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Email from Mark Taylor-Batty to Councillor Anne Hawksworth, 28 September 2007

Dear Anne,

I wonder if I might put two questions to you regarding the public money that is being sought for a feasibility study for a tunnel under Saltaire.

1. Directive 2004/54/EC entered into force on 30 April 2004 and requires that all tunnels longer than 500 meters meet minimum safety requirements. In order to fully respect the integrity of the World Heritage Site, the proposed tunnel beneath it must submerge and emerge at points that indicate its length will meet or exceed 500 metres. Paragraph 2.1.2 of Annex 1 of the directive makes it clear that "... where, for tunnels at the design stage, a 15-year forecast shows that the traffic volume will exceed 10 000 vehicles per day per lane, a twin-tube tunnel with unidirectional traffic shall be in place at the time when this value will be exceeded." Statistics from the Highway Agency indicate that this traffic volume is already in place. ("Traffic volumes of around 28,000 vehicles per day (vpd) are shown on both sections of the A650 Bingley Relief Road" and "On the A650, south of the bypass, traffic volumes have increased from 29,300 vpd to 35,100 vpd, an increase of 5,800 vpd or 20"). A twin-tube tunnel will require a breadth of construction that is not permitted by the limitations of the current proposed sites of submergence and emergence of the proposed tunnel. This twin-tube requirement will also significantly boost the already conservative estimated cost of the bypass. It is our understanding that - in spite of this very clear legal requirement - the feasibility study is for a single tunnel under the station and church, and not two. Should an expensive feasibility study be undertaken when the results will be de facto unlawful?

2. Ancient and Semi-natural Woodland. Hirst Wood near Saltaire AND the strip of woodland that fringes the Bingley Road is designated an  'Ancient and Semi-Natural Woodland'. These woodlands lie wholly within the Saltaire World Heritage Site buffer zone. The proposed bypass cuts through one or both of these - They cannot both be avoided, and damaging impact upon them cannot be avoided by circumnavigating either at proximity. The view adopted by English Nature is that ancient semi-natural woods are irreplaceable, and must  be protected and managed so as to maintain and enhance their special character. Government policies (as set out in the 1994 Sustainable Forestry document) are to operate a general presumption against the conversion of woodland and trees to  other use, and to protect our ancient and semi-natural woodlands. The England Forestry Strategy (1998) states that the government will review the effectiveness of measures for protecting ancient semi-natural woodland  and if necessary introduce new measures for giving them added protection. The UK Biodiversity Action Plan (1994) states as Step 25 a commitment to continue to protect ancient semi-natural woodland and encourage forms of  management which conserve their special characteristics. In 2002 Bradford council's 'Woodland Strategy' was updated to plainly "refuse" (as opposed to the previous "resist") development proposals that threaten Ancient Semi Natural Woodland.  Residents will want to know why the council plans to ignore its own policy, let alone other regulation.

Anne's email in response, 1 October 2007:

far too technical for me --I have sent to steve [Barton]

Email reply from Mark Taylor-Batty, 1 October 2007:

Many thanks Anne,
 
I look forward to Steve's response. One question, though, was not technical. What is your position as regards the Council's 'Woodland Strategy' policy which makes states that any development on ancient semi-natural woodland will be refused (amended in 2002 from 'resisted')? Do you intend to do all you can to see that this policy is upheld, or are you willing to see it ignored?

9 October 2007
Dear Mr Taylor-Batty

Having contacted Steve Barton, I will now answer the technical questions set out in your e-mail of 28 September, as well as those repeated in your e-mail of 5 October 2007.

European directives and national regulations setting out safety requirements will be complied with in the design of any tunnel forming part of proposals for a Saltaire Bypass.  It is not yet possible to say what route might eventually be proposed for such a bypass as the concept route passing under Shipley town centre and Saltaire station is only one of several routes which will have to be evaluated against public transport options.  Similarly, the traffic volumes which might be carried by any tunnel have not yet been forecast as they would depend on the route proposed and any demand management measures incorporated.  It is, therefore too early to say whether single or twin bores would be appropriate for any tunnelling solution which might be pursued.

The concept route recently published was intended to indicate that there may be an alternative to previous bypass proposals but, as indicated, its route is not fixed and it is not the only option which needs to be considered.  The timing of any bypass will probably make little difference to its environmental or community impact but the Council is required to properly evaluate those impacts and compare them with the impacts of other options.  I believe the time for a public debate about the relative merits of those options will be when the evaluations have been completed but this is not likely to be for some considerable time.

The Council's Woodland Strategy policy on Ancient Woodlands is now incorporated into the Adopted Replacement Unitary Development Plan as part of Policy NE4 which, as you suggest, states that "...the Council will refuse development proposals which would result in the loss of trees or areas of woodland cover which contribute to … the Ancient Woodlands of the District".  I would fully expect the Council's Planning Panels and Regulatory & Appeals Committee to recognise that Policy in making a decision on any planning application.  However, for the reasons stated above, I believe it is far too early to be able to state that a Saltaire Bypass route would have the impact on Ancient Woodland that you suppose but it is a valid concern and one which is recognised by the Council.

I trust this response answers your various queries.

Dear Dr Taylor-Batty,

I'm afraid the process is not as simple as your e-mail assumes.  Some feasibility work has already been undertaken and established that it probably geometrically possible to build a route to current horizontal & vertical design standards along the approximate line of the Saltaire Bypass concept recently published.  However, a detailed study of the geology / hydrology of the full length of the route has not been completed, nor has an engineering assessment been made of the feasibility of tunnelling through whatever strata such a study might find.  As part of the negotiations with the Transport Minister over de-trunking of the A650, it was agreed that Highways Agency staff would provide some help with that engineering assessment.  An assessment of the environmental impacts of such a route would need to carried out if its construction was found to be engineering feasible and affordable.  Both environmental and engineering assessments could result in a change of horizontal and/or vertical alignment and/or length of tunnelling to avoid problems or mitigate impacts.

To qualify for any government funding, any proposal will have to be tested against other alternatives, including public transport options.  As a result of that "evaluation" process, other options may turn out to give better value for money, have less environmental impact and/or get more public support.  The resulting Business Case will determine which option, if any, can be taken to the next stage.  The Business Case is reviewed and updated as further investigations / design work / public consultations progress and a decision made on whether support can continue to be given to the proposal.  The Initial Business Case is considered by the Regional Transport Board and only if that is supported can it progress to a Programme Entry Business Case to be considered by the Department for Transport (not Highways Agency).  If successful at that stage, two further stages are required before the go-ahead for funding of construction can be granted, the last stage following planning permission and, do doubt, a public inquiry where the public have an opportunity to comment on proposals.

In short, the recent tunnel concept is not the only option which will have to be evaluated and alternatives to having a bypass at all will have to be considered as part of the evaluation.  No decision has been made yet on what the options will be and the Council is not actively working on alternatives at the moment.  As I have recently advised §§, conservation advisers have previously expressed serious reservations about some surface routes which they feel would have major adverse impacts on the World Heritage Site and I believe Councillor Hawkesworth was referring to those views in the quote you give.

Steve Barton