significance of effect of slight adverse. At this stage we believe that this underestimates the impact on setting. Based on our evaluation of impact we would place significance of effect at moderate. The assessment refers to views, although the road scheme would also change the setting in other ways, including noise and light pollution (from vehicles). It would also lead to a much greater severance of the ‘Neolithic bowl’ formed by Crickley Hill to the north and The Peak to the south. Table 6-6 refers to a wide range of modern intrusions that currently affect the setting of Crickley Hill, although it should be noted that the focus (as per GPA3) should be on whether additional change will further detract from or can enhance the significance of heritage assets. The table also refers to the “substantial contribution” that the setting of Crickley Hill makes to its significance, although this does not appear to be borne out in the predicted magnitude of impact (minor adverse) and significance of effect (slight adverse). Emma’s Grove: For the three bowl barrows known as Emma’s Grove barrows Scheduled Monument (High Value) the preliminary magnitude of impact is predicted as minor adverse,


with a preliminary significance of effect of moderate adverse. At this stage we believe this underestimates the impact on setting. Based on our evaluation of impact we would place significance of effect at moderate. It is also noted that traffic noise at Emma’s Grove may reduce once the scheme is constructed and operational, although the wider setting of this heritage asset would be adversely affected by a wide cutting with five carriageways of fast moving traffic, and associated light pollution. The Peak: It is stated as having formed a wider single complex with Crickley Hill camp (para 6.7.15) and is expressed as a non-designated asset of some note. It is possible that inter-visibility between Crickley Hill and the Peak (as sites used in the Neolithic) would have been important, with the landscape in between the sites forming the ‘Neolithic bowl’. The proposed road scheme could have a very pronounced effect on the landscape setting within which Crickley Hill and the Peak are experienced. The Peak does not appear to be assessed further in the report, other than in table 6-6 in the entry for Crickley Hill, where it is noted as a contemporary prehistoric site. There is a case for both Crickley Hill and the Peak to be considered as individual assets, and collectively; and for there to be a more comprehensive and holistic conclusion on cultural heritage impact. 7. Landscape and visual effects

The landscape chapter of the PEIR refers to the “deep section of road cutting across the escarpment and through Shab Hill, creating exposed rock faces to accommodate six lanes of traffic” (para. 7.8.9). It is presumed the six lanes being referred to are adjacent to Shab Hill (A417 dual carriageway plus slip roads). It should be noted that the new A417 would also encompass a climbing lane up to the Shab Hill junction, beyond which the route would have a rather expansive central reservation, almost suggesting a motorway-scale of highway. Added to this are the parallel roads including the three lanes of the A436 link road, which would result in an overall highway corridor of eight lanes in total for part of the route. It is questioned whether this extent of overall highway corridor is necessary or appropriate in an AONB context. The aim of the project is to upgrade this section of the A417 to a dual carriageway in a way that is sensitive to the AONB landscape. The Landscape and Visual chapter also suggests that there will be positive and negative impacts for the character areas but that for the AONB there will be permanent significant beneficial effects. However, it indicates that during construction activities there are likely to be significant adverse temporary effects for users of the Cotswold Way PRoW at Barrow Wake, Emma’s Grove and Crickley Hill. At year 15 the report concludes that there would be permanent significant adverse effects experienced for users of the Cotswold Way and the PRoW at Barrow wake and Crickley Hill. The summary’s conclusions seem to contradict the assertion that this is a landscape led approach. We have concerns about the level of harm and feel that efforts should be made to understand the impact in more detail in closer liaison with Chapter 6, including thorough analysis of the landscape and its heritage and natural assets in its historic setting, and where feasible mitigate against it. Photomontages showing the proposed designs from viewpoints 7, 8, 9, 10, 11, 12, 13, 14, 15, 16 and 23 will also be important in the detailed design stage where options are assessed. We refer to the following guidance documents to reinforce our concerns:

• The EU Directive and Regulations covering EIA make clear the need to 'deal with the interrelationships between topics. This raises the issue of how landscape interrelates with matters such as, for example, population, flora and fauna, and cultural heritage. Consequently, in the context of EIA, LVIA deals with both effects on the


landscape itself and effects on the visual amenity of people, as well as with possible interrelationships of these with other related topics.' GLVIA (2013) para 1.9. There has been no proper consideration of these interrelationships in the information provided, which is of great concern given the aim to promote a landscape-led scheme.

• DMRB LD 117 Landscape Design, Appendix A. Approach to landscape design - new roads - suggests that a whole design is made up of parts that include alignment and landform; planting, vegetation and soils; integration with rural landscapes; the road corridor and heritage. The current scheme or the supporting information does not demonstrate this 'whole design' approach that should be evident in a landscape-led scheme.

• DMRB CD 351 The design and appearance of highways structures, March 2020 suggests that: 'The design process of highway structures shall include an evaluation of all aspects that affect the aesthetic quality of the completed structure, its position in the landscape and its impact on social, cultural and heritage sensitivities within the community.’ (para 2.1) The guidance also refers to an Aesthetic Appraisal Document (AAD) which is the ‘means by which the key influences and decisions that shape the approach to aesthetics is recorded and agreed.’ (Para 3.1 Note). Please could Highways England provide the additional relevant information that should have been produced in developing the proposals for the proposed structures.

