[email protected] Direct line: +44 (0) 07771 ... · Chairman: Tim Parker Director-General: Hilary McGrady Regional Director: Rebecca Burton Regional Chair: Doug Hulyer

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

[email protected] Direct line: +44 (0) 07771 673976 6th November 2019 Your ref.: A417 Missing Link Public Consultation Sept. ‘19 Our ref: 20191106 A417 Stat.Consultation 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 statutory consultation undertaken by Highways England in accordance to Section 48 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 and as a major conservation organisation responsible for safeguarding the nation’s natural and historic assets. 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). It is a nationally important site for archaeology (including an Iron Age hill fort, which is a Scheduled Monument, the first battle site in the country with evidence of human activity going back to 4000 BC). The calcareous grassland on both sides of the Cotswold scarp is extremely rich in wild plants, which in turn support a large variety of invertebrates, butterflies, moths, bees, snails and other protected species including adders, bats and many species of birds. The amount of fungi found in the wooded areas of Crickely Hill (including the woodland that runs down to the edge of the current A417) – over 600 varieties – puts the site in the top six in the whole country and of huge biological importance alongside a large number of veteran

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trees on the Ancient Tree Inventory. The significance of this site for its geology and ecology means it is a designated Site of Special Scientific Interest (SSSI) which must not be under estimated. Whilst actively used and enjoyed by the surrounding population with over 190,000 visitors per year, Crickley Hill will be directly affected by the proposed road scheme not only along the land ownership boundary, but also access to the site during the construction period which will have a detrimental impact to visitors, wildlife and vulnerable habitats. In response to the current 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. We do however note that – 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 designation, and to avoid compromising the purposes of the designation and for projects to be “designed sensitively” (para’s 5.153 and 5.154). In light of the above, we consider that it is essential that the proposed highway scheme is a genuinely “landscape-led” solution, and we support the emphasis on this in the agreed vision statement. We also agree with 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. From our perspective, 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 Environtment Bill and impact of climate change. We strongly advocate the need for a sensitively designed scheme that is respectful to the landscape it sits within. As things stand, whilst we appreciate the work undertaken by Highways England and its consultants to progress the scheme and take into account relevant constraints and opportunities, we consider that more needs to be done for the scheme to be genuinely landscape-led, respecting its AONB context, and mitigating and enhancing the natural (and historic) environments. We look forward to working with Highways England in coming months to further develop the scheme design in advance of its formal submission to the Planning Inspectorate in Spring 2020. 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 186th November 2019

National Trust - A417 Missing Link Statutory Public Consultation Response

November 2019 Question 1: Do you have any comments on our proposed route from the Brockworth bypass to Shab Hill Junction?

Landscape and heritage The proposed new A417 would involve excavating a cutting of significant width and depth through the Cotswold escarpment, which would have significant landscape impacts (more so than a tunnel solution) and require substantial mitigation that must equal the significance of the Cotswolds Area of Outstanding Natural Beauty (AONB) designation. The proposed route must adhere to the policies set out to meet the challenge of climate change, conserving and enhancing both the natural and historic environment stipulated in the revised February 2019 National Planning Policy Framework (NPPF). At this time, the National Trust believes that this road scheme significantly challenges the integrity of the Cotswolds. This particular section of the route will have significant visual and settings impact from Crickley Hill and Barrow Wake and will be visually damaging for the Neolithic landscape – a triangular connection between the Peak, Emma’s Grove and Crickley Hill and therefore sensitive re-landscaping of the Neolithic bowl will be paramount to reduce the visual impact of the scarring created by the new A417, the removal of the existing tree line, the damaging impact to habitats, light and noise pollution from the increased vehicular usage and the impact of the retaining walls on the aquifers and the water courses downstream. Geological features The proposed dual carriageway cut in along the base of Crickley Hill will be cutting through the geological features that have given Crickley Hill its Site of Special Scientific Interest (SSSI) designation. It will be important that particular attention is made to recover and conserve exposures of the geological features that constitute elements of the SSSI designation, but also to uncover and appropriately conserve other geological features. Any new exposures created must reflect geological interest - no soils, no walling, nothing to obscure the strata. This would equally be relevant for the eastern section of the scheme too. Over time, these exposures would be naturally (but sparsely) colonised by plants but maintain their geological interest for many years. At this stage, the design and visual appearance of the retaining walls requires further examination through this section of the route. The banks should not be even and smooth but designed to fit in with ideas of natural geomorphological variation, thus providing diversity of shape, over deepening to give marshy or wet hollows with variable floors and banks. The same applies to other balancing ponds elsewhere on the scheme. Biodiversity Opportunities along this section must be maximised to create species-rich limestone grassland and scrub mosaics on the road cuttings. We would want to understand and


