THE NORTH SOMERSET COUNCIL (SOUTH BRISTOL LINK CLASSIFIED ROAD) SIDE ROADS ORDER 2013

NSC/1/1 THE NORTH SOMERSET COUNCIL (SOUTH BRISTOL LINK CLASSIFIED ROAD) SIDE ROADS ORDER 2013 THE NORTH SOMERSET COUNCIL (SOUTH BRISTOL LINK) COMPULSORY PURCHASE ORDER 2013 THE NORTH SOMERSET COUNCIL (SOUTH BRISTOL LINK) COMPULSORY PURCHASE ORDER (No 2) 2014 EXCHANGE LAND CERTIFICATES IN RESPECT OF SPECIAL CATEGORY LAND Proof of Evidence of Karuna Tharmananthar North Somerset Council On behalf of in respect of the Overarching Case

!i,, Contents 1. INTRODUCTION................................. 1 1.1. Personal details... 1 1.2. Experience... 1 1.3. Scope of Evidence... 2 2. SCHEME AUTHORiSATION...2 3. SCHEME CONTEXT................................. 3 3.2. National... 3 3.3. local.................................. 4 3.5. Planning Policy........................... 6 3.6. local Transport Plans and Strategies........................ 6 3.7. Joint local Transport Plan 3...7 3.8. MetroBus Programme........................ 7 3.9. North Fringe to Hengrove Park........................ 7 3.10. Ashton Vale to Temple Meads... 8 4. SCHEME OBJECTiVES...9 5. ORIGINS OF THE SCHEME.......................... 11 5.11. Scheme Description... 13 5.12. Planning Consent........................... 14 5.13. Discharge of Conditions... 14 6. CONSULTATION...15 6.3. Pre-planning application consultation... 15 7. DELiVERy... 17 7.1. Budget........................:... 17 7.2. Procurement and construction... 17 8. JUSTIFICATION FOR COMPULSORY PURCHASE... 18 9. OBJECTIONS.............................. 21 10. CONCLUSiONS... 24 APPENDIX 1 APPENDIX 2 APPENDIX 3 APPENDIX 4 APPENDIX 5 APPENDIX 6 APPENDIX 7 APPENDIX 8A APPENDIX 8B Scheme outline and local Authority Boundary West of England Transport Investment Programme MetroBus Network Programme A VTM variants from the TWAO approval A VTM - SBl interface SBl route options Scheme cost estimate Funding Confirmation from NSC Funding Confirmation from BCC

1. INTRODUCTION 1.1. Personal details 1.1.1. My name is Karuna Tharmananthar. I have been employed by North Somerset Council since 2002 and am the Deputy Director for Development and Environment. My responsibility is to secure economic growth and prosperity for North Somerset. As part of this I have responsibility for Economic Development, Development Management, Strategic Planning and Highways and Transport Services. i am the Senior Responsible Officer for South Bristol Link (the Scheme) acting on behalf of Bristol City and North Somerset Councils. 1.1.2. i hold a BSc Honours degree in Engineering, MSc in Transportation and a Masters degree in Business Administration. i am a Chartered Engineer and a Member of the Institution of Civil Engineers. 1.2. Experience 1.2.1. I have extensive experience in the development and delivery of major infrastructure programmes to help support economic growth and regeneration. For example, while at Birmingham City Council, to enable the expansion of the city centre, i was responsible for delivering the supporting infrastructure for the Bull Ring development and the wider Eastside regeneration project, development of the street running Metro and the remodelling of the highway network. 1.2.2. At North Somerset Council, i have led the delivery of the 30M sea defence scheme at Weston-super-Mare to help support its regeneration and the development and delivery of the Weston Package scheme to help support jobs and growth at the J21 Enterprise Area, accompanied by a wider economic strategy to attract investment to North Somerset. 1.2.3. I work closely with the West of England Local Enterprise Partnership Board to develop its programme and strategies in support of its aim of creating the right conditions for economic growth. This includes the development of the revolving infrastructure fund programme estimated at 55m, the City Deal programme which encompasses a wide range of economic interventions to deliver growth and jobs in 1

the West of England and more recently the development of the Strategic Economic Plan for the West of England area. /1 1.3. Scope of Evidence 1.3.1. This proof of evidence sets out the authorisation for the Scheme, the strategic case for the Scheme in the context of national and local policies and it outlines why investment in the Scheme is justified. It looks at the Scheme's origins and objectives and consultation exercises undertaken at various stages. It also sets out the Scheme's readiness for delivery and justification as well as dealing with relevant issues raised by objectors in respect of the Scheme. 1.3.2. I hereby declare that insofar as the contents of this proof of evidence are matters within my knowledge and they are true. Insofar as far as matters not within my direct knowledge, they are true to the best of my knowledge and belief and are drawn from documentation and information to which i have had access. 2. SCHEME AUTHORISATION 2.1. The Scheme is part of a wider package of improvements covering Bath and North East Somerset, Bristol City, North Somerset and South Gloucestershire and these areas make up the West of England. 2.2. The Scheme falls within the administrative boundaries of both Bristol City Council (BCC) and North Somerset Council (NSC) and the Councils discharge their highway authority powers within their respective boundaries as shown in Appendix 1. 2.3. NSC and BCC entered into a Joint Promotion Agreement (JPA - CD2/28) on 8 January 2013 for the purposes of delivering the Scheme. This Agreement incorporates section 8 of the Highways Act 1980 under which it was agreed that NSC would undertake the role of Lead Authority for the Scheme and progress it on behalf of both NSC and BCC. 2.4. On 5 February 2013, NSC authorised the making of a CPO, SRO and section 19 certificate applications on behalf of both NSC and BCC. 2.5. Although not strictly necessary (given the JPA and NSC 5 February 2013 resolution) it was considered appropriate for the Scheme to be presented to the 2

