FAADAG (the Forres Area A96 Dualling Action Group

Transcription

1 FAADAG (the Forres Area A96 Dualling Action Group) offers the following feedback to Transport Scotland (and in copy to SWECO), as invited pursuant to the recent consultation process undertaken in late June Note: This paper seeks to link its observations and conclusions specifically to the Scheme Objectives (as disclosed by the Exhibition Panels June ); (numbering inserted by FAADAG for reference) 1 To improve the operation of the A96 and inter-urban connectivity through: a -- Reduced journey times b -- Improved journey time reliability c -- Increased overtaking opportunities d -- Improved efficiency of freight movements along the transport corridor e -- Reduced conflicts between local traffic and other traffic in urban areas and strategic journeys 2 To improve safety for motorised and Non- Motorised Users through: a -- Reduced accident rates and severity b -- Reduced driver stress c -- Reduced Non-Motorised User conflicts with strategic traffic in urban areas 3 To provide opportunities to grow the regional economies on the corridor through: a -- Improved access to the wider strategic transport network b -- Enhanced access to jobs and services 4 To facilitate active travel in the corridor 5 To facilitate integration with public transport facilities 6 To avoid significant environmental impacts and, where this is not possible, to minimise the environmental effect on: a -- The communities and people in the corridor b -- Natural and cultural heritage assets. 1 FAADAG Feedback August 2017 Page 1

2 This is a list of the stated Environmental Impacts: Key Topics, according to the Exhibition sheets of June 2017: (numbering inserted by FAADAG for reference) I Air quality traffic related changes at sensitive receptors (e.g. residential areas close to roads, schools, hospitals) II Noise and vibration 2 traffic related changes at sensitive receptors (e.g. residential properties, schools, hospitals) III People and communities 3 i -- Land use changes, agriculture and forestry effects ii -- Non-Motorised Users and severance of routes used by the community iii -- Travellers using the new road IV Policy and plans 4 land allocations for development, key planning proposals and development plan policy V Materials material resources and waste management VI Cultural heritage archaeological remains, landscapes and historic buildings (e.g. scheduled monuments and listed buildings) VII Landscape and visual landscape character (including designated areas), effects on topography and potential visual impacts affecting views from properties and on people outdoors. VIII Nature conservation effects on designated ecological sites, and on important habitats (including rivers and woodlands) and species IX Geology, soils, hydrogeology and contaminated land geological and soil resources, groundwater, private water supplies and other sources of drinking water X Road drainage and the water environment flooding and flood risk, water quality, drainage and river processes, forms and sediments. 2 This item was NOT one of the Topics considered within the Tier 2 Strategic Environmental Assessment Report ( T2SEAR ). It is a welcome, if late, addition, however there remains a complete absence of published data or evaluated matrices to enable a technical comparison of all of the proposed Routes. FAADAG has done the best it can in these circumstances to extract relevant data from local knowledge and mapping. 3 In the T2SEAR, a related Topic was entitled Population and Human Health ; it is rather disturbing to note that in the current consultation, relative evaluation of the effect of the Routes ignores human health. FAADAG s commentary will be offered in the context of Noise and People and Communities below. 4 This is a welcome addition to the topics under consideration at this stage, but again, no comparative data has been published, making the task of giving feedback at this time on alternative Routes very difficult for the public, unsupported by technical and professional support. Consequently, FAADAG will at this time limit its remarks to matters pertinent to the character of the Red and Blue Routes only, and will refrain from commenting, save in the most general sense, on other Routes. FAADAG Feedback August 2017 Page 2

3 FAADAG Forres Area A96 Dualling Action Group It is appropriate that FAADAG disclose its interests at the outset, particularly since they have evolved in the wake of the refinement of the current alternatives presented to the public in late June FAADAG is an unincorporated association. It was formed in the wake of the Tier 2 Strategic Environmental Assessment Report ( T2SEAR ) in July 2014, which was the first opportunity offered to the public (as opposed to statutory consultees) to give feedback on what, for the Forres area, were 3 Options : Forres B North, Forres B South, and what may be described as Option N: Pluscarden. FAADAG was formed with the express objective and Policy of providing a collective voice and set of data and resources for the whole of the Forres Area, rather than acting in the interests of those affected by any one Option. 5 In June 2017, the most recent consultation was published; it confirmed that Option N had been dropped. Forres B South had developed in essence into Route Red, but with an additional variant, dependent on the adoption of Route Red: Route Blue. Forres B North has on the other hand developed into two very different alternative Routes: Route Purple, taking an essentially rural course to the Northern edge of the original corridor, and a new Route Orange. The publication in June of the course of Route Purple (in particular) appears to have led to the emergence of a new action group, seeking to provide a collective voice on behalf of the residents of Brodie, Dyke and Kintessack, on whom Route Purple would have a significant impact, and joined by residents of Broom of Moy, themselves potentially impacted by Route Orange, and especially its O2 variant. FAADAG notes that the publication of the current consultation with a short (6-week) period for giving feedback, during the summer holiday period, has created problems for residents of the Forres Area to gather and evaluate relevant data, and respond in timely fashion to the invitation to give feedback. Whilst naturally content that Option N had been rejected, FAADAG noted that this change had removed a unifying factor that had previously perhaps enabled Forres Area residents to associate under a common cause that was encompassed within FAADAG s expressly non-partisan statement of Policy, namely the rallying to the defence of the exceptional environment of Pluscarden and the Vale of St Andrew. FAADAG, through its usual communication route of social media 6 and press coverage, convened a public meeting open to all residents and businesses in the Forres Area, (North and South) and invited people to a meeting in Rafford Church Hall on 18 July FAADAG Feedback August 2017 Page 3

