STAFFORDSHIRE COUNTY COUNCIL The Acquisition of Land Act 1981

Highways Act 1980

and

Compulsory Purchase (Inquiries Procedure) Rules 2007

Highways (Inquiries Procedure) Rules 1994

THE STAFFORDSHIRE COUNTY COUNCIL (A50 GROWTH CORRID OR –

WESTERN GRADE SEPARATED JUNCTION, UTTOXETER)

COMPULSORY PURCHASE ORDER 2014

and

THE STAFFORDSHIRE COUNTY COUNCIL (A50 GROWTH CORRID OR –

REALIGNMENT OF A522 UTTOXETER ROAD, UTTOXETER)

COMPULSORY PURCHASE ORDER 2014

and

THE STAFFORDSHIRE COUNTY COUNCIL (A50 GROWTH CORRID OR –

A522 WESTERN GRADE SEPARATED JUNCTION, UTTOXETER)

SIDE ROADS ORDER 2014

and

THE A50 TRUNK ROAD (UTTOXETER GROWTH CORRIDOR SLIP

ROADS) ORDER 20..

PROOF OF EVIDENCE OF

ANDREW NICHOLAS MASON

BSc. C.Eng. DMS

Dated: March 2015 FINAL

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1.0 Introduction

1.1 My name is Andrew Nicholas Mason. I am currently employed by

Amey as a Senior Project Manager within the Major Projects Team

working in a delivery partnership with Staffordshire County Council. I

have been an employee of Amey since October 2014 when

Staffordshire County Council’s design staff were transferred under

TUPE arrangements forming part of the partnership agreement under

Infrastructure+. I had been an employee of Staffordshire County

Council since 1983 prior to the forming of the partnership.

1.2 I am a Chartered Engineer and hold a Bachelor of Science Degree in

Civil Engineering and a Diploma in Management Studies.

1.3 I have in excess of 40 years’ experience in highways covering all

aspects of highway schemes from inception to construction completion.

Most recently I have been Project Manager on the i54 development site

in South Staffordshire; a project involving the construction of a new

grade separated junction on the M54 near Wolverhampton to form the

main site access to a new major investment site and strategic business

park (additional document 21). I’m currently leading a team of

Engineers and Professionals working on the two major schemes for the

A50 Growth Corridor (Projects A and B), around Uttoxeter.

1.4 On behalf of the County Council I have been involved in the A50

Growth Corridor Project A since December 2013 following the

Government announcement in the 2013 Autumn Statement and as

such I am fully aware of the back history of the proposal. I have been

involved in all aspects related to the Planning Application and

Approval, Compulsory Purchase Orders (the “CPOs”), Side Roads

Orders (the “SRO”), and Slip Roads Order (the “SLRO”) processes

together with the design for Project A (the “Junction Works”).

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1.5 The A50 (T) is part of a key strategic route running through the north

Midlands linking the M6 in the West to the M1 in the East (the “A50

Growth Corridor”); improvements to the A50(T) are required to alleviate

existing and predicted congestion, improve highway safety in the

Uttoxeter area, where over 37,000 vehicles use the A50(T) highway

daily, and to facilitate development along the A50 Growth Corridor.

1.6 The problems associated with the section of the A50(T) around

Uttoxeter are divided into two areas of concern. Firstly, to the West of

Uttoxeter, a project is required to provide improved access to the

A50(T) for business and housing developments, and to improve

highway safety (Project A). Secondly, congestion relief and improved

highway safety to the East of Uttoxeter (Project B).

1.7 The Statement of Case and my proof of evidence both refer to the

Compulsory Purchase Orders, Side Roads Order and Draft Slip Road

Order associated with Project A only. Further design work is required

for Project B which will require its own Planning Application,

Compulsory Purchase Order and other Highway Orders which will be

delivered under a separate construction contract at a later date. Whilst

Project A and Project B will bring complementary benefits, they are

separate and justifiable projects in their own right.

1.8 I have acquired a comprehensive understanding of the background to

the development of the Junction Works and the associated highway

works required.

1.9 I confirm that my evidence includes all facts relevant to the opinions I

have expressed.

1.10 I confirm that I have no conflicts of interest of any kind other than those

expressed in my evidence.

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2.0 Scope of Evidence

2.1 My evidence covers and explains the highway reasons for all the

Orders referred to in paragraph 1.4 above to enable the delivery of the

Junction Works. The Junction Works are later described fully in

section 4.0 of my Proof of Evidence and in paragraph 2.3 of the

Statement of Case.

2.2 This proof of evidence is structured as follows:

i. In section 3.0 I describe the CPO land and negotiations

undertaken;

ii. In section 4.0 I provide details of both the existing and proposed

highway networks (the Junction Works), with a summary of the

main environmental considerations and include details of any

impediments;

iii. In section 5.0 I identify the need for the CPO’s, the SRO and the

SLRO and summarise the Planning history and benefits and the

policy support;

iv. In section 6.0 I identify and respond to the highway related

objections to the CPO, SRO and SLRO;

v. In section 7.0 I summarise the Human Rights issues;

vi. In section 8.0 I provide a summary and conclusion; and

vii. Section 9.0 contains appendices to the above including the

additional documents referred to and Inquiry notice photographs

(appendix T) and location plan (appendix U).

3.0 Property and acquisitions

3.1 Legislative background

3.1.1 The proposals to improve the A50 (T) around Uttoxeter were

announced by the Chief Secretary (Rt. Hon. Danny Alexander MP) on

the 04 December 2013 as part of the updated National Infrastructure

Plan (NIP). This statement was also confirmed and reference made to

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the NIP on 05 December 2013 by Chancellor George Osborne in the

Autumn Statement.

Paragraph 3.10 of the NIP stated “the government will provide funding

to support improvements to the A50 around Uttoxeter starting no later

than 2015-16 (subject to statutory procedures) to support local growth,

jobs and housing; this project will be subject to the usual developer

contributions” (additional document 11).

3.1.2 The Junction Works were again identified as ‘committed’ within the

Department for Transport Road Investment Strategy: Overview (2014)

(additional document 12) and Department for Transport Road

Investment Strategy: Investment Plan (2014) (additional document 13)

to meet substantial growth in the Midlands in terms of housing and

industry. As such it is considered Government policy that the A50 be

improved.

3.1.3 The most recent iteration of Government Policy in Paragraph 2.23 of

the National Policy Statement for National Networks (additional

document 19) details that ‘the Government’s wider policy is to bring

forward improvements and enhancements to the existing Strategic

Road Network’ which shall include ‘junction improvements, new slip

roads and upgraded technology to address congestion and improve

performance and resilience at junctions, which are a major source of

congestion’.

3.1.4 The Highways Agency fully supports the A50 Growth Corridor Project A

proposals noting that ‘the project contributes towards performance

specification outcomes…encouraging economic growth; supporting the

smooth flow of traffic and making the network safer’ (appendix Q).

3.1.5 The Council recognises that the Compulsory Purchase Orders can only

be made if there is a compelling case in the public interest (as

paragraph 17 of the Memorandum to ODPM Circular 06/2004 refers –

additional document 2) which justifies the overriding of private rights in

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the land sought to be acquired. The Council considers that a

compelling case exists for the reasons set out in the Statement of Case

and as summarised in this proof of evidence. It also considers that it is

appropriate to confirm the Side Roads Order and make the Slip Roads

Order in order to carry out the Junction Works.

3.2 Description of the Order land

3.2.1 The land, interests over land, and new Rights proposed to be

compulsorily acquired under the CPOs (the “Order Land” ) relate to

land at and in the vicinity of Uttoxeter, adjacent to the existing junction

of the A50(T) and the A522 New Road.

3.2.2 The Council sealed The Staffordshire County Council (A50 Growth

Corridor – Western Grade Separated Junction, Uttoxeter) Compulsory

Purchase Order 2014 (CPO (A)) on 17 June 2014. A second Order,

the Staffordshire County Council (A50 Growth Corridor – Realignment

of the A522 Uttoxeter Road, Uttoxeter) Compulsory Purchase Order

2014 (CPO (B)) was subsequently made (in the circumstances

described in paragraph 1.9.4 of the Statement of Case) and sealed on

20 November 2014 to ensure that three small parcels of land omitted

from CPO (A) are acquired.

3.2.3 The Order Land is shown on Drawings Number CDX8609/CPO/01 and

CDX8610/CPO/01 (core document R appended to the Statement of

Case).

3.2.4 For the purpose of this proof of evidence where CPO(A) and CPO(B)

are referred to together they shall be collectively referred to as the

“CPOs”, and where the CPOs, SRO, and draft Slip Roads Order are

referred to together they shall be collectively referred to as the

“Orders”.

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3.2.5 The Order Land covers approximately 109,109m2 (10.9109 Hectares)

at and in the vicinity of the existing junction of the A50 (T) and the A522

New Road, Uttoxeter, Staffordshire. The Order Land is currently in a

number of different ownerships, and in general comprises the following:

a. Agricultural (grazing) land adjacent to and north of the A522

New Road being part of the property known as Parks Farm. This

area is broken into several plots running parallel with the A522

and ranges in width from 0 to 35 metres wide, being an average

width of some fifteen metres. This land is in several ownerships

all being within the same family. It is considered that the total

area of these plots (8237sq.m.) does not affect the property and

would not adversely affect the farming unit. Some of this land

currently forms part of an option to purchase for infrastructure

provision associated with the housing and business

development proposed by St. Modwen to the west of the A50(T).

The developer is fully supportive of the scheme, notes the

benefits of the proposals for the Junction Works and states “that

the proposed new A50 junction has the potential to assist in the

timely delivery of this important development” a copy of the letter

in support of the proposals is included as appendix A.

