Highways Agency - Safe roads, Reliable journeys, Informed travellers

Related pages

• Summary
• 1 introduction
• 2 traffic, congestion and safety issues
• 3 geotechnical issues
• 4 environmental constraints
• 5 option development
• 6 options considered further
• 7 engineering comparison of options
• 8 economic comparison of options
• 9 environmental appraisal of options
• 10 waste management
• 11 public open day
• 12 responses from statutory and non-statutory consultees
• 13 conclusions
• 14 recommendations
• Environmental study findings
• Environmental study findings
• Environmental study findings
• Environmental study findings
• Environmental study findings

A417 Cowley to Brockworth Bypass Improvement

12 RESPONSES FROM STATUTORY AND NON-STATUTORY CONSULTEES

12.1 This chapter presents responses received from the environmental statutory consultees and key non-statutory bodies. Formal responses (where received) are provided in Appendix E.

Responses From Statutory Consultees

Countryside Agency

12.2 The Countryside Agency (CA) does not, at this stage, rule out any of the options being taken forward for further consideration. They do, however, have some concerns and have requested more information on certain issues. Their views are summarised below:

• Option 1 - The CA feel this is a short-term improvement and are concerned that this may lead on to further piecemeal improvements to improve capacity once its lifespan has been reached. There is concern about the landscape and visual impact of the offline section around Nettleton on the AONB and would like to see photomontages and more detailed drawings to show the likely impacts. They would also like to see a range of mitigation schemes being developed. This view also applies to Option 2. The CA feel that the introduction of traffic signals would disrupt the free flow nature of the existing roundabout at the Air Balloon and hence impact on adjacent properties i.e. noise and air quality as well as pedestrians and cyclists. The need for increased lighting and signage is also raised as a concern on this option and Option 2.
• Option 2 - In addition to the concerns noted under Option 1, the CA is concerned about the potential impact from the two additional lanes down Crickley Hill and would like to see more detailed drawings before commenting further. They feel that a two-up, two-down arrangement as under Option 1 should also be considered. With respect to the proposed free-flow junction at the Air Balloon, the CA would like to see more information on the likely structures e.g. embankments, retaining walls, landscaping etc.
• Option 3 - Again, the CA would like to see more information and detailed plans particularly for the portals. This would include photomontages. Another major concern for them is the potential impact of excavated material especially if it has to be stored on-site prior to disposal.

12.3 On a general note, the CA would like to see more details of the access arrangements for pedestrians, cyclists and other non-motorised users. They believe there is potential for significant gains.

12.4 Their final comment is on the potential impact of de-trunking the A40 and upgrading the A436 which, they believe, is likely to increase traffic at the Air Balloon junction. They have sought assurances that this has been taken into account as part of the current assessment.

English Nature

12.5 On a general note, English Nature highlight the proximity of SSSIs to the three options and the fact as a public body, the Highways Agency has a duty to take reasonable steps to further the conservation and enhancement of SSSI's when exercising their functions. They also note that as all the options could lead to loss or fragmentation of non-SSSI habitats and features. They would expect to see appropriate mitigation and habitat creation.

12.6 On the specific options, their comments are as follows:

• Option 1 - The boundary of the Crickley Hill SSSI comes very close to the road on Crickley Hill and includes some land owned by the Highways Agency. EN would require confirmation that any improvement works will not impact the SSSI at this point. They are pleased that at Barrow Wake, the new carriageway would deliberately avoid the eastern part of the SSSI by splitting the northbound and southbound carriageways (the existing road cuts through the SSSI). EN recommends that surveys for protected and declining species be undertaken as soon as possible within the appropriate season. With respect to the potential impacts on the water environment, EN would defer to the advice of the Environment Agency however, their main concern would be to ensure the supply of water to the Bushley Muzzard SSSI is not adversely affected.
• Option 2 - The comments on Option 1 apply. In addition, the need for new carriageways on Crickley Hill would need to ensure that there are no impacts on the SSSI and in particular, the rock face, which is an important geological feature.
• Option 3 - EN considers that the potential impacts from a tunnel on nature conservation would be less than for the other options but would expect full surveys and mitigation at the two portals. There remains the potential impact on the water environment. EN supports the EA's objection to the tunnel pending further research and modelling on the likely effect on groundwater. EN also highlight the potential for impacts on bats using caves and mines for hibernation. They would require a survey of bats and the likelihood of caves and mines along the proposed tunnel alignment.