discuss how the slopes of the embankments and general grasslands within the red line boundary are to be managed going forward. It is not currently clear how access would be achieved for grassland management along the verges or abutting land. Lessons learnt from other schemes should be used to inform the sustainable management as an integral part of the creation and maintenance of the limestone grassland characteristic of the Cotswolds AONB. The consultation plan shows landscaping in the 'armpit' of the wood east of the A436 roundabout as part woodland and part calcareous grassland. The new woodland shown next to the existing ancient semi-natural wood is a positive proposal, but it should be allowed to establish by natural regeneration as there is a good wood adjacent (shown as semi-improved grassland on the Phase 1 habitat map). The current proposed Shab Hill junction will have a significant footprint in the landscape. Indeed, the scheme from the new roundabout near Air Balloon to Shab Hill, including the A436 link road (Alternative 2), involves a significant amount of new highway infrastructure in a sensitive landscape context. Significant mitigation will be expected here to reduce the impact of light and noise pollution and consideration must be made to provide better access, both public access and ecological access routes across this new infrastructure than is currently being proposed. With the proposed new infrastructure, we consider that more effort must be made to provide habitat and landscape re-connectivity. For example, there are two balancing ponds shown in the circles at Shab Hill of the dumbbell-like junction. The shapes of these - their banks and the water areas - are shown as standard engineering drawings - this is an opportunity to be creative and tie in better with the lie of the land. Currently, the grassland here would be isolated and not linked to any other new areas or existing grassland. The grassland is also shown with groups of trees - it would be better to have a scrubby edge to the woodland and keep the grassland open for ease of management. Topsoil will also need to be removed for grassland and woodland establishment unless the grassland is good enough merely to be enhanced. Question 2: Do you have any comments on our proposed green bridge? We consider that connecting the landscape on either side of the proposed road cutting, by providing a green or land bridge (or bridges), is a crucial part of the scheme, given that a surface route is being progressed through an environmentally sensitive setting. The green bridge or bridges should provide connectively for people and wildlife, be sympathetic to local geological interests, and integrate with the local landscape and take into account wider visual amenities. Within the PEI, the green bridge is heavily promoted in the landscape and visual chapter and helps the scheme appear favourable in some respects and further emphasises the importance of the green bridge as an essential integral element to the scheme. However, at present, we do not consider that the green bridge, as indicated in the consultation plans and video flythrough, is fit for purpose if it is to provide landscape connectivity, connecting a SSSI landscape whilst providing access for people and is not wide enough to deliver the necessary mitigation and enhancement required as part of the scheme. As it stands it is best characterised as a pedestrian bridge, that whilst provides safe passage for people to cross over the A417 between Crickley Hill and Barrow Wake, does not provide the necessary eco-system connectivity for the habitats on either side of the


bridge. It currently would have a detrimental impact to the SSSI, impact the Scrubbs and would require additional management for National Trust and GWT to protect the sensitive sites across Crickley Hill so that no additional desire lines are created, but instead Public Rights of Ways are integrated into the existing access routes. When considering the form and function of a bridge in this location, the most important factors are the ecology and geology. The aim of the proposed bridge is to reconnect the SSSI, allowing species to move across the landscape and providing access for people. A green bridge in this location will not only support Lawton1 report’s vision by “enhancing connections between, or join up sites, either through physical corridors or through stepping stones” but will have the potential to:

• Maintain, restore or enhance ecological connectivity • Provide habitat enhancement and reduce habitat fragmentation • Reduce species mortality from collisions • Maintain, restore or enhance historical links (Crickley Hill Iron-Age Hill fort, Emma’s

Grove and the Peak in the immediate area) • Maintain, restore or enhance access and recreational links • Maintain, restore or enhance a connected landscape resource or feature • Reduce visual effects and fragmentation • Provide ecosystem services

However, research has proven that if a bridge of 50metres is designed for both people/wildlife – the conflicts from interaction will inevitably prevent wildlife from using the bridge and therefore fail in purpose. There are currently no true examples of green bridges categorized as a natural bridge within the UK that are delivering the ecosystem connectivity the National Trust, and others encourage Highways England to deliver here. Instead, we strongly advise (as we did in the Green Bridge paper submitted in July 2019 to Highways England) that Highways England looks at best practice globally. One example that stands out for ecosystem connectivity ethos is the Singapore Mandai Eco-link bridge (as shown on page 4) that connects the national park and represents the scale of ambition that Highways England should be designing for within the AONB and to connect the SSSI landscape. Other recognised green bridge examples can be found in the Netherlands and across the USA and Canada. This is a perfect opportunity for Highways England to design an internationally recognised green bridge that other countries refer to as an exemplar scheme and example of good practice - that enables both wildlife and human interaction to co-exist sustainably. Public access The green bridge as currently conceived appears to focus on public access and connectivity for people, which is an important part of the scheme vision and objectives. This includes connectivity for the Cotswold Way, which the green bridge would provide. However, whilst this is welcomed, the limited width of the green bridge, and its multi-use function, will mean that its effectiveness for ecological connectivity are considerably reduced.

1 ‘Making Space for Nature: A review of England’s Wildlife Sites and Ecological Network’ Report chaired by Professor Sir John Lawton, 2010


Example of eco-system connectivity: Singapore Mandai Eco-link bridge


Ecology There is currently insufficient information – including the results of ongoing surveys and which species the green bridge is designed to benefit – to comment in detail. More evidence is needed on the likely ecological effectiveness of the green bridge as currently conceived. The characteristic of the habitat on the approaches to the bridge also deserves as much attention as what is on the bridge. We would refer to our Green Bridge paper circulated to Highways England in July 2019, and make further comments below: • The key habitats which Crickley Hill/Barrow Wake are designated for, and which

support the most notable species, are calcareous grassland and dead wood. Therefore, a bridge designed to facilitate the connectivity of species which are associated with these habitats will have the greatest benefits to local area.

• To have dual function (people and wildlife) the green bridge needs to be a minimum of 80 metres wide in the centre, ideally much more, with clear zoning for people and wildlife

• Any smaller bridge is likely to have limited wildlife benefits, which would have to be supplemented by quite considerable investment in – and enhancement of – land surrounding the scheme (and outside of the current red line) for wildlife.