recently elected Mayor of Bristol in order to obtain his endorsement. Therefore on 29 May 2013 a report was presented to the Mayor who approved the making of the CPO, SRO and section 19 Certificate applications (CD2I25). 2.6. On 3 September NSC further authorised the making of the CPO in relation Scheme (CD2/24). to the 2.7. On 7 November 2013 NSC granted planning consent for the Scheme. On 18 December 2013 BCC granted planning consent for the Scheme. 2.8. As a result of a number of issues which arose following discussions with landowners, it was considered necessary to make a supplemental CPO. This was authorised by NSC on 15 April 2014 and was made on 6 May (CD1/8). 3. SCHEME CONTEXT 3.1. The planning policy framework and the details concerning how the Scheme complies with relevant policy tests are set out in Janette Shaw's proof of evidence. In my proof i have outlined the overarching national and local context for supporting the Scheme and its stated objectives. 3.2. National 3.2.1. In 2013 Department for Transport published "Transport - an engine for growth" (CD2I18), in which the Government's investment approach for transport in the United Kingdom is explained. The publication is unequivocal in stating the importance of the strategic role transport plays in supporting economic growth and supporting the UK's global economic competitiveness. In promoting a comprehensive investment strategy the Government expects investment in the transport network to be targeted to ensure it has the most impact in terms of reliving congestion, unlocking growth and encouraging development to come forward. 3.2.2. The National Infrastructure Plan published in December 2013 (CD2/16 at pages 13 and 16) continues to emphasise the need to focus on infrastructure delivery and reinforces the critical role infrastructure plays in a modern, successful and competitive economy and states the importance of an "integrated transport system that provides reliable, cost effective domestic and international connections for organisations and individuals". The Plan notes that a 2006 study of the UK 3

transport system by Sir Rod Eddington warned that the cost of congestion could potentially rise to 36 billion per annum by 2025 (The Eddington Transport Study, Sir Rod Eddington, December 2006:CD7/3). /1 3.2.3. Janette Shaw, in her proof of evidence, demonstrates that the delivery of the Scheme would be consistent with the policies set out in the National Planning Policy Framework. 3.3. Local 3.3.1. The Scheme is incorporated in policies of both North Somerset Council and Bristol City Council, North Somerset Core Strategy (CD2/8) Policy CS10: Transportation and movement identifies it as a major transport scheme. Bristol City Core Strategy (CD217) Policy BCS 10 sets out clear support for the Scheme alongside other improvements to transport infrastructure, in order to provide an integrated transport system which improves accessibility within Bristol and supports growth. 3.3.2. The West of England Local Enterprise Partnership has produced the West of England Strategic Economic Plan (CD7/2) which identifies infrastructure as part of its "levers of growth" and recognises the need to improve connectivity and accessibility for business and communities. The SEP (at paragraph 5.2.5) reiterates the importance of transport investment and states that "our programme of transport schemes will unlock 20,000 jobs and generate 1.2b in GVA per annum by 2030' and identifies 244 million of existing major transport investment. 3.3.3. The overwhelming policy case for investment in the Scheme is underlined by support from the local businesses in the area. In his proof of evidence on economic benefits Mr liias Drivylas sets out the views of local businesses whereby improvements in transport connectivity is seen as vital in supporting economic growth and attracting investment to the area and that the employment to be unlocked by the Scheme would bring additional estimated 199m GVA to the West of England economy by 2030. 3.4. Investment Programme 4

3.4.1. A number of transport schemes are included within the SEP to help deliver economic growth in the West of England and the programme of investment is shown in Appendix 2. These are summarised below. 3.4.2. Bath Transportation Package - 26.9m investment in transport infrastructure tackling the city's current and future traffic problems and supporting economic growth, including 9,000 new jobs in the Bath 'City Riverside' Enterprise Area. Construction completed in 2014. 3.4.3. Weston Package - 14m investment opening up the J21 Enterprise Area and its ambition to deliver 11,000 jobs, with schemes for cars, motorcycles, bus and rail passengers, cyclists and pedestrians. Construction completed in March 2014. 3.4.4. MetroBus - 179m investment in three rapid transit routes (Ashton Vale to Bristol Temple Meads, North Fringe to Hengrove Package and the South Bristol Link) delivering a network of high quality, modern, reliable, fast, 'smartcard' enabled, integrated, low carbon and easy to use services. MetroBus will serve the Temple Quarter Enterprise Zone (17,000 jobs), South Bristol employment area (10,000 jobs), Emersons Green/Science Park (7,000 jobs) and Filton/A38 Enterprise Areas (12,000 jobs). It will also link new housing areas and address congestion hot spots with programmed completions taking place in 2017. As part of the integrated approach to managing transport demand and providing capacity to address economic growth, the SEP proposes investment in rail including: i - MetroWest Phase 1 - improvements to achieve an half hourly train services for the Severn Beach Line, additional local stations between Bristol Temple Meads and Bath Spa, Weston-super-Mare and on the reopened Portishead Line (programmed to open in 2019). ii - MetroWest Phase 2 - improvements to achieve an half hourly train services to Yate and hourly services on a reopened Henbury line with additional stations (programmed to open in 2021). 3.4.5. The West of England authorities were awarded 24m of funding in June 2012 for the Sustainable Travel (WEST) project. This supports minor schemes and working with partner organisations to improve sustainable travel choices. 5

