Table 4.1: Statutory consultees - consultation responses

Stakeholder	Consultation response
Environment Agency	The Environment Agency’s response focused on flood risk, water quality and environmental permitting. Flood Risk: The Environment Agency sees increased risk on watercourses from the works and the scheme may require a flood risk activity permit. There is potential to generate additional amounts of surface water, so Highways England will need to ensure that flood risk is not increased elsewhere. The Lead Local Flood Authority should be consulted on the proposals given their statutory role on surface water flood risk. Water Quality: The Water Framework Directive (and the associated statutory River Basin Management Plan) stipulates that there should be no deterioration of any waterbody. Measures to meet the overall objective of ‘good’ ecological status/potential should be addressed where possible. Surface water from the motorway network ultimately flows into the River Roch and River Irk watercourses which are monitored by the Environment Agency for compliance against the EU Water Framework Directive. Baseline evidence shows that they are currently failing to meet their required objectives with diffuse pollution pressures from ‘Urban and Transport’ noted as a contributing factor. The public consultation document notes that the two shortlisted options for the scheme are likely to have ‘adverse impacts’ on the water environment from a water quality perspective. It also states that ‘these impacts to be mitigated and options for this will be identified and included in the design for the scheme as it progresses’. Any mitigation should consider opportunities to address current water quality impacts from the existing network to achieve a more sustainable solution to the final design of the scheme and/or avoid the need to retrospectively address current outfall problems in the future. These would ultimately cost more in the longer term. Therefore, as part of the further assessment work for the scheme (including any Environmental Statement) a Water Framework Directive Assessment should be undertaken to inform the scope around this. Opportunities to incorporate environmental best practice in the form of multifunctional and above ground sustainable urban drainage solutions (SUDs) should be adopted where feasible. This would not only address any water quality issues but also provide an opportunity for betterment with regards to biodiversity (net gains). Environmental Permitting: This development may require a permit under the Environmental Permitting (England and Wales) Regulations 2016 from the Environment Agency for any proposed works or structures, in, under, over or within eight metres of the bank of Castle Brook and Whitefield 4 Brook which, are designated ‘main river’. Some activities are also now excluded or exempt. A permit is separate to and in addition to any planning permission granted.
Natural England	Natural England have no detailed comments to make about the proposal at this stage but want to be consulted in future.
Public Health England (PHE)	PHE commented on the following implications of the PCF Stage 2 options: · Human health and wellbeing · Environmental hazards · Air quality · Noise · Electric and magnetic fields. The health of an individual or a population is the result of a complex interaction of a wide range of different determinants of health, from an individual’s genetic makeup, to lifestyles and behaviours, and the communities, local economy, built and natural environments to global ecosystem trends. All developments will have some effect on the determinants of health, which in turn will influence the health and wellbeing of the general population, vulnerable groups and individual people. Although assessing impacts on health beyond direct effects from, for example, emissions to air or road traffic incidents is complex, there is a need to ensure a proportionate assessment. This should focus on significant effects of the upgrade. From this standpoint PHE made the following observations: Human Health and Wellbeing: PHE wants to see the application for a scoping opinion once the public consultation is complete and the preferred option is announced. At that point, PHE recommends the applicants follow the methodology provided by DMRB LA 112 (Population and Human Health), when assessing and reporting the effect of the development on population and human health. Environmental Hazards: PHE understands that Highways England will wish to avoid unnecessary duplication and that many issues including air quality, emissions to water, waste, contaminated land etc. will be covered elsewhere in their Environmental Statement (ES). The ES should summarise key information, risk assessments, proposed mitigation measures, conclusions and residual impacts, relating to human health. Compliance with the requirements of National Policy Statements and relevant guidance and standards should also be highlighted. Air Quality: PHE’s position is that pollutants associated with combustion engine-based road traffic, particularly particulate matter and oxides of nitrogen are non-threshold. This means that an exposed population is likely to be subject to potential harm at any level and that reducing public exposures of non-threshold pollutants below air quality standards will have potential public health benefits. PHE supports minimising or mitigating public exposure to non-threshold air pollutants, addressing inequalities in exposure and maximising co-benefits (such as physical exercise). PHE encourages these to be considered during the development design, environmental and health impact assessment, and the development consent. Electric and Magnetic Fields: PHE notes that the current proposals do not appear to consider possible health impacts of Electric and Magnetic Fields (EMF). PHE requests that the ES clarifies this and if necessary, the proposer should confirm either that the proposed development does not impact any receptors from potential sources of EMF or ensure that an adequate assessment of the possible impacts is undertaken and included in the ES.
Bury Metropolitan Borough Council – Environment Team	Overall view of scheme: The Environment Team is neutral about the options for the scheme but is concerned about the potential impacts on air quality and how these can be mitigated. Current junction problems: The junction as it is now is likely to be contributing to high nitrogen dioxide levels on A 56 and at the side of M60 between J17 and J18. Monitoring of nitrogen dioxide emissions close to residential housing at the side of the M60 between Junction 17 and 18 indicate that objectives for nitrogen dioxide were not met in 2019. Views on the proposals: The Environment Team is neutral about both options for the junction. The prospect of having 10 lanes of running traffic closer to the above residential properties is of great concern, as would be the impact on air quality for residents of Simister. The Environment Team suggests that Highways England must ensure that any improvements at Junction 17 and 18 have a positive impact on air quality and reduce nitrogen dioxide at nearby properties. The Environment Team will need to see the detailed air quality modelling carried out for the schemes and associated reports. It will need assurances that the project will not undermine proposals in the Greater Manchester Clean Air Plan to meet nitrogen dioxide objectives in the shortest time possible.
Rochdale Borough Council - Environment	The Council stated that, while there are issues to be assessed in due course through a statutory planning process, it welcomes the mitigation measures proposed to minimise additional impacts of both options in relation to nature conservation, noise and drainage and the water environment. The Council requests additional future proofing in the design of any proposals at Junction 18 to support a new northerly motorway access into the Northern Gateway site around Birch services together with necessary improvements to M66 Junction 3. However, it does not believe that Highways England has not engaged sufficiently to tackle air quality issues and support the Greater Manchester Clean Air Plan work. The Council stated that it will examine the air quality impacts of the selected improvement during the planning process when greater information is available. This, they stated will help them better understand how any scheme supports collective efforts to reduce nitrogen dioxide levels across Greater Manchester. The Council requests early engagement with Highways England on the design of the selected option to assess the timing of any planned work in terms of the Northern Gateway development as well as the impacts of any diversionary routes during the construction period. They stated that restrictions must be in place on several local roads within the Borough to minimise disturbance to residents. They stated that regular meeting with elected Members and communities will therefore be needed. The Council will also want to ensure we have ongoing dialogue with Highways England to ensure any master planning of the Northern Gateway employment site, and its early phases of its delivery, are integrated into the planning of whichever improvement option is taken forward.