IAMP Two - proposed A19 bridge targeted non-statutory consultation

Below is the letter to South Tyneside Council from Lichfields on 21 May 2020.

IAMP TWO - proposed A19 bridge targeted non-statutory consultation

We write to advise that our client IAMP LLP intends to carry out a further targeted non-statutory consultation as part of the IAMP TWO Project.

As you know, in 2018, the IAMP TWO Statement of Community Consultation (SoCC) was agreed between IAMP LLP and the two host authorities (Sunderland City Council and South Tyneside Council). Statutory consultation on IAMP TWO was subsequently carried out in March-May 2019.

At the close of the statutory consultation, responses were reviewed by the IAMP Project Team, to identify if there was a need to consider making any resulting changes to the details of the Project and its delivery. That review also considered the evolution of Highways England's Downhill Lane Junction DCO project. The result of this review is that design changes to the A19 bridge are now required.

The design changes can be summarised as follows:

• An increase in the span of the A19 bridge, from 43.50m to 48.55m.
• An increase in the depth of the bridge deck, which in turn, results in the road level on Washington Roadraised by an additional 0.343m, and an increase in the height of the Washington Road retaining wallstructure by a similar amount in the locality of the new A19 overbridge.
• An increase in width of the footway on the northern side of the bridge by 1.0m to provide a 4.0m Non-Motorised User (NMU) provision.
• An increase in the size of the working area and clearance zone required to facilitate the delivery and lifetime maintenance of the Washington Road retaining wall, resulting in the temporary removal of up to10m from the tree belt between Washington Road and the Town End Farm area to the east.

During the statutory consultation a number of local residents commented on the visual impact of the proposed A19 bridge and their concerns about loss of trees. At the time, it was confirmed that the wooded area near Washington Road would remain unaffected and consultees were referred to the visual impact assessment within the published PEIR. As a partial (temporary) loss of this wooded area is now proposed, and with the bridge road surface sitting at a higher level, we recognise that those residents may welcome the opportunity to engage again, especially around any concerns they may have about visual impact. As a result, IAMP LLP wishes to carry out a targeted and non-statutory consultation exercise relating to the proposed changes to the bridge design and construction.

We will seek to ensure this non-statutory consultation accords with the published SoCC document as much as possible, however variations will be required to reflect the non-statutory nature and the current restrictions imposed by the Covid-19 crisis. The approach to the consultation is being developed with consideration of recent guidance prepared by the Consultation Institute, MHCLG guidance and PINS advice notes.

The SoCC is based on a single stage of statutory consultation, but identifies that 'we may undertake additional consultation if our proposals change significantly following the consultation, because of further technical information becoming available, or because of engagement with the local community and key stakeholders'. Whilst the SoCC sets out that IAMP LLP would 'give at least 14 days prior notice and publicity of the consultation...and allow at least 6 weeks for the [statutory] consultation', it does not make any commitments about the nature or duration of any additional consultation.

In summary, the following is proposed for this targeted non-statutory consultation:

• Consultees will be identified within an appropriate but tightly defined consultation area. Relevant consultees will be selected based on:
  • Residents and businesses in close proximity to the proposed A19 bridge, including those with an interest in the land.
  • Those who were consulted as part of the statutory consultation and who specifically commented on: tree/vegetation loss generally; or impact of the bridge, being trees, visual impact, or otherwise.
  • Those who were consulted as part of the statutory consultation and who referred to other potential impacts sitewide (for example, biodiversity loss), not just in relation to A19 bridge, if new or changed impacts are identified as part of the assessment of impacts.
  • Key stakeholder organisations such as the local planning authorities, Highways England and the Local Access Forum.
• Consultation material will be sent to all those identified consultees, inviting consultees to comment and explaining: why further consultation is being carried out; details of the proposed change and how it compares to that previously consulted on; and the outcome of an assessment of impacts and any proposed mitigation. The material will be presented in the form of a covering letter, a PEIR Addendum with a non-technical summary, and supporting drawings. A feedback form will also be enclosed within the consultation pack.In addition to the consultees receiving material directly, notification of the targeted non-statutory consultation will be publicised in national and local newspapers, for two consecutive weeks commencing at the start of the consultation period. The newspapers will be the same papers that were used for the statutory consultation. Site notices will be posted near the site in advance of the consultation commencing.
• To adapt to the Covid-19 crisis, this consultation will be virtually-led. It will not entail public exhibitions and material will not be deposited at the public venues defined within the SoCC. All material published (newspaper notice, site notice, consultation pack) will direct consultees to the consultation website. The consultation pack will also include all material made available on the IAMP consultation website.
• Consultees will be invited to comment on the proposed change using the same methods offered during the statutory consultation: completing a feedback form; sending comments to the IAMP Consultation email address or IAMP Freepost; or contacting a member of the IAMP Project Team via the Freephone number.
• The consultation will run for 5 weeks, instead of the prescribed minimum 30 days required by the EIA Regulations or the minimum 28 clear days under the Planning Act 2008. The consultation will be held in June/July 2020.
• An extended consultation period is proposed for the following reasons:
  • Noting that the SoCC does not stipulate the nature or duration of prior notification for any additional consultation, such as this targeted non-statutory consultation, we propose to carry out notification at the start of the consultation period and not to provide advance notice. We are of the view that, as a targeted non-statutory consultation which follows the statutory consultation, advertising in advance could be confusing and frustrating for local residents in particular - a consultee may see the advance notice and wish to view the consultation material but would then be unable to do so until the consultation commences. An additional week of consultation over and above the prescribed period will seek to provide the consultee with additional time that they might have otherwise benefited from if advance notice had been carried out.
  • To adapt to the Covid-19 crisis, at a time when consultees may not have the usual opportunity to respond within a prescribed period, an additional week of consultation is proposed to allow consultees more time to review and comment on the Proposed Development.
• An offer of virtual meetings/calls to discuss the proposals, available on request, will be made in the consultation letter. The number of meetings/calls held will depend on the level of interest and the appropriateness of attending virtual meetings. This on-going engagement will be carried out during the consultation period.
• The consultation will invite comments on the proposed A19 bridge design amendments only and not the wider IAMP TWO Project.
• Hard copies and memory sticks of material will be made available on request.