• There appears to be no account of the consideration of alternative schemes or components of the scheme (e.g. location of bridge crossings). GLVIA (2013) notes that the iterative design and assessment process can be helpful in providing evidence that such alternative sites and/or designs have been assessed in terms of their landscape and visual effects. It is therefore important to: record how the scheme has developed through throughout the life of the project; demonstrate how landscape and visual effects have been taken into account; show why some alternative options have been rejected on the basis of landscape and visual considerations.

• The Guidelines for Landscape and Visual Impact Assessment Third Edition (Landscape Institute and IEMA, 2013) states that 'photomontage is the most widespread and popular visualisation technique for illustrating changes in views and visual amenity' (para 8.18) and that 'where the scheme is not fully developed visualisations must be based on clearly stated assumptions about how the development may appear' (para 8.22, bullet point 5). Photomontages or at least wireframes must be provided in order to enable consultees to understand the basis on which the judgements included in the Landscape and Visual Impact Assessment (LVIA) have been made and therefore be able to challenge those judgements where necessary.

• Para 7.9.6 suggests that new woodland and planting would be described in a LEMP (Landscape and Ecological Management Plan). We would wish to review this document when available.

8. Biodiversity

We are pleased to see that there is much more information within the appendices for this PEIR compared with the 2019 Consultation, but there are no comparisons between the


previous proposals and the current ones and therefore unable to comment on positives/negatives. There still needs to be an analysis of species and habitats to identify which ones are most important in this area, which are most fragmented and isolated, and which would benefit most from defragmentation. This is highly relevant to identify areas for connectivity and long-term resilience. Specifically relating to the content of the chapter, we have identified the following issues that we believe need addressing:

a) There are no lichen, bryophyte or fungi surveys, yet the descriptions of the SSSI on Crickley Hill mention their importance. Please can this information be provided.

b) Veteran trees - these are not clearly identified and are not described at all, nor related to where they are, or which species are associated with them.

c) We would question some of the habitat values. The Appendices on grassland surveys for example, highlight some as high value - both MG5 and CG3, but these seem to be underplayed in the main text and down-graded which then reduces the significance of loss. All the CG3 overgrazed pasture west of Air Balloon roundabout would also be lost but is not addressed in the main text along with the species rich MG5 at Shab Hill. The main text separates unimproved grasslands from semi-natural ones (the latter being less valued), but does not show how this is done, and the grasslands appendix does not use these terms, but gives the NVC and values each patch. If the Phase 1 habitat map is being used, then the detailed NVC surveys show it in the wrong locations and should not be used or should be updated. There should be consistency between the appendices and the main text (for example, the grasslands have been treated as a way of reducing value and therefore significance of effects). There is also an inconsistency of Latin names - the up to date ones in the appendix and old ones which are different in the text. A similar point relates to Emma's Grove; it is repeatedly stated that there is no historical evidence for it being ancient wood, but the ground flora evidently is. The ground flora is usually the most important element and indicates its ancient character. Stating there is no evidence for its ancient character is not correct.

d) There is no mention of rare arable plants. We would like to understand whether surveys have been carried out and what is the analysis of the data.

e) Birds are largely evaluated on their rarities (red listed etc), they should also be

evaluated for their assemblages in relation to the different habitats. Rarity is only one criterion for evaluation. The loss of bird habitat that is not replaced in any way like arable for skylarks, is not addressed.

f) There is no overall evaluation of the interrelationships between the habitats and

species at the landscape scale - the interdependencies, corridors and linkages - the landscape ecology. This is a major omission and is fundamental for the mitigation strategy, to deliver the “landscape-led” approach and for deciding on where best to place mitigation to maintain these inter-connectivities.


g) The invertebrate surveys do not relate to different habitats. For example, which surveys are associated with ancient woodland and the veteran trees compared with the grasslands or other habitats. Therefore, which habitats might be lost with the loss of veteran trees and ancient woodland etc. Of those that might be lost, how mobile are they, could they find new habitats useful, can they reach them, are they dependent on dead wood etc. There needs to be further analysis and qualification for terrestrial invertebrates.

h) The section on severance needs to be more scientific. An analysis of species and

their relative mobility and ability to get across the widened road is needed to see which would be affected most. Some plant seeds for example are dispersed by ants, some by wind - these are totally different in terms of being able to reach severed habitats. Which ones would be affected? This would help evaluate whether severance is significant or not for the high value sites area around the SSSI at Crickley Hill/ Barrow Wake.

i) There is dependency for the mitigation on habitat creation using seed or re-using

soils with their plant remains and seed banks to create new grasslands particularly. The success of this is not considered and needs to be. Research has shown that calcareous grassland soils do not contain a seedbank that reflects the species on the surface, so saving soils and seed banks will not produce the required quality or type of grassland communities. Furthermore, there would be a loss of seed bank during the period when soils are piled before re-use. Most seed is in the top 4cms or so, stripping the whole topsoil (even if it is shallow), will dilute this seed bank. More of the seed bank might be representative of the neutral grasslands (the MG5), but the dilution would be more as the soils here would be deeper. It is essential to translocate the high value calcareous and neutral grasslands as large turves (which is best practice) in advance of the works - this would give the best result if they cannot be avoided. The same point applies to woodland creation - planting locally native and suitable trees and shrubs, does not create a woodland (for example, what about the ground flora, fungi and fauna that an ancient woodland supports). To create a woodland is a natural and gradual process over decades or longer. When considering woodland creation within this scheme, it must not be planted as dense plantations (which is often the norm) as this excludes ground flora and glades to establish. Appropriate consideration must be given to habitat creation for woodlands and grasslands and we would welcome discussions along with other key stakeholders in ensuring the right approach is taken.