3.4.6. The comprehensive transport investment programme builds on the track record of success in delivering the JL TP. 3.4.7. In addition to schemes being promoted by West of England, Network Rail is also promoting a significant series of enhancements to the Great Western Mainline between London Paddington and Bristol (via Bath Spa and Bristol Parkway). These enhancements include electrification of the railway from London to Bristol by 2017, the introduction of new rolling stock (Inter City Express) starting in 2018 and improvements to Bristol Temple Meads station. 3.4.8. Bristol Airport and the Port of Bristol constitute key transport interfaces in terms of the area's connectivity to wider national and international markets. Bristol Airport continues to grow with passenger numbers up by 3.4% in 2013 compared to previous years. The Port of Bristol is an international gateway. The Port has key advantages including a deep-water container ship capacity and located strategically with a large population catchment. 3.4.9. The context for justifying investment in the Scheme is strong and fits well with national and local thinking on interventions and infrastructure investment to support economic growth. 3.5. Planning Policy 3.5.1. The adopted plans of both Bristol City and North Somerset Councils provide clear policy framework for the Scheme. The North Somerset Council SBL Planning Committee report in its Overall Conclusion acknowledged that "although the proposal runs through the Green Belt its alignment has been agreed through the local plan process and known for some years"- (CD2/31 at page 35). 3.5.2. Janette Shaw's proof of evidence supporting the planning case demonstrates the Scheme is not regarded as inappropriate development and does not conflict with the fundamental purposes of the Green Belt as set out in national guidance. 3.5.3. This is consistent with the approach of the Councils when the Scheme was granted planning permission in 2013. 3.6. Local Transport Plans and Strategies 6

ti 3.6.1. Robert Thompson's proof of evidence on transport issues sets out in detail the transport and economic appraisals underpinning the justification for investing in the Scheme. I have outlined in the paragraphs below the overall transport policies and programmes supporting the Scheme. 3.6.2. The first Joint Local Transport Plan was adopted by the four Unitary Authorities covering the West of England in 2006 for the period 2006-11 (CD3/1). Its focus was to tackle (through policies and programmes) congestion, improving road safety, increasing accessibility and enhancing quality of life. The interventions set out in the first JL TP continue to provide the basis for current programmes. The programme contained in the JL TP provided a balanced and sustainable set of interventions and included the Greater Bristol Bus Network major scheme programme, new expanded park and ride services, rail improvements at Bristol Parkway and Worle, consistent parking controls and promoting public transport, travel plans, car sharing, cycling and walking 3.7. Joint Local Transport Plan 3 3.7.1. The current Joint Local Transport Plan published in March 2011 following its adoption by each of the four West of England Authorities sets out the vision for the sub region's transport network to 2026. This is for "an affordable, low carbon, accessible, integrated, efficient and reliable transport network to achieve a more competitive economy and better connected, more active and healthy communities'(cd3/2 page 5 paragraph 2.1.2). 3.8. MetroBus Programme 3.8.1. As explained the four Unitary Authorities are pursuing their transport strategies through a Joint Local Transport Plan. The Scheme is part of this strategy for improving the transport network and is an integral part of the MetroBus Programme. Ashton Vale to Temple Meads and North Fringe to Hengrove make up the other two critical elements. Appendix 3 shows the MetroBus network. 3.9. North Fringe to Hengrove Park 7

3.9.1. This project links Cribbs Causeway and Emersons Green to the north of Bristol with Hengrove Park in South Bristol via Bristol City Centre. The scheme is under development and at the stage of securing the relevant planning consents. 3.10. Ashton Vale to Temple Meads 3.10.1. This project connects the Park & Ride site at Long Ashton with Bristol Temple Meads. The project was granted planning permission as part of the confirmation of the Transport and Works Act Order in November 2013. In March 2014, following a review of the scheme by the Mayor, Bristol City Council granted planning consent for a modified section of the scheme thus allowing the amended scheme to be implemented. The scheme is expected to be completed in 2016. The A VTM route alignment is shown in Appendix 4. 3.10.2. The TWA consent for A VTM incorporated two options where it interfaced with South Bristol Link. The AVTM Board, at its meeting in February 2014, confirmed that the option outlined in the consented South Bristol Link design and as shown in Appendix 5 (route referenced 1A) will be taken forward for implementation. 3.10.3. AVTM represents a key part of a programme to provide high quality public transport services in the West of England. The Scheme links with the AVTM via its bus spur between the Brookgate junction and the Long Ashton Park and Ride site. 3.10.4. The combined AVTM and South Bristol Link route network enables public transport services, including the Bristol Airport Flyer, to take advantage of priority measures contained within both schemes to avoid congestion in the city centre and thus improve their reliability and efficiency. 3.10.5. It is proposed that every third service from Bristol Temple Meads to Long Ashton Park & Ride along the AVTM section of the MetroBus network will continue along to Hengrove Park using the SBL bus spur. A Quality Partnership Scheme (QPS) under the Transport Act 2000 as amended by the Transport Act 2008 will be used to set standards for MetroBus. 3.10.6. In assessing the effects of the Scheme on AVTM the Inspector for the TWAO Inquiry concluded that: 8