4 There was a good response and active participation by the people who attended the meeting, but it was noticeable that a) no one apart from people impacted by the Southern Routings (Red and Blue) attended, and b) the spokespeople for the newly emergent grouping of Northern respondents had already begun to argue via their own social media and in the press expressly in favour of a Southern routing, in lieu of either Purple or Orange. Whilst a commonality of rural interest between Purple and Red/Blue receptors might be thought logical, the Northern grouping has evolved independently, and appears to have embraced any inherent conflicts between Purple and Orange advocates, in order to argue for a Southerly Route. FAADAG therefore, in a subsequent General Meeting, reluctantly bowed to the democratic inevitable, and formally altered its Policy, which is henceforth to inform and support those affected by the Red 2, 3, 4 & 5 and Blue 1 Routes, between Brodie and Alves, in their opposition to those Routes. 7 A variety of formal and practical considerations 8 led FAADAG to reject a suggestion (made by some Northern commentators) that it should change its full name to incorporate expressly a Southern designation. Groups and interests who have contributed to and drawn data from FAADAG s resources include businesses and residents along the entire length of Routes Red and Blue 9. FAADAG has also worked alongside Finderne Community Council to gather and share feedback from residents of the more extended community of Finderne (small though it is when compared with other units of local government in Moray). The formal feedback to Transport Scotland made by the Finderne Community Council 10 has been noted, and FAADAG fully endorses the comments made by their locally elected representatives on this Council. FAADAG recognises however that the Community Council has an obligation to represent wider and more diverse interests than just those living on Finderne s Northern borders, albeit that those residents and businesses are the most immediately and severely impacted by the proposed Southerly Routes of Red and Blue. FAADAG recognises a number of common strands of feedback that have been offered in the press and social media on behalf of people impacted by Route Purple, and many of the concerns expressed by FAADAG s own respondents in terms of impacts on biodiversity, nature conservation, and the effect on residents in green field rural locations will likely apply to residents along Route Purple, in differing degrees. The possibility of future collaboration on the development of technical and research materials to be shared with any and all interested groupings remains open for FAADAG. Time, however, has been ticking, and prompt feedback may be deemed more important than extended periods of negotiations of potential local alliances. 7 FAADAG recognises that Route Red R1 would be a logical course, if a routing following the existing transport corridor were to be adopted, and has no comment to make in relation to it in that context. 8 Website, social media identities, bank accounts, signage, etc. 9 A marked-up map of approximate locations of residences of respondents who have contributed to FAADAG s feedback is available at: FAADAG Feedback August 2017 Page 4

5 The feedback offered herein is therefore reflective of the current expressions of concern and interest that have been shared with and by FAADAG among its members and correspondents. The feedback does not seek to comment specifically on the Routes under consideration outwith the immediate Forres Area. FAADAG recognises that there will be many people, who, for example, are currently struggling with long commuting journeys and who would welcome an A96 dualling, whatever the routing, and FAADAG respects those commentators desire for any enhancement of their current transport options. However, FAADAG urges the developers and any general motorway enthusiasts to have a close regard for the interests of a well-established rural Community, and to avoid letting pure engineering (and/or pure financial) considerations direct the course of the proposed development, to the detriment of their neighbours. Before addressing the issues raised by Routes Red and Blue by way of Key Environmental Impacts, FAADAG would like to invite Transport Scotland and SWECO to examine a radical new proposal, that could solve a multitude of problems. FAADAG approach the proposal in three stages: 1: THE RETURN OF OPTION A? FAADAG notes initially that there is a vociferous body of spokespeople who are questioning whether it is necessary to dual the A96 around Forres at all. 11 Most of the residents of the Forres Area, had they been asked prior to the emergence of T2SEAR, would have reacted by saying that Forres already has a by-pass, so what is the issue and where is the need? FAADAG has sympathy for that opinion, and endorses the efforts of those folk who are seeking a revision of the stated Routing alternatives, by essentially inviting Transport Scotland to reconsider Option A, for Forres: thus merely to enhance, and rationalise, not dual, the existing A96 in the Forres area. In this context, one should not lose sight of some hard economic facts that seem to have been subsumed by a political objective that over-rides all stated objectives. The Strategic Business Case published in 2014 actually concluded that end-to-end dualling of the A96 was not the most cost-benefit effective solution out of all the alternatives under consideration. However, complete dualling was nonetheless recommended because "This option achieves the ambitions set out by the Scottish Ministers of connecting Scottish Cities by dual carriageway". The Strategic Business Case is a necessary stage in any "due process" associated with an upgrade of the A96, but it seems that the 47 pages of data and analysis that say it is not worth spending an extra 1 billion (latest estimate - the SBC stated 650million in 2014) have been overwhelmed by a single paragraph saying that it is - because of Government policy. FAADAG accepts that there is no doubt that Elgin and Nairn need a bypass and the volume of traffic in those areas supports a dual carriageway. There is also no doubt that Keith needs a bypass, 11 Forres says No to Dualling : FAADAG Feedback August 2017 Page 5