j) It would be good to understand how the scheme has attempted to avoid the best

habitats. To what extent have high value habitats been avoided. If the changed scheme design has helped this, it should be described as part of the mitigation hierarchy.

k) There is no analysis or evaluation regarding the Gloucester Way bridge and how successful it will be and for which species. To be useful ecologically it needs to be much wider as we have expressed in Q1b.

l) With the detailed information on the vegetation NVC (Appendix 8.4) it is evident that the field north of Shab Hill is high value grassland and not the semi-improved grassland shown on the Phase 1 habitat map. It is concerning that potentially, the Gloucester Way bridge and all the planting associated with it would destroy this field (as well as being dissected by the new dual carriageway). This MG5 grassland is


shown as high value in the grassland appendix 8.4. It has a good range of species, including pyramidal orchids (typical of limestone grassland in the area). MG5 grassland is a lowland hay meadow/pasture community that is now rare nationally, and all examples are important. This is underplayed in the PEIR and there is no balancing analysis about its loss compared with any gains (for recreation and possibly landscape) of replacing what would be left of it with woodland planting (which will not have any good ecological value for a long time). The loss of the remainder of this grassland needs to be avoided, but if that is not possible, then to minimise its loss through design of the road to minimise land take in this section, and then translocate the section lost to the road to an immediately adjacent place to ensure the grassland area remained.

m) BATS: Only one of the issues raised in the last consultation has been addressed in

that we now have details of the bat surveys. However, the frequent use of the term "standard mitigation" implies it works. For bats (and many other species), evidence is frequently lacking or even shows it does not work. For example, alternative roosts are more likely to fail than succeed and when they are used, it is by fewer bats. This still has not been addressed. Similarly, overpasses/underpasses are only likely to be effective if constructed along the right lines in the right places. We have little detail as yet, so unable to make sound judgements, but what is being presented to date, however good the survey work leading up to a mitigation plan, effective mitigation must be provided to appropriate crossing structures on bat flight paths that will be severed by the new road. If the mitigation is inadequate, the scheme fails. There are still concerns about methods, reporting and interpretation, whilst issues related to scientific objectivity are also questioned. However, the following questions relate to key points regarding mitigation and we would welcome a response; • What evidence does Highways England have to show that the proposed

replacement roosts will be effective? • What evidence does Highways England have that the crossing point structures

will be effective in terms of location and design? • If success is uncertain, how will Highways England evaluate it, and what is Plan

B in the event of failure?

9. Geology and soils

The proposal still does not consider or address the importance of geology. It does consider the impact on the SSSI, however, there is no consideration given of the opportunities for geology and geological conservation. These are threefold;

1. An unprecedented opportunity for recording of temporary sections and sampling during the construction phase.

2. The retention of permanent geological sections as part of the design of the scheme improving and extending existing exposures, particularly in the lower part of the stratigraphy (we would anticipate that most of the retained exposures would have restricted access but consideration should be given to design of exposures where safer access can be provided).


3. Provision of interpretation of the geology from viewpoints overlooking and crossing the road. A point here is that the 'effects' seem to be considered around identifying potential negative effects and then dealing with these. This is missing a real opportunity for the geology. There is an effect which is MAJOR - potentially one of the largest excavations in the classic inferior oolite sequence with a real opportunity to record, learn more and retain more.

10. Material Assets and waste As previously stated, the significant scale of the road scheme is likely to result in considerable excavation works, and a vast amount of material and waste arisings. We would advocate careful scheme design to reduce such arisings, as well as their responsible management and disposal. The retention of excavated material within the red line area may help to reduce the need for disposal elsewhere, and this could form part of the landscape mitigation works (including landscape bunds). However, it is important that any retained and repurposed material is used in a manner that is appropriate in respect of visual amenities (including being profiled in a way that is sympathetic with the surrounding contours) and in respect of landscape character and geographical interests. It should also avoid damaging locations that are sensitive from an ecological or archaeological point of view. 11. Noise and vibration

The impact during operation from key locations that have heritage significance is important. To date residential locations are noted within the textural assessments but not the key heritage locations. The noise level changes at locations such as Crickley Hill, Emma’s Grove and Barrow Wake, and from Leckhampton Camp, should be considered as part of the assessment on setting. The ability to reduce noise will be critical through the next design phase, focusing on issues such as different road surfaces, retaining walls, vegetation, earth banking and speed restrictions. The degree of operational noise intrusion is likely to be a significant change to setting for visitors to the heritage assets. As previously stated, the assessment of noise effects should also consider any potential tree felling (for example on the southern escarpment of Crickley Hill) that may be deemed necessary to construct the proposed road scheme. It would also take time for new planting (which may have a noise ameliorating effect) to become established. We would also want a greater commitment from Highways England to the use of low noise road surfacing within this AONB context, and greater assurance on the implications of the road scheme on the noise profile at Crickley Hill. 12. Population and human health As previously stated, we consider that the effects of the proposed road scheme on the visitors to Crickley Hill, and their experience thereof, should be taken into consideration. Crickley Hill (both National Trust and GWT land) contributes to the health and wellbeing of the people who visit, whether they are local residents or visitors from further afield. It offers them the opportunity to get outdoors and close to nature and appreciate some great views across the Cotswolds landscape and beyond. In addition, the ability of people to gain access Crickley Hill during construction and operation of the scheme also needs careful consideration.