i - "return on the investment in the 'first phase' AVTM scheme would be much enhanced with the completion of the South Bristol Link and the North Fringe to Hengrove sections. These schemes would undoubtedly benefit from the shared use of infrastructure provided under the first phase. The completed network would significantly increase the opportunity for integration with other public transport services in the City thereby improving accessibility over a much wider area." (CD2/24 at paragraph 7.3.44) 4. SCHEME OBJECTIVES 4.1. The Scheme objectives are to facilitate regeneration and growth in South Bristol, reduce congestion in South Bristol and adjacent areas of North Somerset and to improve accessibility from South Bristol to the City Centre and to strategic transport links, including the trunk road network and Bristol International Airport. 4.2. The Scheme performs well against all of the above objectives and contributes towards wider economic growth ambitions of the West of England area. 4.3. Chapter 9 of the Environmental Statement accompanying the Scheme planning applications (CD4/2 - at paragraph 9.7.1) concluded that SBL is strategically aligned to local, sub-regional and national policies relating economic development and regeneration. It further states the Scheme will improve accessibility to employment, education, training, retail and make leisure opportunities more accessible to those in the South Bristol area. 4.4. The Multiple Deprivation index shows that much of South Bristol is amongst the 10% most deprived in the country and two areas are in the most deprived 1 %. This Scheme is a key component of an integrated package of measures to facilitate the creation of employment and to increase opportunities to jobs and services in South BristoL. The economic studies and engagement with businesses provide strong evidence that the Scheme will make a significant contribution towards regeneration and economic growth in South Bristol and this is set out in Ilias Drivylas' proof of evidence. 4.5. The local business community has made it clear that reduced congestion will help boost confidence and attract investment to the area. The underlying transport modelling analyses show that the Scheme improves journey times and network 9

resilience by reducing congestion in the surrounding networks and by providing an alternative strategic link between the A38 and A370. Robert Thompson in his proof of evidence provides details of the impact of the Scheme on the operation of the road network, on public transport users and on accessibility. 1 I 1'1 ~ 4.6. The Scheme will improve connectivity to one of the most deprived areas in the City. MetroBus and dedicated cycle and pedestrian provision will give greater transport choices for those who do not have access to a car or choose not to drive, which is pertinent to address the low levels of car ownership in the area. The improved transport links will support economic growth and accessibility to jobs and services for those living in South BristoL. In his evidence on Economic Impact, liias Drivylas, confirms the Scheme has the potential to unlock a large number of jobs in South BristoL. 4.7. There is an existing coach service between Bristol Airport and Bristol City Centre. The service, however, is subject to unreliability at peak times on congested urban roads. The Airport Flyer service would join the segregated section of the South Bristol Link at the A38 junction and travel into the City Centre via the bus-spur and Ashton Vale to Temple Meads route, gaining considerable improvements in journey time reliability. 4.8. These issues are encapsulated in the Bristol City Council South Bristol Link Planning Committee report which, in the key issues Section A - "Is the principle of SBL supported?" concludes: "...... the principle and proposed corridor of SBL is firmly supported by the development plan. The scheme is reflected in up to date policy and follows strategic reviews of the scheme leading to its inclusion in the West of England Joint Local Transport Plan in 2007. Underpinning the proposal is the access and economic benefits it will bring to south Bristol in particular but also to the wider sub region such as better access to the airport and the proposal being part of a wider network of transport infrastructure for the greater Bristol area. The challenges to the economic and transport benefits predictions by some objectors have to be weighed against the very strong policy basis, particularly acs 1 and acs 10 and the significant level of support for SBL from business organisations, individual businesses and some residents. It is considered, therefore that the principle of SaL 10

should be supported and very significant weight should be attached to this aspect of the assessment" (CD2/32 at page 48). 4.9. In considering the economic impact of the Scheme the report to North Somerset Council's Planning Committee concludes that: "...poor transport links and congestion are a barrier to growth and the construction of the SBL will improve connectivity, business opportunities and job creation. The absence of this transport improvement will pose a significant challenge to the growth of the area, increasing the cost to local businesses and affecting competitiveness. Overall the development is in accordance with the economic policy objectives of the Local Plan and Core Strategy" (CD2/31 at page 15). 5. ORIGINS OF THE SCHEME 5.1. The principles of the Scheme have been embedded in the development plan process and examined at relevant stages through detailed route options appraisal, environmental assessment and public consultation. Proposals for a route around south Bristol date back to the 1950s. Indeed, pre-dating that, when King Georges Road was built in the 1930s, the houses were set back to allow for a dualcarriageway to be constructed. The first emergence of a potential link road between Long Ashton and South Bristol in policy terms was identified in the former Avon County and Woodspring District development and local plans in the 1960s and '80s. Janette Shaw in her proof of evidence details the planning policy origins of the Scheme. 5.2. Since 1992, a number of studies have been carried out on a range of alternative routes. These include the Avon Ring Road Options Report, MVA 1992, which looked at alternative routes for the Avon Ring Road between the A4 at Hicks Gate and the A370 Long Ashton bypass. Seven alternatives were compared in terms of traffic and economics but no environmental appraisal was included in the report. 5.3. The Transport Plan for the Avon Area 1994-2013, produced by Avon County Council in 1995, proposed the South Bristol Ring Road for construction between 2004 and 2013. This was followed by the South Bristol Transport Study - Review of Schemes, Halcrow Fox 1997, which reviewed four schemes with safeguarded routes to identify if the safeguarding should be maintained. 11