• As well as being wider overall, the green bridge should be wider at either end (with

fluted or slayed entrances), in order to help wildlife ‘find’ the corridor. It should be no less than 100m at the entrances on either side, with these flush with the existing habitats, and preferably 80m in centre. As suggested by Landscape Institute, this would achieve connections at a landscape/ecosystem level which is what we are looking for. If a major footpath is also included, this should be on one side only of the bridge and be additional to the minimal nature conservation width. The path should be screened from the habitat. Hedges/belts of scrub are edges that might be useful for bats, as well as screening people and keeping dogs (and children) on one side.

• Connectivity will be crucial, and a current concern is that the green bridge does not

appear to link similar habitats, which could potentially limit its effectiveness as a wildlife corridor. The wildlife habitats on the bridge will need to connect seamlessly into the landscape either side (even if it requires a lot of additional planting or reviewing the management of existing woodland).

• On the green bridge, there should be a focus on limestone grassland creation, allowing

for scrub and small trees, but not larger trees. Currently, there is little information of the vegetation that would on the bridge itself. A minimum soil requirement of 0.3m (probably more) for grassland (or 1.5-2m for trees) would be suggested but this also needs to be climate change proofed (so may need to be deeper to prevent habitats from drying out in droughts, similar to that experienced in 2018 and which are forecast to be more frequent in the future). If establishing grassland, it will need to be limestone base and limestone soil (not ex arable) on top with low nutrient levels suitable for creating limestone grassland and scattered scrub.

• A majority of both vertebrate and invertebrate animals are active at night, and the value

of the bridge as a dispersal route may be compromised by light from traffic. Currently, there is no information on any light or sound proofing built into the green bridge. When designing the bridge, screening on both sides from light and noise at least 1.5-2m high will be required and therefore the situation would be improved by a much wider green


bridge, and by having vegetation of different heights, including scrub. This will provide shade, and so dark shelters. There is evidence that some bats, for example, disperse along corridors of shade created hedgerows and woodland edges, as these are darker parts of the landscape and predation less of a risk.

• Linked to the above, further consideration should be given to the effects of the green

bridge (design and location) on Lesser Horseshoe Bats; it is not clear where they are hibernating, although they may be using existing fissures in the rock on Crickley Hill.

Geology Crickley Hill and Barrow Wake SSSI is notified for both its biodiversity and geodiversity. From a geodiversity perspective the SSSI exposes the Middle Jurassic Birdlip Limestone Formation (Lower Inferior Oolite) overlying the Lower Jurassic Lias Group.

Currently the upper part of the sequence is well exposed forming the prominent Crickley Hill escarpment. The lower part of the sequence, however, is less well exposed, being concealed by a build-up of scree and vegetation. The proposed road scheme – and the proposed green bridge – will dissect some significant geology, and the green bridge in its current preferred location may potentially conceal the more accessible area of the lower part of the sequence and therefore, permanently damage the geological interest of the SSSI. There needs to be more consideration – with the green bridge and more broadly - of how to avoid or mitigate adverse impacts, and wider consideration of the potential for new exposures. Should there still be residual damage to the geological SSSI, it is important that the ecological and other benefits that would be delivered by the green bridge would sufficiently outweigh such harm. Landscape and visual (and design) The proposed green bridge needs to respond to the scheme vision, which includes “conserving and enhancing the special character of the Cotswolds AONB”, and reconnecting not just ecology but also landscape, bringing about substantial benefits. The NPSNN emphasises that: “Visual appearance should be a key factor in considering the design of new infrastructure, as well as functionality, fitness for purpose, sustainability and cost”. It also advocates infrastructure that is “sensitive to place” and has an appearance that “demonstrates good aesthetics as far as possible”. Whilst the PEI Non-Technical Summary states: “The design of the proposed scheme will be developed to integrate the A417 into the existing surroundings, enhancing the local environment where possible”; it is not clear from the consultation documents that this would be the case with the green bridge. The proposed bridge structure – shown in the video flythrough – does not appear to integrate into the surroundings, nor successfully “reconnect” the landscape. From the road below, and from many external viewpoints, it could appear as an alien structure – a ‘lid’ supported by columns and elevated high above the road itself. This could mean that – rather than provide landscape and visual mitigation for the road scheme and its large cutting – it would add to the landscape harm. We would advocate that any bridge-like structure should be wider, it should better fit into the surrounding landscape, and it should be beautiful as well as functional. One way forward could be to explore a ‘green tunnel’ rather than a green bridge – a cut-and-cover


solution lower in the landscape, if sufficient (or alternative) provision could be made for public access across the road cutting. This type of solution should reduce the visual and noise impacts of traffic using this stretch of the proposed road, and could enhance the experience of crossing the road, as well as user’s enjoyment of the land on either side of the road. It could also help to accommodate some of the material arisings from the excavation works involved in the construction of the scheme. Therefore, we consider that a green bridge that provides stepping stone habitat connectivity and landscape scale eco-system connectivity is an important component of the overall scheme and could offer multiple benefits and a positive legacy for the future. Question 3: Do you have any comments on our proposed route from Shab Hill to Cowley Junction?