13. Road drainage and the water environment

We will defer to the Environment Agency and other key stakeholders regarding this section 14. Climate We refer to our 2019 consultation response, in that the extent to which the proposed highway solution to the A417 Missing Link could contribute to climate change and the extent to which it is futureproofed to withstand the effects of climate change, are important considerations.


Annex A: A417 Briefing Note for the Access Bridges Authors: Cotswolds Conservation Board, Gloucestershire Wildlife Trust, National Trust Date of Issue: October 2020

A417 Missing Link Project Briefing Note for the Access Bridges

Date of Issue: October 2020

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Contents

1 Table of Contents 1 Introduction .......................................................................................................................................... 3

1.1 Cotswolds Conservation Board .................................................................................................................................... 3 1.2 Gloucestershire Wildlife Trust ....................................................................................................................................... 3 1.3 National Trust ................................................................................................................................................................ 3 1.4 Scope of the application .............................................................................................................................................. 4 1.5 Options Development ................................................................................................................................................... 4 1.6 Information provided by Highways England ............................................................................................................. 4 1.7 Design outcomes ............................................................................................................................................................ 5

2 Environmental factors and evidence base to inform the design process ......................................... 5 2.1 Commitment to aesthetics ........................................................................................................................................... 5 2.2 Community/Stakeholder engagement ........................................................................................................................ 5 2.3 Understanding of sensitivity of context in the landscape .......................................................................................... 5 2.4 Cost and aesthetics ....................................................................................................................................................... 6 2.5 Sustainability ................................................................................................................................................................. 7 2.6 Future management of the bridges ............................................................................................................................. 7

3 Approach to the design ........................................................................................................................ 7 3.1 The big picture ............................................................................................................................................................... 7 3.2 Coordination of disciplines within the design process ............................................................................................. 10 3.3 Collaboration between all relevant disciplines ......................................................................................................... 10

4 The Parts ............................................................................................................................................. 10 4.1 Superstructure .............................................................................................................................................................. 10

4.1.1 Bridge deck depth ......................................................................................................................................................................... 10 4.1.2 Bridge deck width ......................................................................................................................................................................... 10 4.1.3 Bridge deck length. ....................................................................................................................................................................... 10

4.2 Substructure ................................................................................................................................................................. 10 4.2.1 Piers ............................................................................................................................................................................................... 10 4.2.2 Abutments..................................................................................................................................................................................... 10

4.3 Details ........................................................................................................................................................................... 10 4.3.1 Surfaces and weathering. ............................................................................................................................................................ 10 4.3.2 Joints .............................................................................................................................................................................................. 10 4.3.3 Parapets ........................................................................................................................................................................................ 10 4.3.4 Drainage ....................................................................................................................................................................................... 10 4.3.5 Lighting columns and other deck furniture ............................................................................................................................... 10 4.3.6 Light and shade ............................................................................................................................................................................ 10 4.3.7 Colour and tone ........................................................................................................................................................................... 10

4.4 Design Outcome objectives ......................................................................................................................................... 10 4.4.1 Connectivity .................................................................................................................................................................................. 10 4.4.2 Proportion and integration of structure scale within the landscape ...................................................................................... 11 4.4.3 Options for contrast/harmony with surrounding environment ............................................................................................... 11 4.4.4 Proportions of spans/length and height .................................................................................................................................... 11 4.4.5 Symmetry/rhythm/line/order of principal elements ................................................................................................................. 11 4.4.6 Materials and finishes ................................................................................................................................................................... 11 4.4.7 Parapets and other elements that contribute to rhythm ......................................................................................................... 11 4.4.8 Lighting and signage – ................................................................................................................................................................ 12 4.4.9 Managing the effects of water and weathering ........................................................................................................................ 12 4.4.10 Structure curtilage .................................................................................................................................................................. 12 4.4.11 Viewpoints from and to the structure – key thoughts ........................................................................................................ 12