5.4. The preparation of the A38 - A370 Link Road Study, JMP 2002, involved two 1/1 rounds of public consultation to examine eleven routes including a public transport option. Following consideration of the main alternative alignments, the report recommended the 'Orange Route', that ran between the A370 and the A38 close to Barrow Gurney, as the most appropriate to take -forward. A bid for funding was subsequently made to the DfT within the North Somerset Local Transport Plan. However, this was unsuccessful because it did not address wider strategic objectives. 5.5. As a consequence, the assessment of strategic transport objectives was taken forward as part of the West of England Joint Local Transport Plan in 2006 (CD3/1), informed by the Greater Bristol Strategic Transport Study (GBSTS: CD3/3), the details of which are contained in section 3 of Robert Thompson's proof of evidence, which had been commissioned by the former Government Office for the South West and prepared by Atkins in 2006. The GBSTS was a wide-ranging strategic transport study for Greater Bristol that aimed to produce an effective strategy to support the future development of the sub-region in the period up to 2031. The approach adopted by the study was to develop a strategy for public transport and demand management and only then to consider highway improvements. The proposed highway improvements included the A370 to A38 Link (termed SBL Phase 1) and A38 to A4 Hicks Gate (SBL Phases 2 and 3). 5.6. All phases were included in the programme of major transport schemes in the Joint Local Transport Plan in 2006. The South West Regional Assembly identified Phases 1 and 2 as regional priorities for implementation before 2016, through the Regional Funding Allocation (RFA). This priority was further confirmed by the publication of the second RFA, for construction between 2014 and 2017. 5.7. In October 2009 the Joint Transport Executive (CD2I30) considered the options for the Scheme as part of agreeing the next phase of scheme development. There were five options included in the public consultation undertaken between November 2008 and March 2009 and these are shown in Appendix 6. The route configurations included highway only, Rapid Transit only and highway and Rapid Transit combined. JTEC agreed that further assessment should be undertaken on those options for a combined highway and Rapid Transit link as the combined options provided the best fit against both national and local objectives. The 12

combined options were further appraised and Option 4 was then subject to further public consultation (CD4/2 Chapter 5 paragraphs 5.2.32-39 and CD4/3 at Section 3.02.02 paragraphs 3.1.56-57). /1 5.8. In March 2010, the authorities submitted a Major Scheme Business Case to the Department for Transport (CD3/4). This set out the business case for a scheme that included segregated bus rapid transit along its whole length. 5.9. In October 2010 DfT requested that promoters confirm they still wished to proceed with the funding application process and indicated that funding bids would need to be significantly reduced. In December 2010 the authorities duly confirmed their intention to submit a revised funding bid. 5.10. In September 2011 the authorities submitted a fully revised business case known as the BAFB (Best and Final Bid) for a scheme with a significantly reduced scope, however, without compromising the objectives of the scheme (CD3/5). In November 2011 DfT confirmed that their funding contribution was available (subject to conditions) for the construction of the South Bristol Link. With confirmed funding available from the local authorities and third parties the full funding package is now in place, as explained later in paragraph 7.1.3 of my proof of evidence. In conclusion the Scheme design as currently promoted has been shown to perform best against local and national objectives. A number of alternatives options, as explained in CD4/2 chapter 5 and in CD4/3 (the Options Appraisal Report), have been tested and this has included public transport, highway and demand management options, with the conclusion that the Scheme performs as the best alternative against the Scheme objectives. 5.11. Scheme Description 5.11.1. The Scheme comprises sections of new and realigned highway with a total of length of 4.5 kilometres from the A370 Long Ashton bypass within North Somerset to the A38 and onwards to the Cater Road roundabout within the Hartcliffe area of south BristoL. Realigned sections are at Highridge Green, King Georges Road and Whitchurch Lane. A Scheme plan is included as Appendix 1. 5.11.2. New junctions are proposed at the A370, Brookgate, A38, Highridge Green/Highridge Road, Queens Road and Hareclive Road. Bridges are provided 13

at Colliters Brook and Longmoore Brook. SBL crosses the Bristol to Taunton railway line using a new under bridge. /1 5.11.3. A bus spur connects the Scheme with the AVTM guided bus route, thus providing access to the City Centre. Dedicated bus lanes are provided between the Brookgate junction and the new A38 roundabout junction. New bus stops and shelters, and a continuous shared cycleway and footway are provided along the route corridor with links to existing dedicated networks. The benefits of an integrated approach to cycling provision and in particular the benefits of linking into Festival Way, which is part of Sustans' CONNECT 2 project and now provides an eight mile long path from the Create Centre in the Cumberland Basin to Millennium Park, Nailsea, were acknowledged in the AVTM Inspector's conclusions (CD2/4 - at paragraph 7.18.25). 5.12. Planning Consent 5.12.1. The Scheme was granted planning consent in November2013 by North Somerset Council (CD2I1) and Bristol City Council's Development Control (South and East) Committee granted planning consent for the Scheme in December 2013 (CD2/2). 5.12.2. The report to North Somerset Councils Area Committees in recommending approval acknowledges the development and evolution of the Scheme over a number of years and the extensive consultation exercises undertaken to seek the views of a range of stakeholders, including local residents (CD2I31 at page 35). Similarly the report to Bristol City Council Planning committee acknowledges the importance of the public consultation carried out and evaluation of alternatives through a number of studies (CD2/32 at pages 46-47). 5.13. Discharge of Conditions 5.13.1. A number of conditions were applied to the granting of planning permission for South Bristol Link by both North Somerset Council (38, along with 15 advice notes) and Bristol City Council (16 conditions and 4 advice notes). 5.13.2. The pre-commencement conditions imposed on the planning permissions are in the process of being discharged together with a programme of works to ensure timely discharge of the remainder 14