English Heritage

12.7 English Heritage recognise the need for a long term improvement scheme on this stretch of the A417 and accept that any scheme is likely to have some environmental impact. They have no objection in principle to any of the three options being considered but do have some concerns. These are summarised below:

• The potential impact on the setting of Emma's Grove barrow as a result of Option 2. EH would need to see more detailed plans to be able to fully assess the likely impact.
• EH's final concern was that in their view the GOMMMS landscape assessment does not take adequate account of the potential impact on the historic landscape character e.g. field patterns, woodlands, ancient roadways and background settlements etc. They would like to see a more detailed assessment carried out during the next stage of scheme design.
• Potential problems associated with waste material and the size of compounds. Experience from other development schemes suggests that historic remains have sometimes been damaged or destroyed when contractors have cleared land for their compounds. EH would therefore wish to be made aware of the location of proposed compounds (for all schemes) so that checks can be made for known remains or potential for new finds.

12.8 EH are content with the assessment carried out to date and generally agree with the findings. From their perspective, a tunnel would have the least impact on historic resources by virtue of the fact that the majority of it will be well below ground.

Environment Agency

12.9 Throughout discussions held with the Environment Agency which have been based on the available information, they have expressed serious concerns over the potential impact of dewatering for the tunnel option on the Major and Minor Aquifers underlying the study area. They consider that a considerable amount of further investigation and detailed design would be required for them to reconsider the potential 'high risks' of a tunnel option.

12.10 They continue to maintain their objection to the tunnel option because of the potential impact on water resources and nature conservation interests.

12.11 A summary of their views on all of the options is given below.

• Option 1 - Springs that provided water to Witcombe Reservoir are important as the reservoir acts as a reserve drinking water supply for Gloucester and therefore impacts on these should be minimised. This option also provides a good opportunity for using Sustainable Urban Drainage Systems (SUDS) due to the high permeability of the ground. The EA asked that surveys of protected species such as the white clawed crayfish be undertaken at the appropriate time of year. Concern was expressed as to the potential impacts on Horsbere Brook and noted that surface water would need to be attenuated so as not to increase downstream flood risk during a 1% (1 in 100 year) flood event.
• Option 2 - Similar views to Option 1 were expressed.
• Option 3 - The main concern with this option is the potential impact on water resources and the waterfed SSSI at Brimpsfield. In particular, it was noted that the proposed tunnel alignment lies very close to the Total Catchment Boundary for the Baunton Source (Thames Region) and that there are at least 15 licensed abstractions within a 2km radius. Any change in the hydrogeological regime could potentially impact on these.

The Agency therefore objects to the tunnel pending further information on the short and long term impacts on:

• the natural hydrogeological regime, including changes in secondary permeability and flow paths through geotechnical excavations/borings;
• springs and streams (particularly those feeding SSSIs) and the subsequent impact on the headwaters of brooks and rivers;
• private and public licensed water supply abstractions; and
• domestic (unlicensed) abstractions.

12.12 In addition to the above issues, the EA have provided general guidance on various issues including the need for appropriate pollution control equipment to be provided and consent requirements for different works.

Responses from Non-Statutory Consultees

National Trust

12.13 The Trust is concerned not only with impacts on land owned by them but also on the wider environment and would seek to ensure there is an overall environmental benefit from 'doing something' as opposed to leaving things as they are. Their overall opinion is that all three options could be taken forward for more detailed design and assessment.

12.14 With respect to the individual options, their main comments are as follows:

• Option 1 - There are likely to be significant impacts around Nettleton from the new bypass and also at the Air Balloon and down Crickley Hill. However, they accept that some mitigation can be incorporated. They would be concerned if there was 'over-enthusiastic' use of signage and unnecessary lighting.
• Option 2 - They consider that this option will have more significant impacts, especially at Birdlip, Air Balloon and down Crickley Hill. It will have impacts on the views from Crickley Hill. They would like to see further justification for the additional lanes down Crickley Hill.
• Option 3 - The Trust supports the use of tunnels where there is a clear case for building them based on the environmental sensitivity of the area, however, they consider this to not necessarily be the best option because of other issues such as waste production and energy used. With regard to the AST, they do not agree with the Large Adverse score for landscape as it suggests a similar impact to Option 2 (it is not clear from their letter whether they believe the impact of the tunnel would be greater or lesser). They would also like to see a clearer statement on what environmental benefits could be achieved through reducing the remaining infrastructure i.e. the existing A417.