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1 Introduction

The purpose of this document is to set out what our expectations are as environmental stakeholders, regarding Highways England’s A417 road scheme access bridges and crossings. Ultimately our role is to comment upon those designs. The report focuses on four bridges at Emma’s Grove, Shab Hill crossing and the Cowley/Stockwell crossings, proposed by the ‘A417 Missing Link Project’, and uses Highways England’s Aesthetic Appraisal Document methodology. Its aim is to explore the opportunities presented by the scheme, find common ground between the requirement for the road, limit the negative impacts, and mitigate where this is not possible. The following organisations have been involved in this collaborative document: 1.1 Cotswolds Conservation Board The Cotswolds National Landscape is a designated Area of Outstanding Natural Beauty, looked after by the team at the Cotswolds Conservation Board, in partnership with a number of other organisations. The Cotswolds Conservation Board is an independent statutory body that works to conserve and enhance the natural beauty of the Cotswolds AONB; to increase understanding and enjoyment of its special qualities; and to foster the social and economic well-being of local communities. It was established by Parliamentary Order in 2004 and is one of only two Conservation Boards in the country, the other being the Chilterns. 1.2 Gloucestershire Wildlife Trust The Gloucestershire Wildlife Trust (GWT) is the largest wildlife charity focused on Gloucestershire. It was founded in 1961 by Sir Peter Scott, currently has 28,000 members, manages over 1000ha of land as nature reserves, and plays an integral role advising on nature’s recovery in the county. The Trust has a vision where each year there is more wildlife, more wild places and more people with connection to the natural world. The vision is achieved by:

• Creating bigger, better more connected places where people and wildlife can thrive. • Inspiring more people to appreciate and take action for nature in towns and the countryside. • Leading on natural solutions and protect our wildlife and wild places in Gloucestershire.

GWT is managed by a Board of Trustees who provide overall direction for the development of the Trust. The work of the Trust is carried out through staff and volunteers. GWT is a member of the Royal Society of Wildlife Trusts, the umbrella organisation which campaigns at a UK level. 1.3 National Trust The National Trust is a charity that works to preserve and protect historic places and spaces ‘forever, for everyone’. Founded in 1895, The National Trust played a large part in securing the preservation of country houses. Equally important has been their undertaking to preserve the settings of buildings and the landscapes of England, Wales and Northern Ireland. The National Trust looks after over 610,000 acres of land in its care. The National Trust is represented in each property by a General Manager whose team is responsible for the running of Mansions, built properties, gardens and parkland and areas of countryside and coast in accordance with the Trust’s policies and aims. Each property is supported by a

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regional consultancy team that offers the property advice on conservation, construction, design, curation, archaeology and planning. The projects undertaken by each property are governed by a Project Board. 1.4 Scope of the application The purpose of this document is to present our joint understanding and expectations for the four bridges, noted above, proposed by the ‘A417 Missing Link Project’, using Highways England’s Aesthetic Appraisal Document methodology. The four bridges are: Emma’s Grove crossing, Shab Hill crossing and the Cowley/Stockwell crossings. 1.5 Options Development The design process will be an iterative one, with multiple initial options which are then tested and reviewed with respect to the chapter headings noted within the PEIR over the construction and operation phases. Effects, both positive and negative, will need to be balanced with the practical requirements of the structures and costs. The production of summarised reports setting out this analysis and review is in the scope of this commission. Ultimately, the bridges are only economically feasible if their value is equal to or higher than their cost. The value of a bridge is the sum of several components—including its functional value, social value, and aesthetic value. 1.6 Information provided by Highways England The table below outlines key baseline documents which have been received to date and which are fundamental to considered design development, methodology, ensuring that landscape impact is minimised.

Title / Description Author Year A417 Missing Link – Preliminary Environmental Information Report Key chapters include: Landscape and visual, Cultural heritage and Biodiversity NOTE – this covers the project as a whole but is not focused on the four bridges specifically. Refinement is required to understand how the baseline information relates to the sites. The draft PEIR does not include Technical information that is key to design development and impact assessment. Highways England 09/19

The Preliminary Environmental Information Report from September 2019 identifies Further Works required, with respect to each chapter heading. Before the designs for the access bridges are finalised, they will need to be reviewed and checked with respect to the additional baseline information gathered. The key objectives for the design outcome should be understood and defined through a multi-disciplinary design and review process. The primary design focus is to minimise the impact and maximise gains in the landscape, setting of key heritage assets and biodiversity whilst at the same time providing key physical linkages for pedestrians, cyclists, horse riders and the NT’s Belted Galloway cattle. This should be based on a whole landscape approach that brings together and analyses a full understanding of how this landscape and its wider setting has functioned and has delivered ecosystem services over time and how these can be sustained and enhanced in the future.

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1.7 Design outcomes The following aspects (which come from CD351 – the design and appearance of highways structures) should be in focus when designing: 1) proportion and integration of structures (in terms of their scale) within the landscape 2) options for contrast/harmony with surrounding environment 3) proportions of spans/length and height; 4) symmetry/rhythm/line/order of principal elements; 5) materials and finishes, including road surfaces which will have a profound impact visually and in terms of noise levels; 6) parapets and other elements that contribute to rhythm; 7) lighting and signage; 8) managing the effects of water and weathering; 9) structure curtilage; 10) viewpoints from and to the structure and how they have changed; 11) potential for developing a design language amongst structures along route. 12) Potential for design to contribute to scheme mitigation/enhancement.