6 although a single carriageway bypass would more than cope with the existing and projected traffic volumes there. Forres, however, already has a bypass, largely single carriageway, but quite adequate for the current and projected traffic volumes and reference to the Design Manual for Roads and Bridges as regards traffic flows would support the contention that no dualling is required in the Forres area. But even if it were concluded that a dualled section was required, there is no reason to locate it outwith the existing transport and industrial corridor that has been well-established and could easily be redeveloped and rationalised in an integrated manner, to the benefit of multiple otherwise conflicting interests and to achieve many of the Scheme Objectives. Thus, in the context of utilisation of the existing transport corridor North of Forres, to the benefit of the local community, FAADAG believes that, even in the context of a dualled Route, an urgent revisitation should be made by Transport Scotland and SWECO of the validity of the logic, Constraints and costings which led to the prior rejection by Transport Scotland of Option A at least, so far as Forres is concerned. The relative costs of a revised Option A, when set against any variant or combination of the Purple, Red, Blue and Orange Routes, would be vastly reduced, as would be the general disturbance and impact of such alternatives on both the sensitive receptors and commercial interests in the Forres Area. 2: THE ISSUE OF SPACE Option A, which was mentioned in T2SEAR merely as having been rejected (even before the public were consulted!) would have involved the development and enhancement of the existing A96, rather than the creation of a new dualled road in a location other than the existing course of the A96. The rejection of this Option so far as Forres was concerned was said to be based on the lack of viable space to widen the existing roadway as a result of the Constraints imposed by inter alia 1) the course of the railway, 2) the need (sic) to have grade-separated junctions, and 3) the position of the football ground. As to the first such Constraint, the developers did not at that time appear to have taken into account the fact that the railway station was already in the process of being moved a significant distance to the North, thus widening the available corridor at a critical point. As for the alleged Constraining need for grade-separated junctions, that need, whilst it may at some stage have been entered into the developers brief by Transport Scotland as a given, is not established, as a matter of technical requirement, by anything other than an engineering preference and an apparent election for a gold standard of road construction. Such standards are unnecessarily high, as the existing (and projected) traffic flows around Forres 12 are among the lowest of any town in the entire A96 corridor. 12 Source: T2SEAR Appx J Air matrix: AADT 11-13,000 (2012); projected 20,800 to 22,100 by 2032 (if dualled) FAADAG Feedback August 2017 Page 6

7 FAADAG respectfully considers the Constraints noted in the Answers to FAQs 13 to be over-stated, and inaccurate. As regards the requirement for grade-separated junctions, FAADAG observes that the vastly more important (and far more heavily used) A9 survives and flourishes in many of its already dualled sections without the need for grade-separation at points of access to main urban locations. FAADAG would therefore invite a solution of rationalisation of the junctions proposed for Forres, as mentioned in the Answers to FAQs, rather than elimination of a very beneficial Option as a result of principled insistence on grade-separated junctions. It may be that some form of fly-over could assist in creating a suitable access point in association with the railway station, and some design concepts should be explored as part of a review of the new solution which is suggested below. If a degree of lateral carriage separation is absolutely essential, the existing bypass zone is wide enough to accommodate that; it already exists in part at the Western end of the bypass stretch. Where the zone is at its narrowest today, nearest to the soon-to-be-removed level crossing: on the North side, the movement of the railway since Option A was last considered offers the possibility of greater space North of the existing A96; on the South side, Forres Mechanics FC are on record 14 as saying that they are not averse to a relocation of their football ground to a more convenient location (the statement was made in the context of the failed Redco Milne development proposal). Space would not be an issue, if these issues were properly taken into account. FAADAG therefore urges a radical revisitation of the potential for using the existing by-pass zone (especially between the Greshop West and Tarras/Enterprise Park roundabouts) generally. 3: A NEW CONCEPT TO CONSIDER: A SINGLE INTEGRATED JUNCTION FAADAG recommends a fresh review be made of the potential benefits that could result from a new, integrated access junction based around the imminent realignment of the Inverness-Aberdeen railway and relocation of Forres railway station - developments that had not yet taken shape at the time of the last major review (T2SEAR). More specifically, given the significant change in the configuration of the railway station and the relocation of the line, creation of the main junction giving access to Forres at a location adjacent or directly accessible to the new railway station now offers an exciting opportunity. 13 By the Responses to FAQs issued after the 2014 consultation on T2SEAR, viz: The existing A96 single carriageway is highly constrained on both sides through Forres. The constraints include residential properties, industrial estates, the football ground and the Aberdeen to Inverness Railway line all in close proximity to the road, severely limiting the available width to widen the road to dual carriageway and accommodate any required junctions. The existing at-grade junctions, roundabouts and accesses would be required to be upgraded to grade separated junctions and / or rationalised in accordance with the proposed Junction Strategy. To avoid these significant constraints, it was assessed that an offline bypass to the north or south of Forres would be required FAADAG Feedback August 2017 Page 7