Objections, however, to the CPOs and SRO (appended as core

documents Q and Z to the Statement of Case), have been

lodged pending the satisfactory conclusion of the agreement of

accommodation works and suitable compensation (Plots 1, 3, 7,

9) (CPO (A));

b. The whole of the front garden of the residential property known

as Park View Farm. The Order will have a significant impact on

the property; however, during negotiations the Council has

indicated that they are willing to purchase the whole of the

property if it was so desired by the land owner (Plot 2) (CPO

(A));

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c. The right to enter and use a small area of land being part of the

property known as Parks Farm and forming an existing ditch

course collecting surface water drainage from the existing

highway and surrounding agricultural land. The right is for all

purposes in connection with re-grading, discharge of surface

water from the highway and future maintenance of the ditch

course (Plots 4, 5, 6) (CPO (A));

d. Areas of unregistered land forming parts of the existing

highways of the A50(T) and A522 and which will be the subject

of stopping up under the SRO. These areas would be retained

by the Council and used to mitigate the potential adverse effect

which the Junction Works will have on the existing flora, fauna

and ecology of the area (Plots 8, 12, 15, 16, 17) (CPO (A)) (Plot

2) (CPO (B));

e. A thin strip of agricultural (grazing) land adjacent to and north of

the existing A50(T) being part of the property known as Anfield

House. This area of land is relatively small and is at its

maximum only five metres wide. As such it is considered to not

have an adverse effect on the property or the farming unit (Plots

10, 14) (CPO (A));

f. Agricultural land bounded to the south and west by the A50 and

to the north and east by the A522. This area of land has limited

access arrangements and is currently overgrown and unused.

This land currently forms part of an option to purchase for

infrastructure in association with the housing and business

development proposed by St. Modwen (Plot 11) (CPO (A));

g. The right to enter and use a small area of land being part of the

property known as Anfield House and forming an existing ditch

course collecting surface water drainage from the existing

highway and surrounding agricultural land. The right is for all

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purposes in connection with re-grading, discharge of surface

water from the highway and future maintenance of the ditch

course (Plot 13) (CPO (A));

h. Part of the grounds being landscaped or existing car park of the

commercial property (restaurant) known as The Parks. The

Junction Works would result in the need for accommodation

works to relocate the existing access/exit and car parking

facilities; however, when completed the property would be far

more prominent from the roadside and as such the Junction

Works could enhance the existing business operations (Plot 18)

(CPO (A)) (Plot 3) (CPO (B));

i. Agricultural (grazing) land to the south of the A50(T) and west of

the A522 New Road being part of the property known as Parks

Farm. This land currently forms part of an option to purchase for

the housing and business development proposed by St.

Modwen (Plot 19) (CPO (A)) (Plot 1) (CPO (B));

j. A thin strip of agricultural (grazing land) land adjacent to and

south of the existing A50 (T) being part of the property known as

Norbut Farm. This area of land is relatively small and is at its

maximum only eight metres wide; as such it is considered to not

have an adverse effect on the property or the farming unit (Plot

20) (CPO (A));

k. Strips of land adjacent to and north of the A50(T) and adjacent

to and south of the A522 being part of the industrial land of the

JCB World Parts Centre. This land is currently landscaped and

as such the Junction Works would have little effect on the

operation of the existing factory. The Junction works would

assist in fully facilitating the development referred to in

paragraph 3.2.10(a) of the Statement of Case. The owner is

fully supportive of the Junction Works and states in a letter

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dated 30 May 2014 that “The A50 is a vital artery for JCB, both

for inbound parts supply and outbound machine dispatch”; a

copy of the letter is included as appendix I (Plots 21, 23, 25)

(CPO (A));

l. An area of land adjacent to and north of the A50(T) which is

unregistered, and situated within the strip of land described in

3.2.4(k) above. It currently forms part of the landscaped grounds

of the JCB factory (Plot 22) (CPO (A));

m. An area of land adjacent to and north of the existing A50 (T) and

south of the A522. This area of land has limited access

arrangements and currently appears to be unused and

overgrown (Plot 24) (CPO (A)).

3.2.6 As detailed above, the Order Land is predominantly in agricultural use;

although several existing tracks and private accesses and two gardens

to a dwelling and grounds to a commercial property are affected. The

Orders will enable the construction of the Junction Works, to serve

residential and business developments and to improve accessibility

and safety on the existing A50(T) and A522. The Council needs to

acquire the Order Land to enable the Junction Works to be

constructed.

3.3 Negotiations with landowners, lessees and tena nts

3.3.1 In accordance with paragraphs 24 and 25 of the Memorandum Part 1

Compulsory Purchase of the ODPM Circular 06/04 (additional

document 2) the Council has undertaken land negotiations in parallel

with the making of preparations for the CPOs. Negotiations and

discussion has been ongoing with all the land owners and tenants

affected by the CPOs and SRO and further details are outlined below.

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3.3.2 The Allen family [OBJA07, OBJS03]

Plots 1, 3, 7, 9, 11, 19 (CPO (A)) and Plot 1 (CPO (B)) A detailed listing

of correspondence and discussions with the landowners and their

solicitors and agent is included as appendix O. Following negotiations

a letter has been received from the Allen’s agent confirming withdrawal

of objections to the CPO and SRO included as appendix N.

3.3.3 St Modwen [OBJA03, OBJB01, OBJS02]

Plot 11, 19 (CPO (A)) and Plot 1 (CPO (B)) A detailed listing of

correspondence and discussions with the landowners and their

solicitors and agent is included as appendix P.

3.3.4 Mckechnies [OBJA06]

Plot 2 (CPO (A)) Negotiations are proving difficult; the principal

difficulty in overcoming the objection is the objector’s belief that the

property has a ransom value, which the Council does not accept. A

detailed listing of correspondence and discussions with the landowners

and their solicitors and agent is included as appendix J.

3.3.5 Thackers [OBJA09, OBJS05]

Plots 10 and 14 (CPO (A)) A detailed listing of correspondence and

discussions with the landowners and their solicitors and agent is

included as appendix K.

3.3.6 Trust Inns [OBJA08, OBJB03, OBJS06, OBJSL02]

Plot 18 (CPO (A)) and Plot 3 (CPO(B)) Refers to part of the grounds of

the property known as The Parks (see paragraph 3.2.5 (h) above).

The Council has, through negotiation, purchased the whole of the

property and completion was affected on 27 February 2015. A copy of

letter dated 20 February 2015 confirms withdrawal of the objections

(Appendix H).

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3.3.7 Stubbs

Plot 20 (CPO (A)) Negotiations have resulted in suitable compensation

being agreed; a detailed listing of correspondence and discussions with

the landowners and their solicitors and agent is included as appendix

L.

3.3.8 JCB

Plots 21, 23 and 25 (CPO (A) A detailed listing of correspondence and

discussions with the landowners and their solicitors is included as

appendix S. Both parties are currently progressing the transfer of the

land.

3.3.9 Wallington Square Management [OBJA05, OBJS01, OBJSL01]

Plot 24 (CPO (A)) Discussions between the land owner and JCB

regarding the purchase of this plot have been ongoing and JCB have

confirmed that negotiations are in the advanced stages. JCB have

further confirmed that the land will be transferred to the Council as a

developer’s contribution; a copy of the letter dated 26 January 2015 is

attached as Appendix E.

3.3.10 South Staffs Water [OBJA04, OBJS07]

The Council has confirmed that all existing apparatus that remains in-

situ will be in the adopted highway, all diversions will similarly be

accommodated in the adopted highway. Copies of letters dated 21

October and 10 November 2014 for the SRO and CPO respectively

confirming withdrawal of the objections are attached as Appendix F

and G.

3.3.11 Western Power Distribution (WPD) [OBJA01, OBJA02, OBJB02]

Plots 7, 8, 9, 11, 12, 14, 15, 16, 17, 19, 24 and 25 (CPO (A)) and Plot 1

and 2 (CPO(B)). Heads of terms for the withdrawal of the objections

have been agreed with Bruton Knowles who are acting as agents for

Western Power Distribution a copy of this document is included as

appendix M.

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3.3.12 Shell UK Limited [OBJA10, OBJS04] A detailed listing of

correspondence and discussions with the landowners and their

solicitors and agent is included as appendix R.

3.3.13 Accommodation works for the relevant plots are being negotiated with

land owners and agents, and at this moment have not been finalised.

4.0 Engineering and Technical

4.1 Existing local highway network

4.1.1 The A50(T) Growth Corridor is located to the north of the town of

Uttoxeter, within Staffordshire in the administrative area of East

Staffordshire Borough Council. The A50(T) is part of a key strategic

route running through the north Midlands linking the M6 in the West to

the M1 in the East (the “A50 Growth Corridor” ); improvements to the

A50(T) are required to alleviate existing and predicted congestion,

improve highway safety in the Uttoxeter area, where over 37,000

vehicles use the A50(T) highway daily, and to facilitate development

along the A50 Growth Corridor.

4.1.2 North of the A50(T), the Junction Works site comprises the existing

A50(T) merge and diverge slip roads, A522 highway land, together with

the front garden of a residential property, small areas of agricultural

fields and part of the JCB Major Parts factory grounds all being

required for slip road embankments and a new roundabout.

4.1.3 South of the A50(T) small areas of agricultural fields are required

for slip road embankments together with the southern roundabout

to an over-bridge. The site area also includes a link road connection

from this southern roundabout through agricultural fields and then

passing through the grounds of The Parks restaurant to connect

with the A522 (New Road) south of the A50(T). The application

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boundary also includes the existing A50(T) merge and diverge slip

roads and associated roundabout south of the A50(T).