2 Environmental factors and evidence base to inform the design

process 2.1 Commitment to aesthetics

Title / Description Author Year Design Principles – achieving good design in buildings and landscapes. National Trust Sept 19

2.2 Community/Stakeholder engagement Community: Cotswold Planning authority, User groups including rambler clubs. Statutory stakeholders: Gloucestershire Wildlife Trust, Cotswold Conservation Board, National Trust, Natural England, Environmental Agency, Historic England, Gloucestershire County Council, Cotswolds District Council, Tewkesbury District Council and adjoining Parish councils 2.3 Understanding of sensitivity of context in the landscape The following reports provide further baseline information: 1) function;

Title / Description Author Year Active Design: Planning for health and wellbeing through sport and physical activity Sport England 2015

2) adjacent land use and infrastructure features; 3) the presence of other highway structures (either adjacent to or along route);

Title / Description Author Year Design Manual for Road and Bridges, Vol 10 Standards for Highways 2004

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4) geotechnical and geological characteristics; Title / Description Author Year Crickley Hill and Barrow Wake SSSI – Reasons for Designating the SSSI Natural England 2004 Crickley Hill and Barrow Wake SSSI – Our Views About Management (VAM) of the SSSI Natural England 2004

5) character of landscape or built environment; Title / Description Author Year

Cotswolds Landscape Strategy and Guidelines Cotswolds Conservation Board 2016 LCT 1: Escarpment Cotswolds Conservation Board 2016 LCT 3: Rolling Hills and Valleys Cotswolds Conservation Board 2016 LCT 7: High Wold Cotswolds Conservation Board 2016

6) ecology/biodiversity; Title / Description Author Year Gloucestershire LNP Natural Capital Maps Gloucestershire LNP Barrow Wake grassland condition assessment Gloucestershire Wildlife Trust 2017 Crickley Hill grassland condition assessment Gloucestershire Wildlife Trust 2019 Nature Networks Evidence Handbook Natural England 2020 Building Partnership for Nature’s Recovery Natural England 2020 Gloucestershire Nature Recovery Network (NRN) Gloucestershire Wildlife Trust 2020 Crickley Hill and Barrow Wake SSSI – Reasons for Designating the SSSI Natural England 2004 Crickley Hill and Barrow Wake SSSI – Our Views About Management (VAM) of the SSSI Natural England 2004 Making Space for Nature – The Lawton Report DEFRA 2010 Crickley Hill Biological Survey Report NT 2015 Veteran Tree survey report – NT Land NT 2020 Saproxylic invertebrate report – NT Land NT 2020

7) views of or in the case of bridges, from the structure; Title / Description Author Year

LA 107 Landscape and Visual Effects Highways England 2020 Guidelines for Landscape Visual Impact Assessment (GLVIA3) Landscape Institute 2013

9) community values and objectives.

Title / Description Author Year

LA 106 Cultural Heritage Assessment Highways England 2020 The LNP natural capital baseline maps will be available shortly and should be referred to. 2.4 Cost and aesthetics At the time of writing there is no defined budget for the construction of this project. The budget will inevitably have a significant impact on the scope for variation in design, from more standard solutions.

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2.5 Sustainability To be considered with: 1) understanding of historic landscape and respect for heritage; 2) improved amenity for local communities; 3) connectivity of communities; 4) understanding of the natural and historic environment and habitat/network resilience; 5) accommodation of inspection and maintenance; 6) longevity in terms of flexibility for future adaptation. 2.6 Future management of the bridges This should be brought into design development as well as by considering long term relationships and funding. Long term funding is obviously a consideration here. This is particularly true in the context of Shab Hill where whatever landscape is created will grow, develop and change over time. Designing structures and various planting schemes that have this long-term commitment in sight will be important and be subject to the impacts of climate change.

3 Approach to the design 3.1 The big picture We need a bold approach, in which the ’same old’ and rather compartmented ways of addressing schemes and layering the significance of the landscapes around them is changed. We need a clear emphasis on:

• the inter-relationship of human and natural factors - the key legacy of this is the inter-visibility of prehistoric ritual and settlement/ defensive sites on the higher land (including the long views west), the medieval assarted scarp edge with its multi-species field boundaries, post-medieval and post-1750 adapted and (on the High Wolds) transformed agricultural landscapes (the latter being a significant negative change to the ecosystem) and when looking into the valley the impact of transport/ aeronautical (Brockworth, roads, M5), industrial and residential infrastructure: modern transport has brought massive disruption to this area, inhibiting the movement of and acting as a constraint on the ability of species to adapt and flourish

• changing uses and perceptions of the landscape, based on using and further developing the

conservation values approach; this could be supplemented by consideration of how this landscape has delivered benefits (ecosystem services) to people and habitats over time, how it functions now, through identifying the issues/ factors that present risks and threats (climate, poor connectivity, limited understanding of the landscape etc) and how these services can be enhanced in the future.

There needs to be an integrated whole-landscape approach that is clearly communicated; this must include consideration of how non-designated and non-priority habitats that get low gradings in the EIA process have been created and changed within patterns of changing land use - vital for identifying and communicating opportunities for enhancement.

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A clear understanding of the context within which the structure sits, that can influence the designer's aesthetic response, should be developed and recorded. These will include:

1. topography 2. the historic character and function of the landscape and its relationship to heritage assets 3. ecology/biodiversity and their relationship to historic, current and future land use; 4. required function; 5. adjacent land use and infrastructure features; 6. the presence of other highway structures (either adjacent to or along the route); 7. geotechnical and geological characteristics; 8. views of or in the case of bridges, from the structure, and their wider and dynamic and historic

and habitat context; 9. community values and objectives.