8 Such a development would be a significant improvement for Forres. It would be in closer proximity to the town than the current proposals, which would have a positive economic effect, as research 15 indicates that the greater the distance to the town from access junctions, the less likely passing traffic is to stop. It would utilise what is otherwise dead space in a brownfield site on the existing transport corridor. It would give more direct access to the town and to the old A96. It would give better access to the freight requirements of the Waterford and Greshop industrial estates. It would enable better transport integration with existing rail and bus routes. It could also include an access to the Waterford waste site which could resolve the dilemma of Waterford /Broom of Moy access. (see below re Waste Management). One junction would be cheaper than all the current proposals which envisage at least two junctions (three for Route Red). One junction would be less disruptive to traffic than two (or three). The green spaces that would otherwise be given over to large and noisy grade-separated junctions in open countryside on the Red and Blue Routes would be preserved and protected. Such an option would therefore meet not just one, but ALL of the Scheme Objectives: specifically, the Scheme Objectives referenced as items 1d and e,2a, 3a and b, 4, 5 and A new access junction to the North would incidentally give an opportunity to realign or eliminate the notoriously dangerous and inconveniently laid out Market Street/Waterford junction arrangement which is acknowledged by most Forres residents to be in need of revision and re-alignment/location in any event, regardless of which Route is selected. FAADAG now turns to consider the individual Key Topics of environmental impact listed in the 2017 Panels. 15 Cited in The Economic Evaluation of Town Bypasses Review of Literature (Bruno Parolin NSW University Aug 2011) at page 18: To improve the operation of the A96 and inter-urban connectivity through: d e -- Improved efficiency of freight movements along the transport corridor -- Reduced conflicts between local traffic and other traffic in urban areas and strategic journeys 2 To improve safety for motorised and Non- Motorised Users through: a -- Reduced accident rates and severity 3 To provide opportunities to grow the regional economies on the corridor through: a -- Improved access to the wider strategic transport network b -- Enhanced access to jobs and services 4 To facilitate active travel in the corridor 5 To facilitate integration with public transport facilities 6 To avoid significant environmental impacts and, where this is not possible, to minimise the environmental effect on: a -- The communities and people in the corridor b -- Natural and cultural heritage assets. FAADAG Feedback August 2017 Page 8

9 I Air quality traffic related changes at sensitive receptors (e.g. residential areas close to roads, schools, hospitals) Appendix J of T2SEAR 17 concluded that air pollutants would remain well within air quality objective levels for both Forres B North and Forres B South. No comparison, however, was made between these two alternatives in the context of the prevailing wind, which would carry such air pollution as was inevitable from a dualled Route Red/Blue over the main population centre of Forres, as well as creating increased pollution for sites adjacent to that Route. The remarks in the Air Quality section of Appendix J as between Forres B North and Forres B South are, surprisingly, identical. This assessment therefore fails to take into account the marked actual differences between the North and South of Forres, by ignoring the effect of air quality issues in and around the existing transport and industrial corridor, where odours from the sewage works and refuse site combine with exhaust fumes from the road to create a very different and negative quality along the corridor when compared to the pure air of the Southern routings. Confining any dualling to the existing transport and industrial corridor adjacent to the existing A96 and railway, by contrast, would confine the air quality management issues to that existing corridor. Such a routing would also skirt a number of other brown-field sites where air quality is already diminished by industrial activities such as the brewing, distilling, foodstuff and manufacturing processing on the Greshop and Waterford industrial estates. The relative and net effect of impaired air quality on such a routing, as against either Red/Blue or Purple would be greatly reduced. Route Red skirts areas of relative population density (Redcraig, Riverview Park, Mundole, Whiterow, Mannachie Braes, Wester Redhill, Rafford, Leanchoil Hospital, Cathay Care Home for example). Smaller settlements such as the Lawrencetons (on Route Blue) or Marcassie (on Route Red) are not large in terms of population density but are very sensitive in terms of their activity (see below). As rural areas, these sites adjacent to Route Red and Blue are of relatively greater sensitivity than those associated with the brown-field sites of the existing transport corridor. The examples given in the current consultation s descriptive Topic heading of sensitive receptors (residential areas close to roads, schools, hospitals) in respect of Air Quality fails to include in such a classification of sensitivity a number of other sites. The important areas of Community Woodland (Sanquhar Woods, Council Wood, Muiry Wood and New Forres Wood), whilst not areas of residency, are clearly sensitive areas in relation to noise, and visual issues, as well as air quality. All of these woodlands, together with the Chapelton Moss wetlands and bird hide, the Dava Way, Dallas Dhu historic distillery and the Forres Angling Association s key pools at Stony and Redcraig are important and sensitive leisure and amenity locations for the whole population of Forres. They would all be negatively impacted by air quality deterioration associated with a Southern Route. 17 References herein to the T2 SEAR Option Assessment matrices are to Appendix J to the Report. FAADAG Feedback August 2017 Page 9