4.2 Traffic (flows and accidents)

4.2.1 Under existing conditions the A50 carries up to 37,000 vehicles per day

as identified in the below table extracted from the Transport

Assessment (TA) (appended as document L to the Statement of Case)

submitted in support of the Planning Application:

4.2.2 As identified within the TA there have been 52 recorded personal injury

accidents in the previous 5 years up to 31 December 2012 within the

scoping area. Table 3.4 of the TA summarises these accidents as

below:

4.2.3 In addition to the injury accidents detailed in the above table and in the

TA, there have been a number of accidents since December 2012

which have occurred within the study area. Most significantly three

serious accidents have resulted in two fatalities.

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4.2.4 The Environmental Statement (ES) (appended as document H of the

Statement of Case) details that ‘Project A would occur predominantly

within the highway context of the existing A50 (T) and be confined

largely within the existing highway boundary. The Scheme would not

introduce new or incongruous elements, other than locally around the

grade separated junction, and the presence of increased highway

infrastructure would be partially offset by the removal of existing

infrastructure such as the A522 overbridge. The Scheme will not

increase traffic volumes and will not therefore impact on landscape

character as a result of increased traffic’.

4.2.5 The Staffordshire County Council Local Transport Plan 3 and the

associated delivery plan for East Staffordshire (additional document 8)

refers to the need to manage the impact of development sites along the

A50(T) at Uttoxeter. In addition, the County is noted as working with

the Highways Agency to ensure that the highway infrastructure

proposed by the Highways Agency for the A50 is put in place. The

plan further references the high level of growth in employment

land likely to occur in Uttoxeter as follows:

“10 hectares is located at Land West of Uttoxeter, adjacent to the

A50(T) and a further 10 hectares continues to be allocated at Derby

Road in Uttoxeter. These sites will be developed over the plan period

for a variety of employment uses, in particular B1 and B8.”

Quite clearly these development proposals will result in an increase in

traffic flows on the A50(T) and the likely associated increase in traffic

accidents leading to a deterioration in the existing situation on the A50.

4.2.6 Further stated aims of the delivery plan are to:

a) Accommodate sustainable development on local roads in Uttoxeter

and at junctions with the A50(T);

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b) Improve the operation and safety of the A50(T) around Uttoxeter to

support local growth, jobs and housing;

c) Deliver the access and service requirements for developments

proposed in the Pre-Submission Local Plan (additional document 4)

and emerging development east of Doveway and at the former JCB

works in the town centre;

d) Increase connectivity to local jobs at JCB and Alton Towers Resort

through the delivery of the A50 (T) to Alton Growth Corridor transport

improvements;

e) Potentially introduce a Smarter Running scheme on the A50(T)

including the installation of vehicle detection and information on

speeds and congestion problems.

4.2.7 In terms of significant effects, the Junction Works proposal generates a

range of benefits for both strategic traffic travelling on the A50(T) and

local traffic, key benefits include;

a) Removal of substandard slip roads; improving safety and resilience

of the A50(T);

b) Increased operational capacity of the A50(T) through the provision of

lane gain/lane drop facilities;

c) Increased operational capacity of the A50(T) junction for local traffic

access and egress;

d) Provision of a junction arrangement which is capable of sustaining

the proposed development demand with minimal impact on the

performance of the SRN e.g. JCB development.

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However, the principal benefit of the Junction Works is the future

proofing of the A50(T) intersection, enabling the network to

accommodate the development proposal without detrimentally

impacting the performance of the A50(T) or the local highway network.

4.2.8 In conclusion, it has been demonstrated through the TA that the

Junction Works provides a significant benefit to the performance of the

transport network within the study area and improves the resilience of

the network as a whole, whilst providing additional operational capacity

to support the local development proposals. It is considered that the

Junction Works comply with relevant National and Local policies.

4.3 Potential Visual Effects

4.3.1 Changes in views may give rise to adverse or beneficial visual effects

through obstruction in views, alteration of the components of the view

and through the opening up of new views by the removal of screening.

For most locations the Junction Works would result in limited changes

to the nature of visual impact currently experienced from the

representative viewpoint locations. Potential visual impact from

highway modification within the existing A50(T) corridor will be limited

by retention of the substantial woody vegetation which is characteristic

of the A50(T) for much of the Junction Works length.

4.3.2 Where the footprint is extended beyond the existing A50(T) corridor,

potential exists for removal of existing woodland/screening and the

introduction of highway infrastructure which will change the nature of

views – principally this relates to the proposed grade separated

junction with on/off slip roads.

Potential visual effects are listed below:

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a) Temporary impacts arising from earthworks and construction activity,

including machinery, traffic management and vehicles associated

with the construction of the new highway elements;

b) Visual effects arising from the Scheme corridor as a result of

modification within the existing A50(T) corridor, for example

increased proximity to receptors, loss of vegetation or visibility of

new highway infrastructure such as signs or lighting;

c) Visual effects from extension into land beyond the existing highway

boundary of the A50(T) –principally this would relate to the grade

separated junction with on/off slip roads which will extend visibility of

the highway by removal of vegetation and increased infrastructure

above existing ground levels and the creation of new landforms;

d) Visual effects arising from the removal of the A522 overbridge will

result in a locally reduced highway footprint and opportunities for

establishment of planting on land not required for vehicle circulation.

4.3.3 The street lighting will include the illumination of the proposed new

roundabout, junctions and all interlinking carriageways. All existing

roads within the Junction Works boundary, which it is proposed to

illuminate, are already illuminated.

4.3.4 Street lighting will be designed in accordance with BS5489, Codes of

Practise for the Design of Road Lighting and BSEN 13201. It will

illuminate both the carriageway and footway, to enable road users to

aid identification of potential obstacles and each other after dark.

The street lighting on County adoptable roads will be subject to

dimming when traffic volumes are lower.

The type of column will be galvanised steel throughout the Junction

Works and the height of the columns will match existing and the

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lighting levels will be designed in accordance with BSEN 13201 and BS

5489.

Mitigation

4.3.5 The impact of the street lighting has been minimised by ensuring the

appropriate lighting levels are as outlined in BSEN 13201 and BS 5489

have been used. The existing street lighting will be assessed to ensure

that light pollution levels are not significantly increased by the scheme

and the overall lighting impact is minimised.

4.3.6 In conclusion, the street lighting scheme will not have any adverse

impact on the immediate environment greater than the baseline.

Lighting columns will not be taller or more visually prominent than the

existing columns and will be confined to locations where lighting is

currently present.

4.3.7 Mitigation of landscape and visual effects is intrinsic within the Junction

Works proposals, which seek to substantially retain as much as

possible of the existing well established vegetation within the highway

corridor and incorporate planting such that the existing wooded

character of the A50(T) corridor remains a primary characteristic which

limits its influence on the wider landscape of the Study area.

The landscape proposal for the A50 Growth Corridor Project A seeks

to:

a) Provide screening for the new grade separated junction;

b) Provide landscape connectivity with existing retained landscape

features adjacent to the site;

c) Mitigate for landscape features that will be removed to accommodate

the general civil engineering works.

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4.3.8 The new embankments formed by the grade separated junction will be

planted with a mixture of native trees and shrubs. Additional outlying

groups of native planting will extend along the A50 (T) corridor to tie in

to existing vegetation along the road boundaries.

4.3.9 New hedgerows will be planted along some road and field boundaries

to provide further screening and enhance the landscape structure. The

hedgerows will be native stock, with species indigenous to the area

and will be augmented with planting of clear stemmed hedgerow trees.

4.3.10 Meadow grassland will be created to the south west of the pools in the

grounds of the JCB World Parts Centre and in the newly graded area

to the south of Anfield House Stables.

4.4 Ecology and Nature Conservation

4.4.1 The ES, appended as core document H to the Statement of Case,

reports on the predicted effects of the proposed Junction Works on the

biodiversity resource of the area. The objective is to identify the

significance of effects on biodiversity assets likely to arise from the

construction and operation of the Junction Works, in accordance with

the National Planning Policy Framework (NPPF) (additional document

5).

4.4.2 The Junction Works are located in the urban fringe to the north of

Uttoxeter. The immediate environment is dominated by the A50 (T)

and A522 and is predominately composed of agricultural fields

separated by hedgerows. There is also extensive woodland planting

associated with the A50 (T) and a mix of habitats which are part of JCB

landscaping. The River Tean to the north flows west to east towards its

confluence with the River Dove, its meandering course taking it to

approximately 100 metres from the works area at the closest point.

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4.4.3 The NPPF (additional document 5) sets out the Government’s planning

policies for England and how these are expected to be applied. In brief

the policy states:

The planning system is expected to “contribute to protecting and

enhancing our natural, built and historic environment; and, as part of

this, help to improve biodiversity....”

“The planning system should contribute to and enhance the natural and

local environment by minimising impacts on biodiversity and providing

net gains in biodiversity where possible, contributing to the

Government’s commitment to halt the overall decline in biodiversity,

including by establishing coherent ecological networks that are more

resilient to current and future pressures”;

“to minimise impacts on biodiversity and geodiversity through planning

policies”; and

“when determining planning applications, local planning authorities

should aim to conserve and enhance biodiversity.”