/1 6. CONSULTATION 6.1. Philip Paterson in his evidence demonstrates how the Scheme's design has responded to consultation and engagement with general public and key stakeholders. In addition Nick Rowson in his proof of evidence addresses in detail the consultation undertaken in selecting suitable exchange land for loss of open space at Highridge Common. I set out below the consultation undertaken in the development of the Scheme leading up to the grant of planning consent in 2013. 6.2. In addition to the public consultation and engagement exercises, there was also engagement with Statutory Authorities and individual land owners and those affected by the Scheme. John Yexley in his proof of evidence deals with the discussions which have taken place with landowners and objectors in an attempt to address their concerns. There are no objections to the Scheme from statutory environmental bodies. 6.3. Pre-planning application consultation 6.3.1. Public and Stakeholder Consultation November 2008 - March 2009: A programme of public and stakeholder consultation began in November 2008, which included a series of exhibitions and presentations, and the publication and distribution of a consultation leaflet, also available at consultation venues and via the West of England Partnership website. Throughout the consultation period, stakeholders and members of the public were invited to telephone, write or email with questions or comments about the proposal. Consultation was publicised on North Somerset Council, Bristol City Council and the West of England Partnership websites. Press releases were issued and articles published in Bristol Evening Post and local newsletters. This led to a Preferred Scheme. 6.3.2. Preferred Scheme Consultation: November 2009-31 December 2009: The Preferred Scheme formed the basis of an additional stage of public consultation from 1 November to 31 December 2009. This included public and stakeholder consultations, presentations and exhibitions held at three local venues on 2, 3 and 4 15

November (at Withywood Centre, Long Ashton Community Centre and Ashton Vale Youth Club). The consultation was publicised through the distribution of over 6,000 postcards to households in affected areas along with notices to local press and other media. 3,000 pamphlets and questionnaires were printed and distributed via local libraries, community centres and at the three public exhibitions. 6.3.3. Pre-application Consultation: May-June 2012: The methodology for the preapplication consultation strategy for SBL, prepared in April 2012 was shaped by the Statement of Community Involvement documents (SCI) produced by Bristol City Council and North Somerset CounciL. Bristol's SCI sets out 10 methods of preapplication community involvement which are expected to be provided for large scale developments, which would encompass the SBL proposals. /1 6.4. Planning applications and receiving planning consent: July - December 2013 6.4.1. 321 representations were received from individuals and local businesses in response to the consultation, with 44% in support, 50% objecting to the proposals and 6% neither specifically objecting nor supporting the Scheme. The majority of businesses responding supported SBL while residents objecting came from Bishopsworth, Highridge, Hartcliffe, Bedminster and Long Ashton. However, representations from residents of Barrow Gurney were supportive of SBL. _ 6.4.2. Natural England, English Heritage and the Environment Agency raised no objections to the Scheme. Bristol Water and Wessex Water also raised no objections to the Scheme. 6A.3. There were two petitions in support of the Scheme. One from Barrow Gurney residents expressing strong support for the Scheme citing the need to have better links to Bristol Airport and the congestion benefit this would bring to their village and similar areas that have had to suffer the consequences of poor transport link to the Airport. A further petition in support was presented by "Better Transport 4 South Bristol" from people in a number of communities within South BristoL. 6.4.4. Although not a formal petition as such, 65 copies of the same letter requesting that the Bristol City Council Planning committee refuses the application were submitted in advance of the committee decision 16

7. DELIVERY 7.1. Budget 7.1.1. Cost of the works and associated risks have been accounted for in the Scheme budget. These are updated through regular reviews by the project manager and the technical teams. The Scheme budget is estimated to be 46.98m. DfT funding is secured for 27.6m when the Scheme gained Programme Entry in November 2011 and is included in the National Infrastructure Plan (CD2/15 page 21) and the remainder is being sourced from Bristol City Council and North Somerset Council on an equal share basis. Appendix 7 provides details of principal cost components. 7.1.2. Both Bristol City and North Somerset Councils have confirmed through their budget setting process the availability of resources to meet their commitments for the Scheme and consider the Scheme to provide good value for money with a Benefit Cost Ratio of greater than 6 representing very high value for money, as set out in paragraph 4.14 of Robert Thompson's proof of evidence. 7.1.3. Bristol City Council has confirmed that it will through prudential borrowing meet its local funding contribution and North Somerset Council has confirmed that it will through prudential borrowing and its own resources (including Section 106 contributions) meet its proportion of the local contribution, see Appendices 8A and 8B. As part of North Somerset Council's funding, 3.19M has been secured through the S1 06 agreement between Bristol Airportand North Somerset CounciL. 7.2. Procurement and construction 7.2.1. The Joint Procurement Strategy for MetroBus includes three major elements, a) Infrastructure, b) operations c) ticketing. The delivery of infrastructure relies upon contracts being in place including design and build elements. Bus shelters and other operational equipments will be procured at a programme level. Procurement of services will follow a "Quality Partnership Route" and this is expected to be in place by middle of 2015 and commence network services the following year. 17