10 Route Red would also adversely impact the Knockomie Country House Hotel, which must be considered as a sensitive receptor alongside schools, hospitals and the like. The equestrian centres of Mundole and Burgie should also, for these purposes, be considered sensitive receptors, and indeed deserving of specific consideration in their own right, given their local/national importance as leisure and activity centres. Califer Hill viewpoint is likewise a sensitive receptor given its unique role as a tourist attraction as well as a memorial garden. (Whilst the existence and importance of these locations is raised here in the context of Air quality and what is considered sensitive, see also the further remarks below in relation to all of these areas as regards issues of Biodiversity and Nature Conservation, Landscape, and Population and Health). II Noise and vibration 18 traffic related changes at sensitive receptors (e.g. residential properties, schools, hospitals) The comments above as regards the categorisation of all the listed additional sites as sensitive receptors apply equally, and indeed arguably with greater force, as regards the issue of Noise and vibration. Many of the comments that follow are also applicable not only to the issue of Noise and vibration alone, but are equally pertinent to an analysis and feedback on the effects of the proposed routings in respect of Key Topics III People and communities, IV Policy and plans, and VII Landscape and visual. Efforts to avoid undue repetition will be made in the remainder of this paper, but a degree of overlap is inevitable. Noise being perhaps the most perceptible and pervasive impact of a fast dualled roadway on human receptors, this paper will treat the feedback given by FAADAG correspondents from the perspective of Noise in this section in detail. The Red Route skirts, and so will adversely impact not only visually, but much more importantly through Noise - a series of currently peaceful and quiet residential and leisure sites, including: - Newton of Dalvey residential site - River Findhorn walks - The Forres Angling Association huts at Stony/Redcraig - Darnaway woodlands and river walks - Redcraig residential development - Riverview Park housing and caravan parks - Mundole caravan site - Mundole stables, equestrian centre and riding tracks 18 This item was NOT one of the Topics considered at the Tier 2 Strategic Environmental Assessment. It is a welcome addition, however there is a complete absence of published data or evaluated matrices to enable a comparison of the proposed Routes. FAADAG Feedback August 2017 Page 10

11 - Limekilns woodland walks - the North end of the Findhorn gorge and SSSI - Balnageith residential area - Whiterow residential area - the Knockomie Country Inn - the Balnaferry-Knockomie Braes-Mannachie Springfield housing developments - new housing at Fairy Hills Wood - Altyre estate (whose redevelopment plans, both independently, at Dallas Dhu, and those under development within the estate generally in association with the Glasgow School of Art, would be severely impacted by a Red Route) - Glasgow School of Art s new campus at Altyre - Dallas Dhu historic distillery - Dallas Dhu listed buildings - Loch of Blairs walks - the Manachy Burn - the Dava Way (a Core Path) - Altyre woodlands - Sanquhar Mains farm - the Altyre/Mosset Burn - residential developments in Stoneyford, Wester Redhill, Marcassie and Chapeltonmoss - Chapeltonmoss walks, wetlands and bird-hide - Chapelton and St Leonard s Road housing - Rafford, especially the northern or lower part of the village - Marcassie and Rafford Burns - Rafford Church Leanchoil Hospital and (especially) Cathay Care Home would be impacted by noise from a Red (and Blue) Route. The Constraint of a gas pipeline near Cathay is a major issue. The bend in the Red Route, after Newton of Dalvey, whether becoming R2 or R3, is also extremely close to the Northern part of the Findhorn Gorge/Darnaway SSSI, which, involving higher ground than the East bank of the river, would be visually and aurally impacted by the Red Route R2/R3. In contrast, any routing that tracks the existing noise (and pollution) corridor of the railway and current A96 road would skirt a series of brownfield industrial and commercial sites, including: - the Inverness to Aberdeen Railway line - Greshop Industrial Estate - Forres Railway Station (extant and planned) - Waterford Industrial Estate - Benromach working distillery - Forres Sewage Works - the main pylon line - the soon to be old A96 - the residue of the removal of the railway to the North of the existing line FAADAG Feedback August 2017 Page 11