4.4.4 All assessments were carried out in accordance with the guidance in

the Design Manual for Roads and Bridges (DMRB) Detailed

Assessment (DMRB Volume 11, Section 3, Part 4, Ecology and Nature

Conservation) and the Staffordshire County Council Checklist for

Planning Application Validation. This takes into account:

• The National Planning Policy Framework

• The East Staffordshire Borough Pre-submission Local Plan Strategic

Policy 29

• Biodiversity and Geo-diversity

• The Conservation of Habitats and Species Regulations 2010

21

• The Wildlife and Countryside Act 1981 (as amended)

• The Natural Environment and Rural Communities Act 2006

• The Hedgerow Regulations 1997

• The Protection of Badgers Act 1992

• The Staffordshire Biodiversity Action Plan (SBAP) 3rd edition.

4.4.5 The following surveys have been carried out, supported by a records

search that includes information obtained from the Local Records

Centre Staffordshire Ecological Record:

• A preliminary ecological appraisal (Extended Phase 1 Habitat

Survey) including ;

• Scoping for the potential presence of protected species;

• A hedgerow survey determining if any hedgerows qualify as

important under the Hedgerow Regulations;

• Assessment of trees for potential for use by roosting bats and owls;

• Assessment of water-bodies lying within 250m of the site for their

potential to support:-

• Great Crested newts Triturus cristatus;

• Reptile and Dingy Skipper

Results of these surveys are included in the ES.

4.4.6 In designing mitigation of impacts on biodiversity, the mitigation

hierarchy of Avoid: Minimise: Mitigate: Compensate: Enhance has

been adopted. Where possible impacts have been avoided or

minimised, elsewhere mitigation is proposed and where impacts are

unavoidable compensation and, where possible, enhancement, has

been included in the scheme. Construction works will be controlled by

a Construction Environmental Management Plan (CEMP); the provision

of which is a condition of the planning approval (see paragraph 4.4.8

below); this will include measures for habitat and species protection, for

22

protection of the water environment during construction and for

prevention of spread of invasive plant species.

4.4.7 During construction, the proposed highway scheme is both impacted

by and impacts upon the surrounding water environment; a range of

mitigation measures are proposed for both the construction and

operation phases of the proposed scheme. The proposed mitigation

measures detailed within the ES allow the various impacts on the

Junction Works to be addressed as far as practicable.

4.4.8 As part of the Planning Permission for the site there is a Condition

which requires that a Construction Environmental Management Plan is

submitted for approval prior to commencement of the Junction Works.

Within these requirements there are statements that require the

following:-

m) Measures to safeguard protected species which include a

requirement that:

i) in the event that the development has not commenced for 2 years

after the date when the protected species surveys were carried out,

then the site preparation and construction operations shall not

commence until the Site has been re-surveyed for protected species

by a suitably qualified ecologist and the results have been submitted

to the County Planning Authority.

ii) more specifically, in accordance with the recommendations in the

‘Great Crested Newt Survey Addendum Report’ (section 4), no site

preparation or construction operations shall be carried out within 250

metres of ‘Pond 3’ shown on Figure 1 in the report (Dwg. No

CDX8609/R00130 Rev A) until a re-survey for great crested newts

has been carried out by a suitably qualified ecologist at the optimal

23

time and the results of the re-survey have been submitted to the

County Planning Authority;

iii) should protected species be found during the re-surveys then a

Protected Species Method Statement detailing the mitigation

measures that would be employed to safeguard protected

species shall be submitted for the written approval County

Planning Authority.

n) Measures to protect reptiles which shall include:

i) reptile surveys to be undertaken by a suitably qualified ecologist

prior to the commencement of the site preparation and construction

operations

ii) protective fencing; and,

iii) habitat management.

o) Measures to protect breeding birds which shall include:

i) bird breeding survey(s) undertaken by a suitably qualified ecologist

if site preparation and construction operations are planned to be

carried out during bird breeding season (March to August inclusive);

and,

ii) details of the steps that would be taken to minimise the risk of

breeding birds being disturbed during site preparation and

construction operations and the steps that would be taken in the

event that breeding birds are found.

p) Measures to minimise the risk of the spread of non-native American

Signal Crayfish which are present in the River Tean.

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4.5 Archaeology and Cultural Heritage

4.5.1 The ES, appended as core document H to the Statement of Case, in

Chapter 6 reports on the predicted effects of the proposed Junction

Works on cultural heritage assets within the study area. This

assessment was undertaken in accordance with all relevant

legislative and policy requirements. This includes:

• The Planning (Listed Buildings and Conservation Areas Act ) 1990;

• The Ancient Monuments and Archaeological Areas Act 1979;

• National Planning Policy Framework (NPPF, 2012);

• East Staffordshire Borough Council Local Plan (Adopted 2006);

• National Planning Policy Guidance (NPPG, 2014);

• PPS5: Planning Practice Guide (English Heritage, 2010);

• The Setting of Heritage Assets (English Heritage 2011); and

• Conservation Principles, Policies and Guidance (English Heritage

2008)

4.5.2 The NPPF (additional document 5) sets out Government planning

policies for England and how these are expected to be applied; Section

12 of the NPPF sets out the importance of being able to assess the

significance of heritage assets that may be affected by a development.

Significance is defined in Annex 2 as being the, “value of an asset to

this and future generations because of its heritage interest. This

interest may be archaeological, architectural, artistic or historic

interest.”

4.5.3 Paragraphs 128 and 129 of the NPPF state that when determining

planning applications, local authorities should require an applicant to

describe the significance of assets that may be affected by a

development, to a level of detail that is proportionate to their

importance and that is no more than sufficient to understand the

25

potential impact on their significance; this should also include assets

where their setting may be affected by a proposal.

4.5.4 Paragraph 132 recognises that heritage assets are irreplaceable and

that where proposed development may impact on the significance of

designated heritage assets, great weight should be placed on its

conservation; the more important the asset, the greater the weight

should be. Substantial harm to or loss of assets of the highest

significance, for example scheduled monuments, registered

battlefields, Grade I and II* listed buildings and registered parks and

gardens and World Heritage Sites should be wholly exceptional. The

NPPF notes that alteration or destruction of a heritage asset or

development within its setting can harm its significance. Where

substantial harm is found, substantial public benefits must be achieved

to outweigh this loss.

4.5.5 The NPPF states that the effect of a planning application on non-

designated heritage assets should be taken into account when

considering the application. Paragraph 135 sets out the need for a

balanced judgement between the significance of the heritage assets

and the scale of any harm or loss, when considering assets directly or

indirectly affected by proposed development.

4.5.6 The assessment has identified one moderate adverse impact. This is

on the asset of potential prehistoric deposits which may be located

within the scheme footprint and removed by construction activities.

Although this is identified as a moderate adverse impact, the level of

prehistoric archaeology within the scheme footprint is as yet unknown.

Therefore when archaeological evaluation is undertaken, there is a low

risk prehistoric archaeology would be found, with any archaeology

being appropriately recorded and archived. This mitigation means that

there would be no significant residual effect on archaeological deposits.

The assessment has identified slight adverse impacts on ten heritage

assets.

26

This residual effect takes into account the mitigation measures

proposed for the scheme which include a programme of archaeological

evaluation will consist of geophysical survey, if the geology is

conducive to accurate results. If this is not the case, a programme of

trial trench evaluation will be required. This will be followed with

detailed excavation in areas where archaeology of significance has

been identified.

Six heritage assets have been assessed as experiencing a neutral

impact from the proposed scheme. This includes the grade II listed

milepost (1392049).

It is concluded that although a moderate adverse effect has been

identified on one heritage asset, the overall level of effect is not

significant and the scheme represents a less than substantial harm to

the heritage assets within the study area.

4.5.7 As part of the Planning Permission for the site there is a Condition

which requires that a Construction Environmental Management Plan is

submitted for approval prior to commencement of the Junction Works

within these requirements there is a statement that requires the

following:-

t) A Written Scheme of Archaeological Investigations (‘the Scheme’),

based on the environmental Statement (Chapter 6), which shall be

prepared and carried out by an experienced archaeological

organisation. The Scheme shall set out a staged programme of

archaeological work which shall include geophysical surveys,

evaluation by trial trenching, post-excavation reporting and appropriate

publication.’

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4.6 Noise

4.6.1 As concluded in paragraph 8.10 of the ES, a DMRB detailed traffic

noise assessment has been undertaken for the proposed scheme

assessing the impact for the baseline year (2015) and design year

(2030).

The construction of new slip roads for the Junction Works will

have the effect of providing some screening to the existing residential

area to the south of New Road from traffic using the A50(T).

The re-alignment of New Road will also provide some noise benefits to

the same residential area by moving the carriageway further away.

4.6.2 As a result of these changes, noise levels would be expected to

increase very marginally at the most severely affected dwellings but

decrease by a similar level at a substantially higher number. For the

majority of receptors within the study area, the impact will be minimal

ranging from negligible adverse to negligible benefit.

4.6.3 The short term impact in year 1 of opening has an increase of

between 1 to 3 dB being experienced at 20 dwellings. No receptors

would experience an increase greater than 3 dB. There would be 90

dwellings experiencing a decrease in noise of between 1 and 3 dB,

with two benefiting from a decrease of between 3 to 5 dB. For the long

term impact, no receptors would experience an increase in noise

greater than 3 dB. There would be one dwelling experiencing a

decrease greater than 3 dB.

4.7 Air Quality

4.7.1 In general, construction activities have the potential to generate fugitive

dust emissions as a result of demolition, earthworks, construction, or

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trackout of material. However, for the Junction Works, the

concentrations of any airborne particulate matter generated by

construction activities would be controlled using on site management

practices to the extent that should give rise to effects of negligible

significance on dust deposition rates at the nearest sensitive receptors.

The impact of fugitive emissions of PM 10 at these receptors, with

proposed mitigation applied would also be negligible. Overall the effect

of fugitive emissions of particulate matter (dust and PM 10) from the

proposed Junction Works is considered to be not significant with

respect to potential effects on health and amenity.