7.2.2. The Scheme infrastructure works are being procured through two separate contracts. Network Rail is contracted to deliver the under bridge work and the /1 remaining works are being procured under a separate design and build contract. 7.2.3. Scheme construction is proposed to start in late 2014 with a two year programme of delivery. The Network Rail underbridge works are expected to be completed in early 2015. In addition many of the advance work elements including the necessary survey works will be completed by end of 2014. 7.2.4. The SBL delivery programme has been divided into Network Rail Underbridge works, Design & Build of the main works, installation of supporting equipments (shelters, signals, information systems) and utilities. All of these work elements have in place a named lead officer with interface requirements clearly identified to ensure proper management of the contracts. 8. JUSTIFICATION FOR COMPULSORY PURCHASE 8.1. The JPA (CD2/28) makes provisions for the Council to use powers of acquisition under the Highways Act 1980 and to promote and deliver the Scheme within both Bristol City Council and North Somerset Council administrative boundaries. In resolving to exercise the CPO powers the Council did so with due regard to the Circular advice relevant to acquisition by CPO. The relevant tests for confirming a CPO are set out in INSP/1 (paragraph 2.4). I have demonstrated in the following paragraphs how the Council satisfies these. 8.2. Compelling case in public interest - In Section 3 of my proof of evidence i have set out how the Scheme meets both national and local objectives. It is part of an integrated transport strategy for the West of England and as such is closely aligned to the Strategic Economic Plan for the area. The evidence base supporting the planning application clearly identifies significant levels of disadvantage and deprivation in South Bristol which has been sustained over many years. There is clear evidence to show that the Scheme implemented as part of a wider network of transport improvements and economic interventions will deliver economic growth and jobs, improve accessibility and reduces congestion in vulnerable areas. Robert Thompson in his proof of evidence has shown the overwhelming transport benefits to be gained from the Scheme and how it meets its objectives. The cost benefit 18

ratio has been assessed in accordance with DfT guidelines demonstrating categorically that SBL represents excellent value for money. 8.3. The reports to Bristol City Council and North Somerset Council planning committees confirmed the Scheme as delivering significant transport and economic benefits. Furthermore in considering the planning case the reports concluded that the submitted scheme, subject to conditions and some detailed design variations has mitigated its harmful effects as far as possible, including the wider and local traffic impacts of the Scheme. In terms of any residual harm the report concluded that this is outweighed by the substantial public benefits of the development. The report to North Somerset Council Planning Committee (CD2I31 - at page 36) assesses the Scheme against a number local and national policy requirements and concludes that: i) - Overall the SBL is a sustainable scheme offering significant benefits to the transport infrastructure of the wider region and to the local economies. Its adverse effects have been mitigated and beneficial effects enhanced in terms of socio economics, transport, design and sustainability, health, recreation and amenity land, flood risk, water quality, agricultural land, ground and land contamination, amenity (air quality, noise and light), ecology and the historic environment in the proposal is considered to comply with the objectives of the NPPF and Core Strategy policies. 8.4. Bristol City Council Planning Report (CD2/32 at page 48) in considering the principle of the Scheme concludes that: i) - Underpinning the proposal is the access and economic benefits it will bring to south Bristol in particular but also to the wider sub region such as better access to the airport and the proposal being part of a wider network of transport infrastructure for the greater Bristol area. The challenges to the economic and transport benefits predictions by some objectors have to be weighed against the very strong policy basis, particularly BCS1 and BCS10 and the significant level of support forsbl from business organisations, individual businesses and some residents. It is considered, therefore, that the principle of SBL should be supported and very significant weight should be attached to this aspect of the assessment. 19

8.5. Interference with Human Rights of those with an interest in the land affected - The Council in resolving to exercise its CPO powers gave due regard to the Human Rights implications. The need to strike a careful balance between the rights of the individual and the wider public interest is understood and considered and it was concluded that action taken by the Council was proportionate. The evidence presented by Robert Thompson sets out the overall transport benefits and liias Drvylas demonstrates the economic benefits to arise from the Scheme in his proof of evidence. Nicholas Rowson in his proof of evidence has demonstrated the detailed assessment undertaken to identify exchange land in relation to loss of Open Space. Furthermore, John Yexley in his proof of evidence has outlined the extensive engagement undertaken with those who have raised objections to the CPO. There has been extensive public consultation during all stages of scheme development. A high degree of engagement has been maintained. The Scheme design has, prior to planning consent being granted, included changes in response to accommodating the rights of those with interest in the land and property affected. Since the planning application, liaison with land owners has continued. /1 8.6. Acquiring authority should have a clear idea of how it intends to use the land it is proposing to acquire- The Scheme has clear objectives as set out in Section 4 of my proof and furthermore i have explained the origins of the Scheme and Section 5.11 describes the Scheme route and its key features. In addition Philip Paterson in Section 4 of his proof provides a detailed description of the Scheme alignment and in Section 9 describes the engineering details underpinning the Scheme design. The Council has therefore satisfactorily demonstrated with sufficient level of detail how it intends to use the land it is proposing to acquire. 8.7. Demonstrate that the land is required immediately in order to secure the purpose for which it is to be acquired - In this proof i have confirmed a clear timeline, from initial studies, development of a transport strategy, formulation of funding bids to approvals gained and our programme for implementation. Subject to the granting of the powers sought through the CPO and SRO, the Scheme can commence later this year and will be completed in late 2016. Contracts with construction companies are either in place or are being progressed. The programme clearly shows that the Scheme is ready for delivery and it is critical that access to land is secured immediately. 20