We would certainly question the raised height of the Shab Hill junction on the 'wold' landscape and that more assessment is required to lower the junction further, to reduce the visual impact of this junction in the landscape. Lighting must also be an absolute minimum along this section of the new infrastructure as light pollution will be created by road users at night. As in the section to Shab Hill, there are inconsistencies in the landscaping shown on the consultation drawing. The species-rich hedges shown on the phase 1 habitat map (PEI Figs, Vol 4) are also not shown on the consultation plans as linked up, replaced or in any way knitted back together. Just east of Shab Hill and down towards the Stockwell Farm overbridge, there are good patches of new calcareous grassland shown, but of peculiar shape on steep slopes with a balancing pond at the east end near Cowley Lane overbridge. More consideration is needed to connect those isolated and fragmented grasslands indicated as mitigation along this section of infrastructure to deliver that wider habitat and landscape connectivity. This above point applies to the repurposed A417 where there are hedges and belts of trees shown on the Phase 1 habitat map which are ignored in the consultation design with odd patches of grassland and trees unrelated to what is around them. We have consistently advocated the need that all bridges within this scheme must be of ‘greened’ structures to provide that ecological connectivity as well as functional vehicular access. The current overbridges at Cowley Lane and Stockwell Farm will be highly visible within the wider landscape and we would want to see further design work undertaken and refer to the bridges along the Weymouth relief road in Dorset as examples of good infrastructure design within calcareous (chalk) landscape. The overbridges in this scheme must not be engineering-led modified grey bridge structures. It really is important that the scheme design maximises opportunities to create species-rich limestone grassland and scrub mosaics on the road cuttings and that mitigation is considered within the whole area of the red line boundary and not to continually present the current tight, linear approach being proposed along the road verges. As it stands the design will currently fail in delivering habitat rich corridors of mitigation that are sustainable and that can re-connect the landscape. We would also question the need for the smaller roundabout at Cowley junction. This appears over engineered for a junction that is designed to provide access to Stockwell Farm


and Golden Heart Inn and connect into the local road network. We would ask Highways England to consider a smaller T-junction in this instance to reduce unnecessary land take. It would also be good to see the designs for the Cowley underpass – again, there are examples of well-designed structures (Weymouth relief road, Dorset) that we would wish to see explored that allows these bridges to fit seamlessly (and therefore less intrusively) into the landscape. Question 4: Do you have any comments on our proposal for Alternative 2 as the preferred A436 link road?

In the PEI report it states: “The proposed A436 link road would also include a climbing lane in the southern direction as the gradient climbs at 8%”. As a key stakeholder we have not previously been made aware that the A436 link road (Alternative 2) would be three lanes wide (which along with the new A417 would make the scheme 8 lanes wide along this stretch), significantly severing the landscape. We would want to understand why this is necessary and whether a wider link road in this location has been factored into the comparisons with Alternative 1 and Alternative 3? The above statement also contradicts PEI page 27, paragraph 3.4.5 which states: “The preferred link would be single carriageway…. This preferred solution would reduce impact on the landscape by ensuring that as much of the surrounding land as possible is left as is””. This apparent contradiction is of significant concern and we would wish to see further justification for the currently proposed design. Another issue is whether the link road and (the greater overall width of the scheme in the landscape in this location) would be visible from Crickley Hill. It would be good to understand whether this option is better or worse than Alternatives 1 and 3 in this respect. With the combination of Alternative 2 and the new dual carriageway in close proximity, we are also concerned on the impact that this severance of landscape will have on established habitats and established migratory routes in the vicinity. Careful consideration must be made for access points both for wildlife and non-motorised users and currently, we do not feel there has been sufficient consideration or evidence to fully understand the impact this section of infrastructure will have on the landscape. We are however, pleased to see tree planting mitigation being considered to extend into Ullenwood. The selection must include species with climate change resistance. In addition, this must not be considered sufficient provision for delivering biodiversity net gain in this scheme. To our knowledge, no assessments have yet been carried out to establish the significance of archaeology within this area and therefore the importance of the historic environment and connectivity with key heritage assets. Without full assessments, Alternative 2 should not be considered a fait accompli for the scheme design.

Question 5: Do you have any comments on our proposals for repurposing the existing A417?

Historic environment The repurposing of the existing A417 could meaningfully enhance the setting of Crickley Hill and Barrow Wake. The envisaged width of the repurposed carriageway and the physical way in which change takes place, to accommodate the new low-level use, will be central to


the extent of positive impact. The designs for repurposing the road must be informed by statements of heritage significance and settings assessments – informed by Historic England’s approaches to managing change, defined in their guidance documents. Natural environment The repurposed road provides an opportunity for an ecological link across the landscape. The potential area for habitat creation will be limited due to the narrow, linear nature of the old road and therefore opportunities for species-rich limestone grassland and scrub mosaics should be maximised and maintained in perpetuity. It would be helpful to understand how effectively this proposal delivers ecological benefits on the landscape scale. Maximising the opportunities here to re-connect the wider landscape and restoring habitat connectivity will be crucial to truly provide landscape connectivity and provide access for people to enjoy and explore this area of the Cotswolds AONB. We would however recommend that relevant lessons are learnt from other road scheme involving re-purposing former road routes. For example, the A3 Hindhead road 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 raises 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 top soil spoil and not taking sufficient measures to monitor and manage the healing process of habitats and grasslands along this escarpment. Other comments Regarding the actual carriage surface, when repurposing the road, we would want to discuss with Highways England the visual impact this will have in the landscape. 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. We would also want to understand in more detail the proposed sections that will provide access to residential dwellings and how those sections will be integrated sympathetically. We certainly welcome this element of the scheme as it provides opportunities in delivering environmental benefits and will improve the setting of the skyline and this section of the A417 will no longer be a visible scar at night. However, in isolation this again must not be considered satisfactory to meet the net gain requirements of this scheme. Question 6: Do you have anything you think we will need to consider as we develop our construction plans further?