The design process should not start with any preconceptions about the final solution. The key objectives for the design outcome should be developed and defined through a multi-disciplinary review process, focusing on aspects such as:

1. integration of structure scale within the landscape; 2. proportions of spans and height; 3. symmetry/rhythm; 4. potential for developing a family of structures along a route.

Wildlife bridge/crossing design

• Wildlife bridges/crossings should respond to ecological survey data and relevant published scientific research and impact assessments.

• Detailed bridge/crossing design should be evidenced based and follow best practice guidelines. They should be designed for the ecological features (i.e. species and habitats) effected by the scheme.

• The evidence base and best practice will depend on the species using the bridge/crossing; however, detailed design should consider the following: o Type. The type of crossing (bridge or underpass) should be based on the needs of all

important ecological features and not just protected species, as well as surrounding topography/landscape.

o Location. They should be sited to mitigate impacts and maximise benefits for features effected by the scheme (e.g. at important bat crossing points)

o Height. The crossing should be level with the ground on either side. This is especially important for bats.

o Connectivity. Crossings should connect similar habitats on either side of the crossing. o Width. Crossings should be sufficiently wide to provide an effective crossing. This should

consider habitat requirements, edge effects; noise, light and wind intrusion from the road. o Habitat type. Habitats on, and adjoining the crossing, should be suitable for ecological

species using the crossing as well as dispersal and migration abilities of threatened species. Where the crossing is providing mitigation for multiple species, with competing habitat needs (e.g. woodland and grassland), it should be sufficiently wide to accommodate both habitat types.

o Habitat age and structure. Where a dynamic mosaic of habitat is created (either on or adjoining the crossing) it should be sufficiently mature before road construction begins.

o Habitat management. There should be a management plan to maintain habitats adjoining, and on, the crossing in the long-term (e.g. cutting and removing grassland arisings, scrub

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management, etc). o Lighting. The crossing should be lit appropriately for the features using it. This is likely to

mean no lighting and ideally should be designed to allow effective low-intervention management.

o Screening. Sufficiently high screening should be included on both sides to reduce the effects of light and noise.

o Monitoring and evaluation programme. A fully funded (and ring-fenced) long-term programme should be planned to evaluate the efficacy of the crossings and inform future designs.

Design thoughts with respect to the locations Emma’s Grove crossing

- We are in agreement that this crossing is now in the right location and will provide safer access for users of the Cotswold Way National Trail and better links to other trails. At just 5m width, thought will need to be given to final design to avoid conflict between the different user groups (including disabled users) for walkers, cyclists, horse-riders and periodic movement of cattle. It is also important to give consideration to how, in particular, horse-riders and cyclists approach and leave the crossing to join existing bridleways and therefore minimise damage to priority habitats and wildlife by going ‘off piste’. The structure’s aesthetics is also very important as the bridge will, for many, feel like the gateway to the Cotswolds National Landscape. We wish to highlight that this bridge provides no ecological connectivity, and therefore, increased fragmentation of the SSSI caused by widening of the road will need to be mitigated in another way.

Shab Hill crossing

- - Should be a mosaic, primarily of calcareous grassland but with hedgerows along each length to

disperse wind and low-density scattered scrub/trees to provide functional connectivity for bats - woodland to the west side of the carriageway is a small isolated component of secondary

woodland, so expanding and connecting this to the woodland on the east should not be prioritised over expanding and connecting grassland habitats via the crossing.

- Based on the current wider land use the only way to potentially provide functional connectivity is for the bridge to act as a core stepping stone, which means ideally it will need a habitat corridor of 50m+ in width

- An effective corridor width is related to the distance from core areas, a narrower bridge may be sufficient if stepping stone areas of calcareous grassland (above the minimum viable patch size) are created both 350m west and 500 m north.

- Even with the stepping stones, a minimum undisturbed habitat corridor of at least 25m width is still needed over the Shab Hill crossing to provide functional connectivity.

- Evidence that small grassland verges on main highways benefiting invertebrates and grassland plant has been questioned by recent research.

- There must not be a barrier of woodland between the bridge and Crickley Hill to the north or Barrow Wake to the west. A corridor of open habitat should be maintained in both directions.

- The bridge needs to be designed and ‘landscaped’ in such a way that it helps to minimise the adverse landscape and visual effects of the road (e.g. through appropriate hedge / tree planting on the bridge helping to screen the road for receptors on the bridge and on nearby public rights of way / access land, etc.).

Cowley Crossing & Stockwell crossing

- Any greening features are good but not a strong preference for habitat type. - Needs to provide woodland connectivity between the two core areas identified in the NRN

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- Same point applies as above regarding appropriate hedge / tree planting to help screen the road for receptors on the crossings and the approach to the crossings.