4.7.2 East Staffordshire Borough Council have not identified any risk to the

national air quality objectives in the Uttoxeter area to date and have not

declared an Air Quality Management Area in or around the air quality

study area considered in the Environmental Statement. The ES

concludes that on balance, the magnitude of change in annual mean

concentrations of nitrogen dioxide at locations close to the A50 (T)

means that the Junction Works would have a slight adverse effect on

local air quality. However, such an effect is not considered to be

significant.

4.8 Ground Investigation

4.8.1 Data from Ground Investigation Reports has been interpreted and

analysed to inform the design of the development and the residual

significance of the impacts on land quality, geology and soil

contamination is considered to be primarily negligible when mitigation

is considered.

4.8.2 The direct cumulative effect of urban development around Uttoxeter

and the Project A proposals is not considered significant due to the

difference in scale of the Project A proposals when compared with

other committed urban developments within Uttoxeter.

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4.9 Proposed road network (“the Junction Works”)

4.9.1 The Junction Works (as shown on drawing No. CDX8609/P/01

(Document Y of the core documents), include the construction of a

completely new junction to the west of Uttoxeter. This junction will

provide local access to Uttoxeter and the development sites within the

Town Centre, the proposed housing and business park to the south of

the A50 (T), and to the existing and new factories to the north of the

A50 (T).

4.9.2 The Junction Works in detail comprise:

a) Carrying out improvements to the junction of the A50 Trunk Road

with the A522 north west of Uttoxeter and approximately 560

metres to the east of the JCB World Parts centre by:

i) The construction of westbound and eastbound merge and

diverge slip roads;

ii) The construction of two roundabouts north and south of the

A50 Trunk Road, and a bridge linking the roundabouts and

crossing the A50 Trunk Road, (forming part of the realigned

A522), such roundabouts linking with the slip roads referred

to above;

b) Carrying out improvements to the A522 for a distance of

approximately 180 metres running north west from its junction with

the new north roundabout referred to in a(ii) above;

c) The construction of a highway (being the realigned A522) running

southwards from the south roundabout referred to a(ii) above for

approximately 70 metres, a roundabout at the end of that section of

highway, and a highway running from the roundabout in a generally

30

eastern direction for approximately 840 metres to join the existing

alignment of the A522 approximately 60 metres west of the junction

of Bentley Road and the A522;

d) The construction of a highway from a point on the A522

approximately 150 metres north west of the north roundabout

referred to in a(ii) above extending generally south eastwards for

approximately 410 metres;

e) Carrying out improvements to the A50 Trunk Road by widening it to

a dual three lane highway for a distance of approximately 930

metres in an easterly direction from the bridge referred to in a(ii)

above;

f) The diversion of watercourses and the carrying out of other works

on watercourses in connection with the construction and

improvement of the highways mentioned above;

g) Use of the Order Land and existing highways by the Council in

connection with such construction and improvement of highways

mentioned above;

h) The mitigation of any adverse effects which the existence or use of

the highways proposed to be constructed or improved will have on

their surroundings;

i) Demolition of the existing A522 over bridge;

j) Provision of footway/cycleway facilities, along the new alignment of

the A522 and across the A50(T) to provide a clear link between the

existing and proposed residential and business developments and

links to Uttoxeter Town Centre;

31

k) Provision of alternative private tracks and accesses to replace

those effected by the Junction Works and detailed in the SRO.

l) Provision of a new realigned section of public footpath linking the

existing Public Footpath no. 56, Uttoxeter Rural to the new highway

network;

m) Reconnection of public footpaths 52 and 56 to the new highway

network following extinguishment of short sections under the SRO;

n) Associated tree planting, landscaping and further aesthetic

measures and mitigation.

4.10 Impediments

4.10.1 Accommodation works are required to provide alterations/

reconfiguration of The Parks parking area and associated works (e.g.

surfacing, lining, retaining structure, lighting etc.), a replacement

helipad at JCB, and a farm access road to Park Farm, as well as the

general provision of fences, hedgerows and gates at all affected plots.

These works were not covered by the planning application (core

document F) and the subsequent permission granted by Staffordshire

County Council, as negotiations with the relevant landowners were still

ongoing at this time. It should be noted that these works do not actually

impact on the ability to construct the Junction Works.

4.10.2 For the purpose of the Council being able to demonstrate that there will

be no obvious impediments at the CPO Inquiry (in accordance with

ODPM Circular 06/04 Memorandum para. 23), East Staffordshire

Borough Council have confirmed (letter dated 16 March 2015) that

where planning permission will be required for the accommodation

works, and has not yet been granted, ‘there should be no obvious

reason why it might be withheld’ (appendix C).

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4.11 Construction timetable

4.11.1 Subject to confirmation of the CPOs, SRO, SLRO and finalising the

construction contract (as contingent on confirmation of the Orders), the

Council intends to start on site in autumn 2015 with completion by late

summer 2017; it is anticipated that there will be a two year build period.

5.0 Planning

5.1 Purpose and need for the CPOs, SRO and SLRO

5.1.1 The land, interests over land, and new Rights to be compulsorily

acquired under the CPOs (the “Order Land”), as previously described

in section 3.2, are needed to secure highway and access

improvements and to mitigate access and highway safety issues.

5.1.2 Compulsory acquisition will enable the Junction Works to take place in

a timely fashion and give certainty to the delivery of the wider public

benefits that the junction improvements and the development of the

surrounding area will secure. The Orders will also provide certainty for

programming and the realisation of the Council’s policy objectives.

5.1.3 As a consequence of the CPOs various sections of the existing A50(T),

A522 and public rights of way Nos. 52, 56 and 57 are required to be

stopped up, diverted, improved and/or raised to allow the Junction

Works to be progressed and these have been addressed through the

making of the SRO. All existing private accesses affected by the

Junction Works have also been included in the SRO and will be

realigned so they continue to have direct linkage to the local highway

network. There are no requirements for additional land, other than that

stated in the Order Land, to replace existing private means of access

affected by the Junction Works and all new accesses will have direct

access to the new highways referred to in paragraph 4.9.2 above.

33

5.1.4 The SLRO which has been made by the Highways Agency under

sections 10 and 41 of the Highways Act 1980 will facilitate the new

eastbound and westbound merge and diverge slip roads, which are to

be created for access and egress onto the A50 and will become part of

the A50 Trunk Road.

5.2 Planning History

5.2.1 The planning application for the Junction Works was submitted to

Staffordshire County Council on 11 June 2014 as the Local Planning

Authority under Regulation 3 of the Town and County Planning General

Regulations Act 1992. The planning application for the A50 Growth

Corridor Project includes the construction of a new grade separated

junction on the A50(T), including associated link roads to the A522,

demolition of an over-bridge, and landscaping to provide improved

access to the A50(T) for business and housing developments, and to

improve highway safety. The Planning Committee determined the

application on 06 November 2013 with a permission being confirmed

on 14 November 2014 (core document F); no Judicial Review

challenge to the grant of permission has been made, and the Council is

advised that it is now too late to do so.

5.2.2 Planning applications have also been submitted for developments

adjacent to the Junction Works by St. Modwen and JCB (additional

document 16). Land West of Uttoxeter is allocated for development in

the East Staffordshire Local Plan; whilst the JCB scheme, despite

being a departure from the Adopted Local Plan (additional document

3), results in significant economic investment in the Borough and is

supported by the presumption in favour of sustainable development as

set out in the National Planning Policy Framework which outweighs the

older saved policies of the Local Plan. These applications can be

summarised as follows and are demonstrated in additional document

15 showing proposed developments in proximity to the Junction

Works:-

34

a) A50-Waterloo Farm – Erection of a detached factory building

together with associated offices, delivery storage and despatch

facilities and associated lorry, visitor parking, security gatehouse

and sprinkler tanks, associated drainage, bunding and structural

landscaping; JCB CAB Systems Ltd. (Planning reference

P/2013/01530). Planning Permission granted 10 July 2014.

b) Land West of Uttoxeter – Development of 50.7 Ha of land for up to

700 dwellings, 10Ha of employment use (Classes B1, B2, B8), a

first school, a mixed use local centre incorporating retail, leisure,

social, cultural, community and health facilities, green infrastructure,

associated engineering works, access to New Road and Bramshall

Road and associated internal access roads including demolition of

Dutch barn and rear stable building; St. Modwen. (Planning

reference P/2013/00882), which is allocated for development in the

East Staffordshire Local Plan.

5.2.3 Both of the above applications included a Transport Assessment (TA)

as part of the submitted supporting information and there are several

specific points raised which indicate that the Junction Works will

facilitate the developments and bring forward their full potential.

JCB CAB Systems Ltd. (P/2013/01530) (see additional document

16)

It is noted that the Transport Assessment submitted by JCB CAB

Systems did not include any reference to the St. Modwen development

and as such did not consider the traffic generated from that site; the TA

does however make the following relevant assumptions in:

35

a) Paragraph 4.1 as follows:-

‘For assessment of the A50 junctions, a design year of 2024

would typically be used in accordance with the Department for

Transport’s Circular 02/2013 ‘The Strategic Road Network and the

Delivery of Sustainable Development’, which requires assessment

of the existing network to accommodate traffic up to ten years

after the date of application registration. However, given that the

comprehensive highway improvements planned in the area would

mitigate the development impact at maximum operation (2018),

the worst case assessment would be for the opening year,

assuming the highway improvements are not in place.’

b) Paragraph 5.10 as follows:-

‘Typically, traffic impact can be assessed for the opening year, and for

a period up to ten years following the application registration. As

mentioned however, only the opening year, has been modelled, since

the local highway improvements for the area would be in place by

2018, and would be expected to mitigate the impact of the additional

flows at this time. The highway improvements are also being designed

to accommodate the anticipated growth in JCB employment in the

area, of which this application forms a part of. Impact has hence been

assessed for an opening year 2015, when the highway improvements

would not yet be in place. The 2015 opening year development

flows have been used for assessment of highway impact.’

c) Paragraph 5.38 as follows:-

‘This TA has confirmed that the residual impact of the proposed

development could be satisfactorily accommodated on the local

highway network at the site access and local highway network.