12 The prevailing wind direction (from the South West) presently carries noise (and air pollution) from the existing A96 to the North, over these brown-field sites, and away from the populated areas of the town. Both options for the Red Route (R2 and R3) would bring significant parts of the residential areas of Forres, including those areas which have recently been released by Moray Council as development zones for future housing 19, into areas that would be adversely impacted by air pollution and noise. Situating the new road to the South via the Red Route would mean that the prevailing winds would carry the noise and air pollution over the town of Forres, especially over the new housing developments to the South West, and the designated parks, Community Woodlands and wetlands at the Eastern end of the Red Route. Confining such effects to the existing Northern transport and industrial corridor (current A96, industrial estates, distillery, sewage works and railway) would seem to be more sensible and consistent with Scheme Objective 6. The impact of the prevailing winds of the Red Route is clear from the plan below, in terms of both Air Quality and Noise: However, in terms of Noise, the wind direction is not determinative; the net increase in noise levels will be very significant indeed on all but the extreme Western section of the Red Route (R1, which is already affected by the existing A96 and railway). 19 See also notes below re Planning considerations FAADAG Feedback August 2017 Page 12

13 Current noise levels on the Southern and Eastern sections of the Red Route (R2, R3, R4) are very low indeed, particularly when compared to the flatter, industrialised Northern transport and industrial corridor, which already is affected by noise from the existing A96, the railway, the industrial estates, and the Waterford recycling centre. The Design Manual for Roads and Bridges refers to the consideration of traffic related changes at sensitive receptors in air quality, noise and vibration. The blue line in the diagram above denotes the existing line of traffic and rail noise, and highlights the significant changes that would arise if the Red Route were selected. It is worth noting that, as the railway would continue in its current course, and the old A96 would remain an important access to the industrial and employment sites to the north of the town, Noise would not simply disappear from the North of the town; the area of the existing transport corridor would not become an alternative haven of peace and quiet by reason of a Southerly routing of the dualled A96. The human health impact of removing the A96 from its current corridor, doubling its width and traffic flows, and running it through hitherto peaceful rural areas has not been properly assessed nor costed in any of the studies undertaken to date that have been published to the residents of Forres. Noise is however regarded as perhaps the most significant irritant of modern living. The only published material currently made available to residents in terms of comparative or indeed any - environmental impact is the Tier 2 Strategic Environmental Assessment Report. The T2 SEAR failed completely to take into account Noise as a relevant criterion in its evaluation of the Options - which had included Option A, the routing that followed exactly the route of the existing A96. Noise is however one of the most relevant and important criteria for Route and Option assessment. FAADAG considers that it should be a factor for comparison and selection of currently proposed Routes, not merely a matter for mitigation after selection has occurred. Although (through the emergence in June 2017 of Route Orange) a further Option has effectively been introduced, no relevant matrices comparing Route Orange and Routes Red/Blue and Purple have been published in the context of the 2017 Consultation. (cf. T2 SEAR Appendix J). Route Orange does not appear to fit naturally within the scope of the original Forres B North proposal in the form that it was considered in detail in T2 SEAR its description and the mapped course of the Forres B North Option is more redolent of the current Route Purple. There appears therefore to be a failure properly to evaluate the environmental impact of Route Orange in comparison to other alternatives to the same extent that was undertaken at Tier 2. The public is being asked for feedback on Routes which have not been the subject of any published comparative Assessment. The earlier Assessment of similar routes appears to be flawed in multiple respects as noted elsewhere in this paper. These failures are especially egregious as regards the issue of Noise. FAADAG Feedback August 2017 Page 13

14 Noise is of significant concern across Europe. Those areas which have the highest level of quietness are limited both at European and at United Kingdom levels, as can be seen from the map 20 below, published by the European Environment Agency in Such quiet areas of which the North of Scotland has more than any part of the UK - therefore become even more precious and requiring of safeguarding. The Noise in Europe 2014 Report from which the map above is taken begins: Noise pollution is a growing environmental concern. It is caused by a varied number of sources and is widely present not only in the busiest urban environments; it is also pervading once natural environments. The adverse effects can be found in the well-being of exposed human populations, in the health and distribution of wildlife on the land and in the sea, in the abilities of our children to learn properly at school and in the high economic price society must pay because of noise pollution. The European soundscape is under threat. The Report s conclusion includes the following: What we do know is that noise is one of the most pervasive pollutants in Europe and that drivers such as economic growth, expanding urbanisation, more extensive transport networks and increased industrial output will present challenges to protecting the quality of the European soundscape. 20 Noise in Europe report 2014 available at FAADAG Feedback August 2017 Page 14