8.8. All the necessary resource are available to achieve the scheme purpose within a reasonable timescale - The Scheme has been given programme entry status by DfT and the availability funding has been confirmed. Bristol City and North Somerset Councils have confirmed the availability of their share of the local contribution, a sum of 16.15m, over and above the 27.64m confirmed by DfT. The Scheme has secured 3.19m funding from Bristol Airport and this is confirmed through a S 106 agreement. The funding is therefore available to complete the acquisition and deliver the Scheme. Appendices 8A and 8B contain confirmation of funding commitments to the Scheme from both North Somerset Council and Bristol City CounciL. 8.9. If the Order powers are granted it is reasonable to conclude that the Scheme will proceed. Considerable progress has been made to enable the delivery of the Scheme to the programme set out in this proof. The scope of works has been agreed with the relevant Utility Contractors. Network Rail have been contracted to deliver the underbridge works and a contractor has been appointed. Tenders for the main works, on design and build arrangement, are expected back by the end of July 2014. 8.10. Reasonable prospect of the scheme going ahead - Planning permission for the Scheme has been granted. A programme of activities is underway to discharge the conditions at the appropriate time. There are no objections to the Scheme from statutory environmental bodies. The Council is working to resolve objections to the Orders and anticipates being able to resolve a significant proportion of the issues raised and expects withdrawal of majority of the objections. 8.11. I consider therefore that the tests for confirmation of CPO powers are met. 9. OBJECTIONS 9.1. Forty-two objections were received to the Compulsory Purchase and Side Road Orders. John Yexley in his proof of evidence deals with consultation with individual interests who have raised objections to the Orders. There has been one objection raised in relation to the need for the Scheme and one objection to the "vires" of the Order. My evidence is restricted to addressing these two objections under this 21

section. There is in addition one objection to the Supplementary CPO from a statutory consultee, which I anticipate will be withdrawn. 1/1 9.2. Need for the Scheme 9.3. The objection received from Ms Penny Tomlinson (OBJ/36) states she sees no reason for investment in the Scheme and furthermore on the basis of her observations claims that because of decreasing traffic levels she does not see the need for the Scheme now or in the foreseeable future. 9.4. Robert Thompson in Section 4 of his proof of evidence deals with the approach to the Economic Appraisal of the Scheme and in Section 5 deals with the transport benefits the Scheme will bring to the operation of the road network, improvements in accessibility and aiding regeneration and economic growth. Furthermore liias Drivylas demonstrates in his proof of evidence the wider economic benefits of the Scheme. I have set out in Section 5 of my proof of evidence both the national and local context and how the Scheme will deliver economic growth and regeneration, reduce congestion and improve accessibility. I consider the need for the Scheme has been amply demonstrated. 9.5. Vires 9.6. An objection has been received to the vires of the CPO by the Burnells (OBJ/29), the owners of the land being acquired to provide suitable exchange land for the common land required for the Scheme, 9.7. The basis of the Burnells' objection is that the land authorised to be acquired by BCC on 29 May 2013 referred to land edged red on Appendix 1 and that the plan does not exist and therefore there is uncertainty as to what BCC authorised. 9.8. As outlined in paragraph 2.3 of my proof of evidence, a Joint Promotion Agreement was entered into on 8 January 2013. 9.9. This agreement transfers BCC's function of construction of the Scheme, including any CPO promotions, to NSC. At this point full authority was therefore given to NSC to make the CPO to acquire all the land required for the Scheme including acquisition of the proposed exchange land. No further authorisation was needed from BCC. 22

/...~ 9.10. Notwithstanding this, a report was taken to the Mayor on 29 May 2013 to outline the Scheme and to seek his endorsement (see above). The report refers to an appended plan, which was to mirror the plan attached to NSC's Executive Report of 5 February 2013 (showing the land to be the subject of the CPO). I understand that this plan was not physically attached to the BCC report. 9.11. However, I presented the Scheme to the Mayor when he considered the report and part of my presentation included the 5 February 2013 NSC Executive Report plan as well as a number of other Scheme design drawings (which included landscape plans showing the exchange land and cross sections). Therefore, the Mayor had the relevant plan in front of him showing the land to be the subject of the CPO when he considered the Scheme. 9.12. A further issue raised by the Burnells is that more land than authorised appears to have been included in the CPO. This appears to be on the basis that a revised plan was taken to NSC Executive Committee on 3 September 2013 (CD2/24) which could be read as slightly reducing the boundaries of the land authorised to be acquired from the Burnells. However, this report needs to be read in conjunction with the 5 February 2013 report. The 3 September 2013 report expressly recognises at paragraph 3.5 that the land investigations were ongoing and that responses to these or other information may necessitate amendments to the plan. Recommendation 4 of the Report is expressly made subject to paragraph 3.5. It was therefore recognised that the plan might be amended and it was not therefore definitive. The relevant land needed for the Scheme is included in the CPO and NSC's authorisation in September 2013 provides sufficient authority for all the land included in the Scheme. 9.13. Finally Mr Burnell also raises an objection on the basis that the report to the Executive on 3 September did not make reference to his letter of 30 August to Mr David Tate, the case officer for SBL planning application. The letter was received on 4 September, the day after the Executive and in any event the report to the Executive made it clear that all the land including the Burnells land was required for the Scheme. 23