The information provided by Wiltshire Council regarding the A350 Melksham Bypass is misleading and needs to clarified prior to the non-statutory consultation window being closed at the end of November. This relates specifically to the information within the assessment matrix and supporting material as it relates to Option 10d.
Option 10d has only recently and hurriedly been included in what has been a very long process. No Environmental Impact Assessment has been registered as having being conducted on route 10d. This should be done this in order to complete the assessment matrix that was published in the consultation materials. The concern is that it has been presented as looking like a favourable comparison to 10c (scoring similarly on the assessment matrix, when in fact the land over which it would be built is significantly different).
Presenting the assessment matrix in this way completely distorts the validity of any public feedback on these two different options.
Any independent person looking at the evidence presented in the Melksham Area Board meeting (4th November) and the supporting information would draw the conclusion that 10d is now one of two clear front-runners from the 18 sub-options provided.
Some examples of how the information is misleading:
Further information on these matters are provided below.
Please ask the Council for an extension to the consultation process beyond the very short time frame of 26 days (taking place during a pandemic). Other residents and stakeholders will have made their responses based on the assessment matrix and narrative already provided.
In order for residents to be able to respond fairly there needs to be
a) a direct and accurate comparison of the southern forks of 10c and 10d
b) an extension to this non-statutory consultation period
Option 10d goes straight across a floodplain. The road would have to be built on stilts to mitigate against the road flooding, which means that it will have a significant impact on the landscape - being visible from miles around, and would be considerably more costly.
The green bars denote Options that were submitted to DfT in September 2017. 10d was not considered as part of this submission – yet is clearly assessed as being one of the two front-running options.
Both options would deliver the same transport outcomes- Option 10D (overall) doesn’t have such a beneficial noise impact reduction (but is still positive) and has a lower severance benefit (but is still neutral)- Option 10C (overall) would be cheaper to deliver, with less risk of cost overruns, is relatively easier to deliver, and has a lower landscape impact- Yet, 10 C and 10 D score the same (4.2 / 5) on how they relate to delivering the Strategic Options for scheme and the same 3/5 on Ease of Delivery. The only qualitative difference is an Indicative Value for Money – where 10 C is given an ‘Medium to High” VFM, vs ‘Medium’ for 10 D
c.65% of the Option 10 C and D are the same. Therefore, there needs to be specific comparison of the points of divergence, rather than an assessment of the routes as a whole.
Option 10 c and 10 d are scored equally on biodiversity, classified as a ‘moderate adverse impact’. The description within the supporting evidence states the same for both “the corridor passes through land associated mainly with farming and equestrian uses” However, the reality is that they are very different from a biodiversity perspective.
On 4th November (the day of the MAB), this photo was taken by a dog walker of an otter within the blurred route boundary of the proposed 10 southern fork D. Otters are a European Protected Species (EPS) under Schedules 9 and 11 of the Wildlife & Countryside Act.
As southern fork D crosses a canal, a river and flood plain / water meadow there are many protected species and birds under special protection (see below). None of these are registered on the Wiltshire Biological Record. Had Option 10D been part of the original and thorough assessment, this information would be accurate by this stage.
Due to the time of year (nesting/mating seasons), this ecological information cannot be gathered imminently. However, some allowance needs to be made in this very rapid process if 10D is to be accommodated fairly. For example, At the very least, we need to make the following irrefutable statement public:
The extensive severance of habitat and loss of connectivity, together with increase in lighting, which potentially could cause a preventative barrier for species moving across the landscape. The impact to the species using the canal could be significant too, particularly to the commuting routes of bats and potential loss of habitat for otter and water vole