15 Increased pressures impact upon our ability to protect our own health and the health of sensitive populations such as the young, the immobile and those living in deprived areas, which may well be at most risk from the adverse health effects associated with noise. The health of our ecosystems is also at risk. The noise maps of Europe reveal graphically how the extent of even relatively moderate levels of noise such as 55 db L den are consuming more and more territorial area outside of urban areas and directly threatening valuable habitats and species that are particularly susceptible to noise. It is clear from END data and citizen ratings that noise from road traffic is the most dominant threat, both due to its geographical extent and by the numbers of people it affects. Article 1 of the European Noise Directive 21 (the END ) refers to the need for preserving environmental noise quality where it is good. Environment Protection Scotland (EPS) has issued guidance, written in May 2014, on the Good Practice Guide to Quiet Areas. EPS note that: The END states that Member States shall also aim to protect quiet areas against an increase in noise, however how they define a quiet area is left up to each Member State. In support of this, the European Environment Agency has published its Good Practice Guide on Quiet Areas 22. EPS guidance explains that: In Scotland, the decision was taken that quiet areas should be defined as areas which are a minimum of 9 hectares and in which at least 75% of the area is subject to noise levels not exceeding <55dB Lday. Scotland has yet to define formally any quiet areas in the countryside ; but simply because that has not yet been done does not mean that the underlying legal and policy requirement of the Directive, namely to aim to protect quiet areas against an increase in noise can be ignored, as appears to have been the case in the A96 dualling studies carried out to date. A report to DEFRA in November states that: Environmental noise is a pervasive issue across the UK and internationally. In 2011 the Burden of Disease from Environmental Noise by World Health Organisation (WHO) identified environmental noise as the second largest environmental risk to public health across Western Europe. Furthermore it suggested that noise exposure is increasing across Europe The report went on: 21 Directive 2002/49/EC Report for DEFRA Environmental Noise: Valuing impacts on: sleep disturbance, annoyance, hypertension, productivity and quiet. November environmental-noisevaluing-imapcts-pb14227.pdf FAADAG Feedback August 2017 Page 15

16 One of the key findings in the literature review was that quiet is inextricably linked with overall perceptions of the quality of the area in which it is present, which is why it was necessary to use a more subjective definition of quiet for the purpose of this project, with the following criteria: natural sounds are audible and not masked by manmade sounds, and for relative quiet, the area must be noticeably less noisy than its immediate surroundings. The potential use of the area must also be considered, so the area must be one which users choose to visit due to its quiet nature, and an area that is used for quiet activities such as reading, strolling, meditation or reflection. The literature review established several important benefits of quiet which can play a role in improving well-being, these benefits included improved creativity, problem solving, mental health, concentration and undisturbed sleep. These benefits were in addition to the benefits associated with avoiding the negative costs of noise, which include savings in healthcare costs and increased worker productivity. Furthermore, quiet adds value to properties (as people generally prefer to have access to quiet areas), and provides benefits to the wider community. Preservation of quiet cannot be achieved by after the event (of decision-making and Route selection) mitigation ; it needs to be a part of the comparative assessment of all of the Route options at a selective stage. Leaving it, as in the papers published in 2014, to be a merely mitigatory appendix to the decisionmaking process is quite inappropriate. There is currently sound mapping available for only part of the proposed routes for the A96, as can be seen from the table below, extracted from the Scottish Noise Mapping website. The mapping does not grade noise levels below 55dB. Whilst the entirety of the Orange Route appears to be subject to noise levels of up to 55 db already, the settlements along Route Red (and Blue): Riverview Park, Mundole, Stonyford, Altyre, Wester Redhill, Rafford, the Lawrencetons and Burgie are well known to be particularly quiet, tranquil areas even within the relatively high quality context of the local soundscape. The mapping also reveals areas close to the existing A96 which are FAADAG Feedback August 2017 Page 16

17 already subject to noise levels of between 55dB and 65dB, and even higher noise levels than these could be expected in many parts of the tranquil areas listed above if the Red and/or Blue Routes are adopted. Had Scotland moved forward by now with the creation of formal quiet areas in open countryside as defined in the END, there is every reason to expect that all of these areas would qualify, and on that basis the current proposal of a Red and/or Blue Routing would be simply out of the question. What is also notable from the existing sound-mapping information is that: - the impact of road noise spreads across a much wider area in open countryside than in urban areas - the soundscape is not much quieter at night - faster stretches of road have higher sound levels. For example the A9 dualled stretch of road north of Inverness has a higher db level than is currently seen on the single carriage A96. Noise also increases where there are climbs, so any route that includes any form of gradient will inevitably be noisier than one that is flat, all other things being equal. Route Orange is essentially all across flat land; Route Red and its derivative Blue would involve a series of gradients, thus a significantly increased noise profile. To take decisions which would change the profile of noise for the people of Forres and the surrounding area without assessing that change s impact on their wellbeing, and their ability to access a peaceful environment, with all the well-recognised benefits that entails, involves a failure to assess the impact of the proposed Routes correctly. The response that was issued by way of Answers to FAQs raised by respondents to the then request for feedback, in September 2015 referred to the mitigation of Noise being in the nature of bunds or fencing, in keeping with the local environment. In the local environment around Forres the majority of fences are post and wire stock fences, which would not provide any form of mitigation of Noise. Earth bunds are recognised as being more effective than, say, concrete bunds, as earth absorbs sound waves, while hard surfaces such as concrete merely reflect them. That said, the design of such berms must take account of the local conditions, height of vehicles, and gradients of the hills, to be effective. Each route would offer different issues in relation to size, location and effectiveness of noise walls, and have different costs. These would impact the overall financial and environment cost of each route. They should for this reason also form part of a selective process, not merely mitigation of the final choice. Such bunds also impact the travelling experience of road users. No apparent attention has been given to the relative and viable measures that would be required as between the various Routes now proposed, nor to the existing soundscape which they would be seeking to preserve. Mitigation measures, as for the underlying issue of Noise, ought to be considered as an integral part of the selection and key decision making process, and should not be left to mere sweeping up after the final decision s effects, once taken. The 2017 consultation lists as a Scheme Objective: (6) To avoid significant environmental impacts and, where this is not possible, to minimise the environmental effect on: the communities and people FAADAG Feedback August 2017 Page 17