This is in light of the comprehensive highway improvements planned in

the area to facilitate wider job creation and residential development.

36

Such improvements are expected to occur prior to the 2018

maximum operation stage and will therefore supersede the need

for the upgrading of the substandard slip roads, which would have

occurred as part of the JCB Heavy Products Factory scheme at

Waterloo Park. Therefore, no further intervention would be required

and the proposed development would not result in a material traffic

impact on the wider highway network.’

d) Condition 19 of the permission dated 10th July 2014 also made

reference to the Junction works as follows:-

‘In the event that the A50 Uttoxeter Improvement Scheme, broadly in

accordance with drawing E2-1250-A (exhibition), has not been fully

implemented at the point of the first occupation of the development

hereby approved, then a Transport Strategy shall be submitted to the

Local Planning Authority for their written approval following consultation

with the Highways Agency. The factory shall thereafter be operated in

accordance with the approved Transport Strategy until the A50

Uttoxeter Improvement Scheme has been completed.’

Clearly the above references show that the effects on the highway

network were only considered up to 2018 and the growth in traffic after

this date was not considered appropriate as the Junction Works would

be completed and would therefore mitigate the effects of this and future

development on both the local and strategic highway network.

St Modwens/Uttoxeter Estates (P/2013/00882) (see ad ditional

document 16)

Similarly to the JCB application it is noted that the Transport

Assessment submitted by St Modwen did not include any reference to

the JCB development and as such did not consider the traffic

generated from that site. Furthermore, it is clear that the two

applications were considered in isolation when considering the traffic

37

implications and the Transport Assessments and that neither took

account of the others development, possibly as a result of the timing of

the applications.

a) St Modwen’s Transport Assessment (TA) in paragraph 5.6 states

the committed development that it was instructed to take into

account in the preparation of their TA as follows:-

‘Staffordshire County Council have requested that the following

committed development be included within the traffic impact

analysis of the local highway network;

1. JCB Heavy Products Factory Redevelopment - Mixed-use

development including 257 residential units, A1 food retail land-

use with a gross floor area of 4,200sqm, B1 office land-use

with a gross floor area of 5,000sqm and a Primary Care Trust

building (Planning ref: OU/05254/18)

2. Redevelopment of the former Uttoxeter Cattle Market - Mixed-use

Development including an Asda unit with a gross floor area of

2,880sqm, a non-food retail unit with a gross floor area of

2,258sqm and Primary Care Trust Doctors surgery (Planning

ref: PA/2012/00771)’

This quite clearly shows that the TA did not take into account the JCB

CAB Systems development proposals and the traffic generated from

the proposals.

b) The Officers Report for the above application included Paragraph

1.6 of the Executive Summary which states:-

‘the proposals can be accommodated by the existing highway network

subject to minor improvements. However, the County Council has

recently consulted on a programme of improvements to the A50

38

corridor which will further reduce its impact on the town’s highway

network’.

Clearly the inference from this paragraph is that the Junction Works

(Project A) proposals would further improve the conditions on the A522

and the impact on the towns highway network i.e. assist in facilitating

the implementation of the development.

c) Paragraph 4.7 also contains consultation requirements of the

Highways Agency as follows;-

The Highway Authority ‘has no objections subject to conditions

requiring the submission of reserved matters relating to access and

layout, details of surface water drainage, details of road construction,

details of the Bramshall Road Access prior to the commencement of

Phase 1, details of the northern access prior to the commencement of

Phase 2, the provision of a primary access road connecting Phase 1

and Phase 2 prior to the commencement of the 501st dwelling,

upgrading the northern access road prior to the occupation of any of

the commercial units,’

d) The Main Report in section 10.4 also gives further definition to the

Highway Matters relevant to this development and the following

sections are considered relevant.

Paragraph 10.4.2 gives details of the requirements for the northern site

access which ‘is proposed to be improved by increasing the width of

the existing farm access to 5.5metres, and introducing traffic lights at

the junction of the site access road and the A522 New Road.’

Paragraph 10.4.6 refers to the Transport Assessment which

accompanies the Planning Application which, ‘concludes that the

proposal would increase traffic flows in Uttoxeter, particularly on the

A522 and B5027.’

39

Paragraph 10.4.8 refers to recommendations from the Highway

Authority which states that ‘no industrial units are to be occupied until

the northern access road has been increased in width from the 5.5

metres proposed to 7.3 metres with a 2.0m wide footway.’

Paragraph 10.4.10 specifically refers to the A50 Growth Corridor as

follows:- ‘Members will be aware that the Highway Authority has

recently consulted on a programme of improvements to the A50

corridor through Uttoxeter. Part of these improvements include the

provision of a new grade separated junction approximately on the site

of the existing A522/A50 junction to the west of the town. The scheme

of improvements proposes that this grade separated junction directly

accesses the application site. The existing A522 flyover which contains

the northern site access is proposed to be demolished, with the A522

realigned through the inn on the Parks site to a roundabout within the

application site. A spur from that roundabout would connect with the

proposed grade separated junction on the A50. Works on the A50

improvements are currently timetabled to begin later this year,

beginning with the grade separated junction and realigned A522. It is

therefore likely that the works would be complete in advance of the

second phase of residential development on the application site.’

Paragraph 10.4.11 refers to improvement to the A50 Growth Corridor

and the reduction of the impact of the proposals on the existing

highway infrastructure. ‘Whilst it has been demonstrated that the

existing highway network has the capacity to accommodate traffic

generated by the development without severe effects, the proposed

improvements to the A50 corridor would reduce the impact of the

proposals on existing highway infrastructure in the town. Since access

is a reserved matter the proposals could be accessed from the

improved A50 without the need for a further outline application,

provided that the wording of the conditions recommended by the

40

Highway Authority are sufficiently flexible whilst still maintaining the

necessary degree of control.’

e) In consideration of the above it is clear that the development of the

employment land (10 hectares) cannot take place until the northern

access road is upgraded prior to the occupation of any of the

commercial units (Paragraph 4.7) and no industrial units are to be

occupied until the northern access road has been increased in

width from the 5.5 metres proposed to 7.3 metres with a 2.0m wide

footway (paragraph 10.4.8). To undertake this upgrading the

developer of this application would require land from the adjacent

property known as The Parks and as such the development could

be held to ransom and the full potential of the development could

not be achieved. The proposals for Junction Works would result in

the requirements of paras 4.7 and 10.4.8 not being required as

access would be provided off the new junction layout and hence the

full potential of the employment land could be realised, this is

realised in the paragraphs 10.4.10 and 10.4.11 of the officer’s

report.

5.2.4 Bearing in mind the above (paragraph 5.2.3), it is considered that the

full development potential of both the specific sites referred to cannot

be fully realised without the Junction Works proposal.

5.2.5 In addition to the two sites adjacent to the Junction Works there are

also other potential sites contained within the East Staffordshire Local

Plan period up to 2031, which could include 1700 new houses and up

to 6700 new jobs. Full details of the wider economic benefits the

Junction Works will enable are addressed in the proof of evidence of

Mr Steven Burrows.

5.2.6 The National Planning Policy Framework in paragraph 7 states that

there are three dimensions to sustainable development, namely

41

economic, social, and environmental; the Junction Works as proposed

demonstrate gains in each of these dimensions:

a) Economic – The Junction Works will make it easier for jobs to be

created in and around Uttoxeter, with the proposal facilitating

economic growth by helping to bring forward the 10 ha B1/B2/B8

site on the Land West of Uttoxeter, included in planning application

P/2013/00882. This should create some 40,000m2 of employment

floor space and 1,000 jobs. The Junction Works will also assist in

the creation of the additional new jobs at the proposed JCB

Cab Systems development included in planning application ref

P/2013/01530. A total of some 1,700 jobs will indirectly be

facilitated by the A522/A50 junction improvement scheme.

b) Social – The Junction Works will facilitate access to the

supply of housing included in planning application

P/2013/00882 and facilitate accessibility through new highways

infrastructure to mitigate the impact of development traffic on the

local and strategic highway network, also by providing

sustainable transport options through the provision of a

footpath/cycleway and links to bus stops and services on the A522.

c) Environmental - The supporting documents submitted with the

planning application and listed in paragraph 1.7.2 of the Statement

of Case, demonstrate the proposal fulfils the environmental

requirements by creating new habitats and replacement tree

planting, which will result in a net gain for nature.

5.2.7 It is vital that the quality and effectiveness of the Junction Works

enable the area to be served efficiently and smoothly delivering

materials, goods, customers and travellers without unacceptable

delays or congestion. Well designed, appropriate standard and safe

roads are at the heart of most successful communities. The scheme

will contribute to the achievement of sustainable development by

42

increasing the capacity and flexibility of the highway network and

improving accessibility to and through the area.