We would like to emphasise the importance of delivering the agreed landscape-led vision, principles and objectives and that all necessary assessments must be carried out before any construction commences. A construction environmental management plan, along with a traffic management plan, must be in place and key stakeholders must have had an opportunity to feed into the drafting of these documents. It will be essential that ongoing monitoring of the impacts to all topics in the Environmental Impact Assessment is maintained throughout the construction works and that the current survey work provides a


comprehensive baseline. We will also need to understand what impact to the biodiversity of Crickley Hill and its SSSI designation construction works will have. Archaeological assessments will also need to be active throughout the construction period. There is still so much unknown about this historic environment and understanding the significance and importance between the heritage assets in the landscape. There will be huge archaeological interest along the scheme route and a great opportunity to understand human activity over the centuries. The level of archaeological interest must not be underestimated. With regards to construction compounds, in section 2.5.9 of the PEI, it refers to the locations of the proposed construction compounds with satellite compounds identified in 2.5.11. We would want to see a commitment from Highways England that every measure is taken to ensure that the impact of harm is mitigated (as these sites and access to these sites will have the capacity to inflict as much long-term ground, historic and natural environment and short-term visual and landscape damage as the proposed road works themselves). Mitigation must also be implemented at every stage of the construction process for protected species (and other wildlife) and phased to have the best opportunity of success in starting the gradual process of restoring and re-connecting the landscape within which the road scheme sits. Other considerations for mitigation include:

• Tree protection areas around retained trees within development red line • Measures to minimise soil loss during construction • Measures to prevent water course pollution during construction • Appropriate planning and use of excavated limestone and soil (limestone is a

valuable material in habitat recreation projects. It would be good to see this used on site where limestone grassland creation is proposed, as well consideration for how excess can be used by local partners for habitat creation projects)

• Noise impact of new roads is much overlooked as an ecological factor. Effects can be mitigated by using low-noise road surfaces and minimising the amount of reflective hard surfaces. Vegetation can help to mitigate as can scrub and woodland by absorbing sound, but grasslands provide the most benefit as they significantly reduce sound reflection which is a major content of noise pollution.

From a business impact perspective, maintaining good access to Crickley Hill will be paramount during the construction process and we would welcome early discussions with Highways England, alongside Gloucestershire Wildlife Trust who jointly own the site with us, to ensure every possible measure is implemented to maintain safe access for people to be able to visit the site during this period. Question 7: Do you have any comments on our PEI Report and other proposed mitigation measures?

Section 3 – Assessment of Alternatives It is particularly important in a nationally designated landscape to fully appraise all options. The National Policy Statement for National Networks (NPSNN) states: “The EIA Directive requires projects with significant environmental effects to include an outline of the main alternatives studied by the applicant and an indication of the main reasons for the applicant’s


choice, taking into account the environmental effects”. We would emphasise the reference to environmental effects. As we have stated before, the assessment of alternatives should include consideration of tunnel options (of the six scheme options referred to in the Scoping Report, four were tunnel options). A road scheme incorporating a tunnel would mean that part of the route is underground and hidden from view, thereby reducing the overall landscape – and noise – impacts of the new road. The highest scoring option on environmental terms was a tunnel option, and we believe that tunnel options would have met the objectives and vision for the scheme. It is therefore important to be clear on the reasons – including the environmental merits of each option – for a surface option being taken forward. It is also important to stress that whilst a surface option may initially appear preferable in terms of financial costs, for such a scheme to be acceptable in environmental terms within an AONB landscape, sensitive design and considerable mitigation is required. For example, the Trust has previously advocated for a cut-and-cover tunnel to be part of an otherwise surface scheme. Alternatively, it may still be possible for a substantive green or landscape bridge to contribute to the mitigation of landscape and visual impacts. We are not clear that in selecting a surface route, the costs of the necessary focus on design and mitigation were fully considered, and that they are currently factored into the scheme. Finally, 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. Section 4 – Environmental Assessment Methodology The Trust made a number of comments in relation to assessment methodology in response to the Scoping Report, which we trust have and will be considered as the Environmental Statement is being prepared. 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 also raised concerns about potential over-reliance on the Design Manual for Roads and Bridges (DMRB) in assessment criteria and methodology. Section 5 – Air Quality We have not had the opportunity to make a detailed assessment of the PEI Report in respect of air quality. However, the points we raised in our response to the Scoping report remain relevant and are repeated below:

• In this section, clear scope for ecological receptors in terms of the habitats and the

zone of influence is needed. The potential for mitigation measures to reduce any adverse impacts should also be fully considered.

• We would support the assessment of the effects of dust during construction and vehicle emissions during operation, including on ecological interests and visitors at Crickley Hill.

• There needs to be an assessment of nitrogen deposition from any increased traffic in operational phase on the ecological receptors – all limestone grassland plus any


ancient woodland within about 300m from the road as evidence demonstrates. Are these habitats already affected by level of nitrogen deposition exceeding thresholds? They are very sensitive to this in terms of increasing vigour of more competitive species and reductions or losses of less competitive species, which might include fungi as well as plants and the invertebrates that feed on them.