18 in the corridor (emphasis ours). It is clearly possible to avoid significant impacts on residents on Routes Red, Blue and Purple - by a selection of a Route that follows the existing transport corridor. Better still: revert to Option A, and a simple enhancement of the existing A96. Rafford Village, and the contiguous areas of Marcassie, Redhill, Wester Redhill (between Rafford s northern agglomeration and the Dava Way) and Stoneyford form part of a community which would be significantly affected by traffic noise in the event of the selection of Route Red. The same holds true for the Lawrencetons and Burgie, on Route Blue. Any Forres estate agent (and any resident of an IV 36 post-code) will tell you that the predominantly residential properties that lie to the South of Forres consciously situated away from the existing, noisy, A96, and often shielded from the urban overspill of light and noise pollution by woodlands depend very substantially on the quiet, rural, character of the area for the enhanced character and value of the properties in question. That amenity is a major contributor to the value of the assets in the affected area, as well as to the quality of life of the receptors in that area. The marketing literature of Riverview Park 24, (at Grid NJ012571) for example, refers in particular to it being a quiet, idyllic park setting a beautiful residential park set in tranquil Scottish surroundings. There has been a deliberate expansion of residential housing opportunities on the South side of Forres, in the arc from Redcraigs through Knockomie and Rafford over a number of decades. Further releases and schemes have been published in the Balnaferry/Mannachie/Dallas Dhu area since the last public consultation. Plans by local land-owners to engage with the newly established Glasgow School of Arts in regenerating Altyre Estate are also significant at both macro (Forres and area) and local (Altyre) level. The Southern aspect of Forres would be affected for the first time by traffic noise emanating from Route Red and/or Blue, and, unlike the existing transport corridor, is almost exclusively populated by properties that are residential. Furthermore, the relative age demographic of the Route Red Output Areas according to the 2011 Census 25 is that of an elder, retiree population, many of whom will have chosen to retire to the area, and settled deliberately on the quieter, Southern, side of Forres specifically because of its quiet, rural, character, away from the existing A96, railway and industrial zones to the North of the town. According to the 2011 Census for the Rafford Output Area (S ), for example, the retiree population was 34%, more than twice the national average. Certain areas of the Riverview Park development are also restricted to the over-50s as residents. The effect on a community with over twice the national percentage of retired citizens, who would be subject to a far greater disturbance to life, health and amenity due to a major trunk road, is Census Output Areas S , -767, -665 and -222 FAADAG Feedback August 2017 Page 18

19 proportionately higher than the effect on younger, more mobile populations, who are more likely, at the road s busiest times, to be out at work rather than out in the garden. The reasonable expectation of, and impact of routing on, people who have settled within the existing transport and industrial corridor will be quite different from those of the Route Red zones of Redcraig, Mundole, Altyre, Balnaferry, Manachie, Stoneyford, Wester Redhill, Marcassie, Rafford and Blervie. Settlements adjacent to the existing transport and industrial corridor are already substantially negatively affected in terms of their relative amenity value by: the existing A96 traffic, the railway, the industrial estates and sites on the North side of the town, the sewage works, the waste disposal site, and the electricity power lines. The airfield at Kinloss, whose approach flight path overflies all of the Northern Options, is at present not used to its full extent; but were flights to be resumed, a further Noise generation source would be added back to that area. The Red Routes (and their dependent Blue) are presently targeted directly through what are, on any reasonably objective evaluation, quiet areas in open country. Traffic noise, as any estate agent or resident of an area adjacent to a major trunk road will affirm, is a very significant consideration in both the financial valuation of a residential property and the quality of life associated with living there. An urban flat may be rendered quieter by triple glazing. That option is not available for a rural garden. Traffic noise has been confirmed to represent for the ordinary citizen of the UK the most annoying form of all noise, in research made on behalf of the UK Government 26. It is increasingly associated with poor health issues 27. The EU Directive has set a fair standard for protection of the peace and quiet of the countryside. The dilution of that protection in the Regulations does not oblige the developers to take the line of least resistance; a proper evaluation of how to avoid the environmental impact of Noise ought to regard peace and quiet as assets to be protected, not only in the interests of the residents, but to enhance the quality of life and tourism in the Moray area. III People and communities Reference has been made above to the relative impact of the Southern Routes when compared to a routing that followed the existing transport and industrial corridor. Specifically in relation to this Topic, FAADAG would emphasise, especially the retiree predominance in the South of the town as described above. New investment in housing and the development of imaginative schemes to enhance and improve the amenity and leisure potential of the Southern areas is evident in the growth of new communities 26 A report published by the Health Protection Agency on behalf of an ad hoc Expert Group on the Effects of Environmental Noise on Health eb_c/ ibid. FAADAG Feedback August 2017 Page 19