5.3 Highway Benefits

5.3.1 The Junction Works generate a range of benefits for both strategic

traffic travelling on the A50 (T) and local traffic, which include the:

a) Replacement of substandard slip roads; improving safety and

resilience of the A50(T) and as a result increased operational

capacity of the A50(T)/A522 junction for local traffic access and

egress;

b) Increased operational capacity of the A50(T) through the provision of

lane gain/lane drop facilities, with the reduction of congestion and

journey times on both the Trunk and Local road networks;

c) Provision of a junction arrangement which is capable of sustaining

the proposed development demand;

d) Provides a junction which is capable of sustaining future

development proposals and opens up development land for housing

and business, to facilitate the creation of jobs and bring economic

benefits to the area;

e) Provides enhanced cyclist and pedestrian routes with efficient and

safe crossings;

f) Provides for future-proofing the A50(T) intersection, enabling the

structure to accommodate development without detrimentally

impacting the performance of the A50(T) or the local highway

network.

43

g) The Junction Works provide a significant benefit to the

performance of the transport network within the study area and

improves the resilience of the network as a whole, whilst

providing additional operational capacity to support the local

development proposals.

5.3.2 The economic benefits are explained fully in the proof of evidence of Mr

Steven Burrows.

6.0 Extant Objections

6.1 The outstanding objections are summarised in the below table and

referenced throughout the remainder of this section as per the

Statement of Case depending on which Order an objection has been

lodged against. For clarification:

• [OBJA…] objection to CPO (A);

• [OBJB…] objection to CPO (B);

• [OBJS…] objection to Side Roads Order (SRO);

• [OBJSL…] objection to Slip Roads Order

Party CPO SRO SLRO

Western Power

Distribution

X

St. Modwen X X

Wallington

Square

Management

X X X

Mr and Mrs

McKechnie

X

R Thacker and

BJL Thacker

X X

Shell X X

44

6.2 [OBJA10, OBJS04] Shell UK Limited (as Freeholde r), Shell

Ventures UK Limited (as Head Tennant), Woodlea Limi ted (as

Under Tenant), and Shell UK Limited (as Occupationa l Tennant) –

Uttoxeter Service Station, New Road and A50, Uttoxe ter

• The proposal of stopping up of direct access to the A50(T)

would result in the site no longer being conveniently accessible

thus threatening viability;

• New junction will lie someway to the west of the existing junction

which will no longer be convenient to motorists;

• New arrangements incompatible with current delivery

requirements and results in HGV traffic u-turning within the site.

Council’s Response

• It is agreed that the Junction Works result in the stopping-up of

direct access from the A50; however impact on viability has not

been proven. There is already alternative access off the A522 to

this facility.

• The Council is in correspondence with Shell’s architects to

assess design options within Shell’s land and the potential for

utilising additional land available to the Council to find a solution

to HGV access;

• The new arrangements will be investigated as part of the

compensation negotiations.

6.3 [OBJA09, OBJS05] R Thacker and BJL Thacker, Anf ield House

Farm

• No need for the project, could be dealt with by alternate works to

slip roads;

• Private road created to property would be costly and a

maintenance liability;

• Increased mileage fuel, wear, tear and time given layout;

• Decrease in house value

45

Council’s Response:

• There is a clear need for the Junction Works and no viable

alternative to the scheme as appropriately ranked and made

clear within the Planning Application documents; the Junction

Works have Planning Consent;

• The service road created to the property will remain as public

highway and not private;

6.4 [OBJA03, OBJB01, OBJS02] St. Modwen including s ubsidiary

company Uttoxeter Estates

• The pumping station is working adequately and it is only

because of the scheme that changes are proposed. No

adequate arrangements have been proposed to deal with this

disruption nor the need for a suitable reconfiguration and link to

the mains sewer;

• Loss of land taken from the planning application site area will

require a major re-design and potentially a new application. It

challenges the viability of the scheme and has major

implications for the infrastructure requirements;

• Removes the existing access to the farm and the proposed

access to the development;

• There will need to be an agreement with the Council regarding

mitigation, compensation and re-design to enable an amended

scheme to proceed;

• The operation of the farm will be seriously affected, the

disruption to existing farming operations and the impact of the

scheme makes the continued operation of the farm significantly

disrupted if not impossible;

Council’s Response

• There will be some disruption to the existing pumping station

and the rising main serving the JCB factories to the north of the

A50, however, a replacement pumping station will be

46

constructed and the rising main relayed within the new highways

- the final solution will therefore be the same as exists at

present;

• There are implications on Planning Application P/2013/00882,

however, this development currently only has outline approval

and it is understood that the final designs have not yet been

developed for the northern end of the works. Many of the

existing requirements are mitigated through the Junction Works

providing enabling infrastructure and a superior access to the

highway network from which St. Modwen will benefit;

• A new access from the adoptable highway will be provided to

the farm at a far better position than is currently available,

access will be maintained during the construction phase;

• The effects on farming operation will be minimal and land take

will be no more than has already been purchased by St

Modwen. Outstanding considerations will be dealt with by

accommodation works and there will continue to be useable

access;

• It is considered that the objection is a matter of compensation

and not principle given the content of the submitted letter of

support (appendix A)

6.5 [OBJA01, OBJA02, OBJB02] Western Power Distribu tion (WPD)

• The Order does not adequately address how WPD interests will

be affected by the scheme;

• The Order does not adequately address how interests and the

electricity network will be protected both during the construction

and operational phases of the scheme;

• Insufficient information to fully understand design and

construction of the scheme and the potential operational

implications;

47

• WPD need to be able to understand how it will continue to fulfil

statutory responsibilities as an electricity distribution company

following acquisition of the Order Land by the Council;

• Not aware of any provision for replacement cable or overhead

line routes for any electricity apparatus that would need to be

relocated.

Council’s Response

• The Council is in ongoing consultation with Western Power

Distribution regarding service diversions and easement to meet

requirements;

• Heads of Terms have been agreed between WPD and the

Council which confirms “Where any apparatus owned or

operated by the Objector within the Order(s) land needs to be

diverted and/or removed in consequence of the proposals

underpinning the Order(s) the Promoter shall meet all the

associated costs reasonably and properly incurred by the

Objector net of any discount to which the Promoter may be

entitled under the provisions of The New Roads & Street Works

Act 1991 where applicable. For the avoidance of doubt these

costs include apparatus installation, new supply cable

installation costs and any associated diversion costs.” This will

result in the withdrawal of the current objections. A copy of the

Heads of Terms is included in appendix M.

6.6 [OBJA05, OBJS01, OBJSL01] Wallington Square Man agement

Limited

• The alternative options for the scheme were not discussed

allowing opportunity to influence the design/specification;

• Appears that the design of the scheme and land-take to

accommodate it are excessive;

• Failure to make efforts to negotiate purchase of the land by

agreement;

48

• The Junction Works result in denial of opportunity to proceed

with a development scheme for the site;

• The Council has yet to secure planning consent as such the

making of the CPO is premature;

• CPO and SRO not made simultaneously to assess cumulative

impact on the site

Council’s Response

• There is no viable alternative to the Junction Works as

appropriately ranked and made clear within the Planning

Application documents; the Council is not aware that an

alternative scheme is being promoted by the objector. Project A

has Planning Consent;

• The Council has, to date, not been involved in negotiations to

purchase the land as it is understood that JCB are to acquire the

land (given their interest in it) and gift to the Council, (this has

been confirmed in correspondence from JCB, see appendix E);

• The making of the SRO followed the making of CPO(A) to allow

the Council the maximum amount of time to negotiate with

landowners; there is no legal impediment to proceeding in this

manner;

• At the time of making the Orders, it is understood that there was

no current planning application or approval regarding assessing

impact on development proposals for the site. It is therefore

considered unreasonable to have to take account any possible

development on this land, which has only been identified as

being suitable as a site for employment development. It is noted

that this land is not included in the Local Plan or in the emerging

local plan for this area.

6.7 [OBJA06] Mr and Mrs McKechnie, Park View Farm

• Little attempt to negotiate and the Order is considered

premature;

49

• No significant justification to interfere with human rights;

• There is no requirement for any changes to the A50 or its

accesses to accommodate the proposed mixed use

development and JCB;

• The new junction, if required, does not need to be at this

location – it can be reconfigured to avoid Park View Farm;

• If alternatively the scheme is needed in this location the extent

of road works is excessive and involves greater land-take than is

necessary;

• If improvement to the A50(T)/A522 is necessary the existing slip

roads should be brought up to standards as required by the

planning permission granted to JCB in 2005 (reference

OU/29352/002/PO)

Council’s Response:

• Extensive negotiations have been ongoing but are proving

difficult (see appendix J); the principal difficulty in overcoming

the objection is the objector’s belief that the property has a

ransom value, which the Council does not accept. It is therefore

considered that the objection is a matter of compensation and

not principle;

• There is no viable alternative to the scheme as appropriately

ranked and made clear within the Planning Application

documents;

• The Junction Works are required to provide improved access to

the A50(T) for business and housing developments, and to

improve highway safety;

• Any issues associated with previous Planning applications are a

matter for East Staffordshire Borough Council

50

7.0 Human Rights

7.1 The Human Rights Act 1998 incorporated into domestic law the

European Convention on Human Rights (the “Convention”)

(additional document 9). The Convention includes provision in the form

of Articles, the aim of which is to protect the rights of the individual.

7.2 Section 6 of the Human Rights Act prohibits public authorities from

acting in a way which is incompatible with the Convention. Various

Convention rights may be engaged in the process of making and

considering a compulsory purchase order, notably the following

articles:

a) Article 1 of the First Protocol protects the right of everyone to the

peaceful enjoyment of possessions. No-one can be deprived of

possessions except in the public interest and subject to the

conditions provided for by law and by the general principles of

international law.

b) Article 8 protects private and family life, home and correspondence.

No public authority can interfere with these interests except if it is in

accordance with the law and is necessary in a democratic society in

the interest of national security, public safety or the economic

wellbeing of the country, for the prevention of disorder or crime, for

the protection of health or morals, or for the protection of the rights

and freedom of others.