• The air quality objectives and limit values need to include the total nitrogen deposition

thresholds for different habitat types to which the limits apply. There is a difference between what is measured in the air and what is deposited on vegetation. Highways are suggesting doing this in 6.6.19/20 but the deep gully like gorge and the topography will have an effect on this too. This should not just be designated sites as suggested but priority habitats as well

• Human health receptors must include the visitors to Crickley Hill, not just residential

properties. Section 6 – Cultural Heritage The PEI Report at Section 6.0 sets out the approach taken to Cultural Heritage – using importance/magnitude of impact/significance of effect. The PEI references Historic England Guidance and the NPPF. We consider that the PEI should review heritage significance and setting using the methodology referred to in these documents – whereas as things stand, it doesn’t. To date there has been no heritage values or narrative based understanding of the asset or their setting. Highways England current DMRB-focused approach does not properly embrace a full and holistic understanding of the whole of all the values relevant to the historic environment in a landscape (rather than asset-based) context. The baseline information is therefore currently poor. Moving forward to the detailed design/mitigation phase a full and considered baseline understanding of context is essential and we consider it unsatisfactory that this data was not available to inform route selection. It was essential that this data was available to inform that stage, not to be generated as part of that process. The absence of the data regarding Zones of Theoretical Visibility (ZTVs), as well as noise, are notable and critical omissions in this section of the PEI. In addition, we consider that the DMRB assessment methodology is inadequate, with only a 1km corridor buffer from the boundary of the development. This means that the already heavily site-orientated assessment methodology is unable to assess properly the historic landscape impact of the proposals regardless of the lack of information at this stage. Furthermore, all non-designated heritage assets are afforded only a 300m buffer within which assessments of impact will be made, which conflicts with the acknowledgement within the document that some non-designated heritage assets are of schedulable quality and should therefore be treated as if they were designated. Para 6.6.1 in the PEI report states that: “Desk based historical research and consideration of non-designated assets had not been completed at the time of writing”. A full site survey-based understanding is required. This work must be progressed as a matter of urgency and should have been completed ahead of this stage. At para 6.12.6 under ‘Further work’ the report states that: “A detailed level of assessment on the cultural heritage impacts during construction and operation of the proposed scheme will be undertaken in accordance with the methodology set out in the DMRB”. As indicated above, we consider that the DMRB is not the correct approach.


The PEI also states that the proposed scheme would result in a “significant adverse effect” on the setting of various scheduled monuments including Crickley Hill camp. This conclusion is meant to have taken into account the implementation of mitigation measures, although it says that: “A programme of mitigation appropriate to the proposed scheme will be developed in consultation with Historic England and the County Archaeologist to reduce harm and to provide enhancements”. As one of the key stakeholders, we would like to understand the proposed programme of mitigation and how it might address the adverse effects. In terms of the potential adverse impacts apparent from the consultation proposals, the biggest impact of the scheme will be in the area between Emma’s Grove and the Cowley roundabout. Although affected by late Georgian and Victorian agricultural improvement, with enlarged and straightened-out fields, it has considerable time-depth in the context of what has been summarised above. Placing field boundaries, routeways and non-designated historic buildings within the scope of the EIA should not be considered as an obstacle, but as an opportunity to discover and interpret the story of this landscape. There needs to be greater emphasis on how the EIA can address ‘known questions’ in national and regional research frameworks as well as raise new questions that can be addressed through various forms of mitigation (i.e. recording the context of an integrated approach to landscape and the species, heritage assets etc within it) as the scheme moves into its construction phase Finally, there are clear overlaps between historic features and natural environment designations – especially Scheduled Monuments and SSSIs – which will enhance overall significance of some areas. The current piecemeal approach detracts from this additional overlay in terms of understanding significance and needs to be supplemented by a broader ‘landscape led’ holistic analysis. Section 7 – Landscape and Visual The proposed dual carriageway would cut through the escarpment at the western edge of the Cotswolds AONB. In this designated landscape context, national planning policy requires that “great weight” is given to landscape and scenic beauty. There is also a “strong presumption” against the building of new roads in designated landscapes such as AONBs, unless it can be shown “there are compelling reasons … and with any benefits outweighing the costs vary significantly” (NPSNN). The proposed A417, with two lanes westbound and three lanes eastbound, would be of considerable width, and it would be in a deep cutting. This would cause a significant landscape and visual impact (a large scar in the landscape). At present, despite the scheme being referred to as ‘landscape-led’, it may not meet the policy tests in NPSNN. Whereas the Cultural Heritage chapter of the PEI report acknowledges that the proposed scheme would have significant adverse effects on the setting of various scheduled monuments, the Landscape and Visual chapter indicates that the effects when constructing the road would only be temporary, and there would be a “mix” of effects during operation. This seems to underplay the adverse effects of a new 5-lane highway being built in a deep, wide cutting through an escarpment in an AONB. As already indicated, if a surface road is taken forward, significant landscape mitigation is likely to be needed. This does not currently appear to be built into the scheme and our impression is still that a standard approach to road scheme mitigation is being proposed which does not appear to fulfil its own landscape-led scheme vision and principles. For example, many of the proposed mitigation measures – whilst helpful – remain rather tight to the proposed dual carriageway itself, and we consider that there are additional opportunities