3.2 Coordination of disciplines within the design process To be decided upon in discussion with Highways England 3.3 Collaboration between all relevant disciplines To be decided upon in discussion with Highways England

4 The Parts 4.1 Superstructure Once the function of the bridge is determined fully, the form of the bridge whether girder, arch, cable-stayed or suspension can be designed to satisfy its given function. As the function of the bridge in relation to specific user groups such as pedestrians, cattle, horses and agricultural vehicles has not been fully determined, together with predicted numbers it is not possible to comment on the specifics of design. This information is fundamental when developing designs and will have a significant impact on how well the structure sits within its landscape context. Sections 4.1.1 – 4.3.7 below can only be considered once a fully detailed specification of what the functional requirements of the bridge are has been developed. This design brief can only be commissioned when this information has been provided. Their form should be underlined with clear explanations of whether there is scope for change. 4.1.1 Bridge deck depth 4.1.2 Bridge deck width 4.1.3 Bridge deck length. 4.2 Substructure 4.2.1 Piers 4.2.2 Abutments 4.3 Details 4.3.1 Surfaces and weathering. 4.3.2 Joints 4.3.3 Parapets 4.3.4 Drainage 4.3.5 Lighting columns and other deck furniture 4.3.6 Light and shade 4.3.7 Colour and tone

4.4 Design Outcome objectives 4.4.1 Connectivity The Emma’s Grove bridge will provide essential connectivity for the visitors to Crickley Hill and Barrow Wake and the Cotswold Way, the NT’s Belted Galloway cattle and colleagues and contractors who manage the landscape. The Shab Hill, Cowley and Stockwell over bridges will also provide the necessary connectivity between local communities across the wider Cotswolds landscape

https://www.sciencedirect.com/topics/engineering/bridge-girder

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4.4.2 Proportion and integration of structure scale within the landscape The ultimate objective of the bridge designs is to produce a safe, elegant, functional and contextual bridges that satisfy all functionality requirements, at a cost that is acceptable. The design must be natural, simple, original, and harmonious with its surroundings. Aesthetics should not be an additional consideration in the design but an integral part. Both the structural configuration and the aesthetics of the bridges must be considered together during the conceptual design stage. With this in mind there are two options for the design of the bridge in terms of visual representation. One solution is that the bridges hide within the landscape by reflecting natural context such as curves, form, materials and textures. The alternative option to this is for the designs to act in absolute contraposition with their surroundings and context and become stand-alone pieces of architecture and engineered design. 4.4.3 Options for contrast/harmony with surrounding environment In general, aesthetics is about proportion, balance, and harmony. People have historically been immersed in nature most of the time and are accustomed to natures simplicity. In order to arrive at the most sensitive structure, the best method is simplifying the structures as far as feasible and not to over engineer. 4.4.4 Proportions of spans/length and height To be determined by the structural and functional requirements 4.4.5 Symmetry/rhythm/line/order of principal elements To be determined by structural and functional requirements 4.4.6 Materials and finishes The design of the bridges should be in line with Cotswolds Conservation Board Guidance, specifically the Cotswolds AONB Landscape Strategy and Guidelines. The Landscape Strategy and Guidelines provides a set of guidelines for each Landscape Character Type (LCT), with the relevant LCTs being LCT 2 (Escarpment), LCT 7 (High Wold) and LCT 8 (High Wold Valley). The guidelines for LCT 2 and LCT 7 have a section on ‘major road construction and improvement schemes’ (Sections 2.7 and 7.11 respectively). The guidelines for all three LCTs also have a section on ‘road upgrading and improvements’ (Sections 2.8, 7.12 and 8.10 respectively). Theses sections don not specifically refer to bridges. However, from these guidelines, the most relevant recommendations relating to bridges would appear to be: Refer to DMRB Vol 10 for general environmental design guidance. Conserve the rural character of the local road network. Promote use of design and materials appropriate to local character. Produce guidance on design and suitable materials. Overall, the bridges should play their part in conserving or enhancing the natural beauty of the Cotswolds National Landscape, including the local landscape character.

The Shabb Hill bridge provides the most scope to minimise the landscape and visual impacts of the highway scheme and maximise the environmental benefits. In landscape terms, the Shabb Hill structure should help to ameliorate the landscape and visual impacts of the highway cutting, for example by ‘knitting together’ the two sides of the cutting and providing ‘landscape scale’ connectivity. 4.4.7 Parapets and other elements that contribute to rhythm To be determined with respect to user needs.

https://www.sciencedirect.com/topics/engineering/structural-configuration

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4.4.8 Lighting and signage – To be determined. It should be minimised and directioned to limit light pollution. 4.4.9 Managing the effects of water and weathering To be determined from information supplied by HE. 4.4.10 Structure curtilage To be determined. This will significantly influence the degree to which landscaping can mitigate. Clarity is required. 4.4.11 Viewpoints from and to the structure – key thoughts The visual impact (and perception / experience) of the bridges for people using the local public rights of way, including the bridge crossings, and visiting local viewpoints is a more important consideration than the visual impact / perception / experience for people using the road. The visual impact (and perception / experience) for people using the nationally significant rights of way (such as the Cotswold Way National Trail) and visiting national significant heritage assets (such as Crickley Hill hillfort), would be particularly important, followed by regionally significant rights of way and viewpoints such as the Gloucestershire Way and Crickley Hill, respectively. This prioritisation is consistent with the value allocated to different types of visual receptors in Landscape and Visual Impact Assessments. The Cotswold Way crossing, through good design, could make it clear to road users coming up the escarpment that they are entering the nationally important landscape of the Cotswolds.

Documents

10th November 2020 Your ref: TR010056/S42 A417 Missing