7.3 The European Court of Human Rights has recognised in the context of

Article 1 that regard must be had to the fair balance which has to be

struck between the competing interests of the individual and of the

community as a whole. Similarly any interference with Article 8 rights

must be necessary for the reasons set out. Both public and private

interests are to be taken into account in the exercise of the Council's

51

powers and duties. Any interference with Convention Rights must be

necessary and proportionate.

7.4 The Council considers that the Order Land is both suitable for and will

facilitate the carrying out of development and improvement and will, for

the reasons explained in this Statement, make a positive contribution to

the promotion and achievement of economic, social and environmental

wellbeing. It is considered that the Junction Works and the Order will

not unduly infringe the rights of the individuals affected; the public

benefit will outweigh the private loss arising from the acquisitions. The

compulsory acquisition of the Order Land will not conflict with the rights

provided by Article 8(1) of the Convention as the qualifications in Article

8(2) apply.

7.5 All of those persons whose rights under Article 8 and Article 1 of the

First Protocol of the Convention would be affected will have an

opportunity to object to the Order and to have their objection

considered at a fair and public hearing, in accordance with their rights

under Article 6 of the Convention. Appropriate compensation will be

made available to those entitled to claim it under the relevant

provisions of the statutory Compensation Code.

7.6 In pursuing these Orders, the Council has carefully considered the

balance to be struck between individual rights and the wider public

interest. Any interference with Convention rights is considered to be

justified and proportionate in order to secure the economic, social,

physical and environmental regeneration that the Junction Works will

bring. Appropriate compensation will be available to those entitled to

claim it under the provisions of the relevant statutory provisions.

7.7 The Council considers that there is a compelling case in the public

interest for confirmation of the Orders and that the Orders, if confirmed,

would strike an appropriate balance between public and private

interests. It has concluded that there is a compelling case in the public

52

interest for the acquisition of the Order Land. In addition, having regard

to the guidance set out in ODPM Circular 06/2004 (additional document

2), the Council considers that the Order Land is both suitable for and

will facilitate the carrying out of Junction Works, will accommodate

redevelopment and improvement and will make a positive contribution

in the promotion or achievement of the economic, social and

environmental wellbeing of the area for the reasons explained in this

Statement.

7.8 Consultation meetings with the affected land owners, lessees and

tenants of the Order Land have taken place as part of a consultation

exercise carried out prior to submission of the Planning Application;

further consultation took place during the planning application process

and the process connected with the Orders, with the opportunity being

given for interested parties to make representations regarding the

proposal.

8.0 Summary and Conclusions

8.1 My evidence provides background to the A50 Growth Corridor Project

A in relation to the highways and transport work required and gives

detail on the effects on the proposed road network. Project A is

justified and has been through the planning process.

8.2 Project A has support of Central government with proposals to improve

the A50 (T) around Uttoxeter announced by the Chief Secretary (Rt.

Hon. Danny Alexander MP) on the 04 December 2013 as part of the

updated National Infrastructure Plan (NIP) (additional document 11), as

follows:

(NIP Dec 2013) Paragraph 3.10 - “the Government will provide funding

to support improvement to the A50 around Uttoxeter starting no later

than 2015-16 (subject to statutory procedures) to support local growth,

53

jobs and housing; this project will be subject to the usual developer

contributions.”

8.3 The County Council and the Highways Agency have agreed a funding

and delivery agreement dated 19 November 2014. Funding has already

been obtained for land purchase and design costs. Further details are

addressed in the proof of evidence of Mr Steven Burrows.

8.4 Support for the Junction Works and their wider benefits are also noted

by other stakeholders including St. Modwen (appendix A), the LEP

(appendix D), East Staffordshire Borough Council (appendix B), JCB

(appendix I) and the Highways Agency (appendix Q).

8.5 The Council is satisfied that there is a compelling case in the public

interest for the reasons outlined above, which outweigh the adverse

effects of acquisition on individual rights. It is considered that the case

meets the requirements of Paragraph 17 of Circular 06/2004, domestic

legal requirements and the requirements of the European Convention

on Human Rights (ECHR).

8.6 My evidence has addressed the outstanding objections relating to

highway matters; additionally, strenuous efforts have been made to

overcome objections by negotiation and this has been achieved in

some cases.

8.7 I, Andrew Mason, hereby confirm that the facts contained within this

Proof of Evidence (and appendices) are true and the opinions

expressed are correct to the best of my knowledge and belief.

54

9.0 Additional Information

9.1 Appendices

A. St. Modwen letter of support

B. ESBC letter of support (Project A)

C. ESBC letter of support (accommodation works)

D. Letter of support LEP

E. JCB letter Re. Wallington Square Management land

F. South Staffs Water SRO withdrawal of objection

G. South Staffs Water CPO withdrawal of objection

H. Trust Inns withdrawal of objection

I. JCB letter of support

J. DVS record of negotiations - McKechnie

K. DVS record of negotiations - Thacker

L. DVS record of negotiations – Stubbs

M. WPD Heads of Terms

N. Eaton and Hollis Letter re Allen’s withdrawal of objection

O. DVS record of negotiations – Allen’s

P. DVS record of negotiations – St. Modwen

Q. Highways Agency letter of support

R. DVS record of negotiations – Shell

S. Record of negotiations – JCB

T. Photographs of Inquiry Notices erected on site 04 March 2015;

U. Location Plan of Notices

9.2 Core Documents as Attached to Statement of Case Referred to in

Proof of Evidence (as already supplied to Objectors ):

A. Funding Agreement

B. Compulsory Purchase Order (A)

C. Compulsory Purchase Order (B)

D. Side Roads Order

E. Draft Slip Roads Order

55

F. Planning Decision Notice ES.14/11

G. Design and Access Statement

H. Environmental Statement (excluding appendices)

I. Historic Environment Report

J. Ecological Survey

K. Flood Risk Assessment and Drainage Strategy

L. Transport Assessment

M. Tree Survey and Plans

N. Public Consultation Report

O. Vissim Model Performance Images

P. Email from National Casework Team

Q. Letter from National Casework Team

R. Drawing Numbers CDX8609/CPO/01 and CDX8610/CPO/01

S. Officers Report to Planning Committee

T. Letter removing objection to CPO from South Staffs Water

U. Letter removing objection to SRO from South Staffs Water

V. Scheme Options table

W. Land Registry completion of registration (Title No. SF602273)

X. Stoke-on-Trent and Staffordshire LEP business case letter of

support

Y. Scheme Drawing CDX8609/P/01 – scheme layout

Z. Email from National Casework Team (CPO(B))

9.3 Additional Documents which may be referred to a t the Inquiry:

1. Design Manual for Roads and Bridges Volume 6 Section 2 TD

22/06;

2. ODPM Circular 06/2004;

3. East Staffordshire Borough Council Local Plan (July 2006)

‘Saved’ Policies Extended beyond 20 July 2009;

4. East Staffordshire Borough Council Pre-Submission Local Plan

(October 2013);

56

5. Department for Communities and Local Government National

Planning Policy Framework (2012);

6. Highways Agency North and East Midlands Route Strategy

Evidence Report (April 2014);

7. East Staffordshire Borough Council Infrastructure Delivery

Study Part 1 growth options assessment (Final document

2012);

8. East Staffordshire Borough Integrated Transport Strategy 2014

– 2031;

9. European Convention on Human Rights;

10. Stoke-on-Trent and Staffordshire Enterprise Partnership

Strategic Economic Plan Part 1 – Strategy (March 2014);

11. HM Treasury National Infrastructure Plan 2013 (December

2013);

12. Department for Transport Road Investment Strategy: Overview

(December 2014);

13. Department for Transport Road Investment Strategy:

Investment Plan (December 2014);

14. Staffordshire County Council Strategic Plan 2014-2018;

15. Selected drawings;

16. Planning Application forms and drawings for JCB and St

Modwen developments;

17. Letter(s) of support from various parties;

18. Trust Inns Letter removal of objections;

19. DfT National Policy Statement for National Networks December

2014;

20. Department for Business Innovation and Skills. An introduction

to Assisted Areas (October 2014);

21. i54 Brochure

57

Appendix A – St. Modwen letter of support

58

Appendix B – ESBC Letter of support (Project A)

59

Appendix C – ESBC letter of support (accommodation works)

60

Appendix D - Letter of support LEP

61

Appendix E – JCB/Wallington Square Letter

62

Appendix F – SSW SRO withdrawal of objection

63

Appendix G – SSW CPO withdrawal of objection

64

Appendix H – Trust Inns removal of objection

65

Appendix I – JCB letter of support

66

67

Appendix J – DVS record of negotiations – McKechnie

68

69

70

71

Appendix K – DVS record of negotiations - Thacker

72

73

74

Appendix L – DVS record of negotiations - Stubbs

75

76

Appendix M – WPD Heads of Terms

77

78

79

80

Appendix N

81

Appendix O – DVS record of negotiations – Allen’s

82

83

84

85

Appendix P- DVS record of negotiations – St. Modwen

86

87

88

Appendix Q – Letter of support from Highways Agency

89

90

Appendix R – DVS record of negotiations - Shell

91

Appendix S – Record of Negotiations – JCB

92

93

Appendix T - Inquiry Notices

A522 adjacent A50 slip road (JCB) A522 o/s Anfield House Farm

A522 overbridge to A50 o/s The Parks access road

94

Tunnicliffe Way/A522 junction A522 o/s Shell

A50 Verge (Westbound Carriageway) Town Centre

95

Appendix U – Inquiry Notice Plan