that could be afforded by working with the red line scheme boundary. This is a landscape scale intervention / development, so it requires a landscape scale approach to mitigation – including more woodland and limestone grassland. Whereas the indicated green bridge structure is likely to have an adverse landscape impact, there is an opportunity for it to be designed to provide landscape mitigation as well as benefits for people and wildlife. It could be the form of a substantial land link that is better integrated into the surrounding landscape and provides a key element of essential landscape scale connectivity. Overall, in order to address the likely significant adverse impacts on building a major new highway through an AONB, we consider that more robust landscape mitigation and enhancement is required. Turning more specifically to the sides of the road cutting, the visualisation appears to show large extents of constructed retaining walls, which would impose an alien or urban character on the area. It would be good to explore the potential to make greater use of the exposed geology (using natural stone benching) or slopes seeded with native calcareous grassland, although this would have to be balanced against any greater land-take involved. Whatever the case, we have concerns about the potential visual impacts of the cutting sides, and this needs to be carefully considered, with sensitive design and mitigation as appropriate. Finally, regarding lighting, the PEI report states: “It is currently assumed the proposed A417 would not have road lighting and would follow the “Dark-Skies” scheme”. As we have stated previously, it would be good to have a stronger commitment than this; or if there are small sections of the scheme that would be lit for safety reasons, this needs to be acknowledged within the Environmental Statement. Section 8 – Biodiversity At this stage it is difficult to provide detailed comments until the full survey results and mitigation are presented. We would however advocate a more science-based approach to ecological mitigation, as opposed to a ‘box-ticking’ methodology. It is also important for Highways England to include realistic assessment of the value of proposed mitigation tools in their proposals, and to build effective monitoring into their schemes, in order to demonstrate that the mitigation is effective. In section 8.9.26 we would wish to see more detail on the additional proposed habitat creation and the re-purposing of the old A417 at Barrow Wake will need to be done sensitively. Musk orchid populations are present very close to the road and could easily be lost. An honest, scientific appraisal of the effectiveness of proposed mitigation methods for getting wildlife safely across roads must be presented. Throughout this section there are explicit/implicit assumptions that lost habitat can be simply replaced, with no discussion of its quality relative to lost habitat or the time it takes to become 'good' habitat. We believe that this should be addressed. In addition, the frequent use of the term "standard mitigation" implies that it works. In many instances, for bats (and other species) the evidence is lacking or even demonstrates that it does not work. Alternative roosts are more likely to fail than succeed and when they are used, it is by fewer bats – this is currently not being taken into account. The amount of habitat creation – woodland, trees and grassland – is not significantly more than normal, whereas this is a substantive road scheme through a sensitive environmental context. The grassland shown is in small blocks and is fragmented from other blocks by the


planting. We would question how it will be managed in such circumstances – it would need late hay cutting and/or grazing to be of highest value. None of the grassland blocks seems to link to existing areas of grassland and therefore add to this or defragment it significantly. However, in a more positive vein, the new woodland does seem to join up with the existing block to the north-east of the Air Balloon roundabout, which is good. There 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 in relation to the landscaping shown on the consultation plans, which gives patches of woodland and grassland, but not always linked. Section 9 – Geology and Soils Geology There appears to be an increasing acknowledgement of the geological importance of landscape through which the road scheme would pass, although we consider that geology remains underplayed and undervalued. In the design of the road scheme, consideration needs to be given to the strati graphical (age) range and lateral variation in geology represented in the Crickley Hill and Barrow Wakes SSSI, and the public benefits that arise to ensuring this remains available for future study. This design should consider the retention and improvement of existing exposures or seeking suitable alternatives. In respect of additional geological enhancement, this should be more fully explored and strengthened as there are potentially significant opportunities including recording of and sampling from new (temporary) geological sections and the retention of permanent sections within the road design, as well as the opportunity to improve existing sections within the SSSI. Soils The PEI report refers to the Defra 2009 Code of Practice for the Sustainable use of Soils on Construction Sites on temporary land take (para. 9.8.4). This guidance, although labelled as for habitat creation as well as other uses, really does not cover habitat creation and the need for low fertility soils. Many of the fields are arable or improved grassland suggesting use of artificial fertilisers - these will not be needed for the creation of new woodland or grassland. We would therefore like to see a focus on the movement of topsoil and subsoil, to avoid or minimise any temporary and long-term impacts. Section 10 – Material Assets and Waste The significant scale of the road scheme and the size of the proposed cutting are 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 and the design of green bridges). 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.


Section 11 – Noise and Vibration As things stand, the wider Cotswolds AONB landscape is associated with relative tranquillity and quiet recreation, although road traffic noise is intrusive in a number of locations including currently at Crickley Hill. Despite indications in the PEI report that road traffic noise could reduce at Crickley following construction of the road scheme, we are concerned that the noise profile of a larger and busier road network could adversely affect visitors and wildlife. There may also be particular impacts during the construction stage. We consider that road surfaces and landscaping should all focus on limiting noise intrusion during construction and operation. At present, the consultation documents appear to contain contradictory messages regarding road surfacing, with the Non-Technical Summary saying that lower noise surfacing would be used “where practicable”, but para. 11.8.5 of the PEI Report stating that: “Low noise surface would be laid on all new and altered roads in the scheme”. We would 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. In addition, the assessment of noise effects should 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. Section 12 – Population and Human Health Briefly, 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. Section 13 – Road drainage and the Water Environment We will defer to the Environment Agency and other key stakeholders regarding this section, but we have several points we would nevertheless like to make. The proposed road scheme is likely to have a significant impact on drainage and the water environment, in particular due to the size of the cutting in the vicinity of the existing Air Balloon roundabout. It will be important to ensure that the drawdown of the water table (and its implications) are fully considered, whilst adequate drainage is also included in the proposals. We are concerned about the retaining walls for the road cutting, and the construction works to reduce the gradient of the dual carriageways at the base of Crickley Hill, because of the unknown impact it will have to the aquifers and hydrology in the area, in addition to the potential negative impacts to the water courses downstream (in particular Norman Brook and Hatherley Brook). Furthermore, para 13.4.38 of the PEI report states that “the interruption of flow [due to the cutting drainage system] may lead to a reduction or loss of water supply to abstractions, springs and streams and potential loss of habitat (which may be permanent)”. The likelihood