Gloucestershire Fire & Rescue Service

12.15 The general view of the fire and rescue service is that Options 1 and 2 would still have accident, fire and rescue issues whilst the tunnel option would be unacceptable. In order to provide adequate fire and rescue services a dedicated fire station would be necessary at the tunnel with rescue vehicles located at each end. They believed that this would add to their already stretched capabilities and that without Government funding they would be unable to provide and maintain such a dedicated service. Given the choice between a tunnel and leaving the road as it is, they would prefer the latter.

Gloucestershire Constabulary

12.16 Similar concerns to the fire and rescue service were raised. For options 1 and 2, they felt these had merits as they are 'open air' roads and as such could be policed using conventional methods and resources. However, they did have concerns about tight radius turns on the grade separated junction and were uneasy about the provision of additional lanes down Crickley Hill.

12.17 With regard to the tunnel option, they expressed serious concerns particularly over the need to provide a dedicated service in conjunction with the Fire and Rescue Service. Despite the reduction in gradient, they felt that breakdowns would still be common (particularly HGVs) and rescue and recovery services within the confines of a tunnel would be very difficult. The potential for a large number of vehicles to continue using the existing A417 instead of the tunnel due to perceived safety concerns by drivers was cited as another concern.

12.18 Finally, it was stated that unless Central Government provided funding up front for the maintenance of the service, then the burden on local taxpayers would likely outweigh the benefits. The tunnel would "become an immense 'millstone' around the necks of the emergency services, both financially and operationally."

Gloucestershire County Council (GCC)

12.19 Gloucestershire County Council have indicated support for all options to be taken forward for further consideration. They agree that a long term solution to the "Missing Link" is necessary but that any scheme must be deliverable.

12.20 They do have concerns about the effectiveness of Option 1 as it represents only a short term improvement. It also performs poorly on safety. GCC have expressed real concerns over the deliverability of a tunnel given the total cost of the scheme and the very low cost-benefit ratio. Other concerns relate to the potential impact of a tunnel on the Major Aquifer and the waterfed SSSI.

12.21 Option 2 is generally seen as a more deliverable long term solution although concerns have been raised over the potential visual impact of adding the two new lanes down Crickley Hill. GCC have asked if this option would remain viable if one lane were added down Crickley Hill (retaining the two lanes up) as in Option 1.

Cheltenham Borough Council (CBC)

12.22 CBC's views on the 3 options were similar to Gloucestershire County Council in supporting the need to consider all of them further.

Tewkesbury Borough Council (TBC)

12.23 TBC has resolved to support a tunnel option for this stretch of the A417. In the view of TBC officers, the current assessment reinforces their position in view of the comparative impacts on the local communities and the Cotswold landscape. They feel that Option 1 is of questionable value given the short time period predicted by which it would reach its design capacity. TBC are also concerned as to what evidence has been provided of the potential adverse impact of a tunnel on the aquifer as they understand this has been challenged by other parties. It is also noted that there is continued concern among TBC Members about the potential impact of proposals to de-trunk the A40 which is likely to direct additional traffic onto the A436 and down to the Air Balloon roundabout.

Cotswold District Council (CDC)

12.24 CDC strongly support a tunnel and see it as the only option to solve all the problems associated with this stretch of the A417. Whilst agreeing with a number of the key issues identified during this study, they have questioned whether or not the potential impacts would be as significant as suggested. Issues related to the potential impact on the Major Aquifer and the re-use/disposal of excavated material are considered by CDC to be relatively simple to resolve. The high construction cost of approximately £200 million is not considered to be a problem if the tunnel would ease congestion and improve safety on the A417.

Cotswold AONB Partnership

12.25 The AONB Partnership have highlighted concerns over the potential visual impact of any scheme and reiterated the need to maintain the integrity of the Cotswold AONB.

Parish Councils/Missing Link Action Group

12.26 Eleven local Parish Councils have formed a group known as the "Missing Link Action Group" to campaign for a tunnel. They see a tunnel as being the only viable solution. The Highways Agency and WSP have met the group on two occasions (November 2001 and March 2002) to discuss the potential options and concerns they have. One of their main concerns has been the problem of 'rat-running' through the villages by vehicles trying to avoid congestion at Nettleton and the Air Balloon. In their view, on-line options would not resolve this problem.