and implications of this should be fully understood. From an ecological and land management perspective, it could affect the water environment nearer the ground surface and alter ecological habitats and species, including those that form part of the SSSI designation. It could also affect trees adjacent to the road. This should therefore influence the assessment of effects on biodiversity and the natural environment, and landscape and visual effects. Finally, some of the proposed drainage basins are shown to be highly engineered regular oval basins, whilst some are shown as being more responsive to landform and scale of surrounding landscape features/character. The latter approach is essential and standardised approaches to water management adjacent to highways should be avoided. Section 14 – Climate Change 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. Effects on emissions The consultation documents firstly focuses on the effects on the climate of greenhouse gas (GHG) emissions arising from the proposed scheme. We note that the position of Highways England is as follows:

“The NPSNN states that it is very unlikely that the impacts of a road project would, in isolation, affect the ability of Government to meet its carbon reduction plans. In the ES, project emissions would be reported against the relevant carbon budget periods of the UK Government. This would demonstrate that the proposed scheme would not have a material impact on the ability of Government to meet its carbon reduction targets. Hence there is no likely significant effect on climate”.

However, we equally note that in 14.4.1 it states, “user carbon emissions are likely to increase as a result of the proposed scheme”. It should also be noted that the NPSNN is now some five years old, and recently there has been a much stronger emphasis on climate change and efforts to reduce greenhouse gas emissions. In addition to the Environment Bill, the UK Climate Change Risk Assessment 2017 report that was presented in January 2017 in pursuant to Section 56 of the Climate Change Act 2008 provides a five-year assessment of the risks and opportunities to climate change. From this, the National Adaptation Programme (2018-2023) report outlined necessary actions which we will want to see Highways England commit to implement in the scheme design, during construction and as a legacy. The Gloucestershire Local Nature Partnership have also drafted the Local Industrial Strategy 2019 which sets out a vision for the county to become “the greenest place to live and work in the UK”, and states that “we must ensure that our growth is not at the expense of our unique environment both locally, nationally and globally”. It also has an aim to “reduce our carbon emissions to net zero by 2050”. We therefore want to see a clearer statement from Highways England on how the greenhouse gas emissions arising from the A417 Missing Link could be accommodated within the Government’s carbon reduction plans. We also note that a detailed assessment of the “capital, operational and user carbon emissions” arising from the road scheme has


yet to be undertaken, and we would like to see this progressed (and the outcomes shared) as soon as possible. Finally, based on the road scheme progressing as planned, it will be important that all possible steps are taken to mitigate and reduce associated greenhouse gas emissions. Vulnerability to climate change The consultation documents also focus on the vulnerability of the proposed scheme to climate change and impacts relevant to climate change adaptation, assessed though a climate change resilience (CCR) assessment. Briefly, we consider it crucial that the vulnerability of the scheme is fully assessed, and that appropriate design and mitigation measures are incorporated to create resilient new infrastructure (including hard infrastructure and landscape works). As things stand, we consider that there needs to be stronger linkage to ecological effects, to ensure that the design of any mitigation, compensation and enhancement proposals for habitats, species and landscape, factors in the 2080 climate projections used in the Scoping Report. Question 8: Do you have any other comments you would like to make about our proposals?

Given that the recent Glover report is recommending that the Cotswolds AONB is designated a National Park and that the statutory powers of National Parks and AONBs should be strengthened, our assessment is that any development, including road improvement schemes will need to pass the tests posed by these recommendations which could be adopted by Government during the delivery of this scheme. One very firm recommendation is that National Landscapes (including National Parks and AONBs) should lead the way in reconnecting the landscape in nature recovery areas reaching out into the National Landscapes hinterland and to each other. This is critical in this case in terms of ambition, vision and its implementation. This also makes the generic aim to be landscape led more important and critical to the scheme’s success. It must be of the highest possible quality for the landscape. This puts greater emphasis and a more urgent interpretation on the landscape/ecological needs of the scheme for it to be considered landscape led. The current engineered design needs to fit better in the landscape from an ecological perspective. Our current position is that more work is needed to reduce the impact of the new infrastructure on the surrounding countryside if Option 30 is to deliver the landscape-led solution that has been proposed and that this special landscape deserves. Our primary concern is that the mitigation required to deliver a landscape-led solution will be omitted or reduced due to budgetary constraints and that ultimately financial costs to ensure a scheme is delivered below the £500million budget envelope will result in a standard engineered Highways England scheme that will be unacceptable.

Documents

[email protected] Direct line: +44 (0) 07771 ... · Chairman: Tim Parker Director-General: Hilary McGrady Regional Director: Rebecca Burton Regional Chair: Doug Hulyer