Residents Action Group M6

The report from the consultant that was commissioned to undertake the initial desk top analysis of the available documentation is now complete. They have provided us with a written report, a full copy of which is available for whoever would like to read it and is available from RAG on request.

RAG have however drafted a synopsis of their findings and this is set out below for your information.

As you will see, the consultant has identified a number of errors and inconsistencies with Government guidance that Highways England should have been following when determining both the current level of noise generated by the M6 and the future impact of its’ multi-lane extension.

RAG believe this fully vindicates the concerns that we and many residents have, so we thank you for your donations and support thus far. We couldn’t have got this far without you.

With our consultant’s findings, and their technical knowledge, we are now in the process of drafting a series of questions under the Freedom of Information Act to drill down further into Highways England’s methodology and get access to documentation that we believe will show their approach is flawed and that noise attenuation measures should have been provided and still can be.

These measures could range from assistance for individual homes (e.g. financial support for double glazing etc) right through to assistance for the broader community by way of noise absorbent barriers (if ultimately there is deemed to be sufficient benefit derivable from such a structure in our community)

When the answers to our questions have been received, we will need to use our consultant again to analyse the data and information provided. As we have explained in previous newsletters, this will cost a further consultant fee so please do help wherever you can to help us raise the additional funds we need and lobby your Parish Council to provide additional support.

We’ve never been closer to finding out the truth and getting somethings done to protect Cranage resident’s health and well-being. That said, it will continue to require a collective effort to get the relevant authorities to act, even with this more robust argument and evidence.

Reference should be made to the Apex Acoustics document for the scope, and this document represents RAG’s assessment of that document. The paragraph referencing in italics  is that used in the Apex report.

Regulation and policy

2.1The EAR states that a Statutory Environmental Impact Assessment is not required for the project under the Town and Country Planning Act (Environmental Impact
Assessment) Regulations 2011. The report was produced to “meet the Highways Agency’s responsibilities to identify, manage and monitor the effect of all its major

RAG comment, The Highways England (HE) environmental assessment report (EAR) states that an environmental impact report is not required; this is something that was referred to at early meetings with Kate Beirne, the HE project leader at that time. SHE stated that they didn’t need to do a full impact assessment because they were not exceeding the footprint of the motorway, this we contended was not correct the hard shoulder was to be widened and traffic would ultimately be nearer to residents.

2.2The introduction to the report identifies the Design Manual for Roads and Bridges (DMRB), which contains requirements and advice relating to the development, maintenance and operation of motorway and all-purpose trunk roads as the appropriate guidance source. DMRB Volume 11 provides guidance on the statutory and non-statutory environmental impact assessment of projects. Chapter 8 – Noise and Vibration of the EAR presents the assessment of the scheme in accordance with the methodology for a “Detailed Assessment” under DMRB Volume 11, Section 3, Part 7 – Noise and Vibration (HD 213/11).

RAG comment, This paragraph refers to the design manual for roads and bridges DMRB and highlights chapter 8 of the DMRB noise and vibration with reference to volume 11 section 3 noise and vibration HD 213/11 this is referred to elsewhere in this document.

2.3Chapter 8.5 of the EAR sets out the regulatory and policy framework of the assessment and identifies relevant statutory legislation. 
2.4 In relation to the operation of new and improved roads, HD 213/11 identifies The Noise Insulation Regulations 1975 (as amended 1988) and The Highways Noise
Payments and Movable Homes (England) Regulations 2000 (as amended 2001) as relevant statutory legislation.

RAG comment, 2.3 And 2.4 sets out that there are statutory legislation requirements under HD 213/11.we contend they have not met the requirements

2.5 Regarding The Noise Insulation Regulations, HD 213/11 states that “Regulation 3 imposes a duty on authorities to undertake or make a grant in respect to the cost of
undertaking noise insulation work in or to eligible buildings. This is subject to meeting certain criteria given in the Regulation… Regulation 4 provides authorities with
discretionary powers to undertake or make a grant in respect of the cost of undertaking noise insulation work in or to eligible buildings, subject to meeting certain
criteria given in the Regulation.

RAG comment, This refers to regulation 3 which imposes a duty on authorities to undertake or make a grant in respect to the cost of undertaking noise insulation work to eligible buildings, it is RAG’s view that HE have failed to do this.

2.6 The EAR does not present an assessment of eligibility under Regulation 3 of The Noise Insulation Regulations; however, this document is referenced in the definition of the
significant observed adverse effect level (see below)

RAG comment, The EAR does not present an assessment of eligibility under regulation 3 of the noise insulation regulations. RAG’s view is this should have been available for all residents to access from day one and deprived many residents from applying for consideration.

2.7 HD 213/11 states: “The Highways Noise Payments and Movable Homes (England) Regulations 2000 … provide highway authorities with a discretionary power to provide
a noise payment where new roads are to be constructed or existing ones altered. The relevant regulations set out the criteria which should be applied in assessing eligibility
for making such payments.” This document is not mentioned in the EAR

RAG comment, Again we see a document (“The Highways Noise Payments and Movable Homes (England) Regulations 2000”) that should have been available not mentioned in the EAR.

2.8 Paragraphs 8.5.8 to 8.5.17 discuss the Government’s Noise Policy Statement for England (NPSE). The Noise Policy Aims are as follows:
“Through the effective management and control of environmental, neighbour, and neighbourhood noise within the context of Government policy on sustainable
avoid significant adverse impacts on health and quality of life;
mitigate and minimise adverse impacts on health and quality of life; and,
where possible, contribute to the improvement of health and quality of life.

2.8 to 2.14 this sets out the different levels of noise and if they are acceptable

They are      NOEL no observed effect level              

                     LOAEL lowest observed effect level

                     SOAEL significant observed effect level

SOAEL this is the level which significant adverse effects on health and quality of life can be detected . RAG comment,  This again is referred to later in this document.

3.1 The study and calculation areas for noise are defined according to HD 213/11; noise impact is calculated at every residential dwelling and other noise sensitive area within
600 m of the proposed scheme and within 600 m of roads on the existing road network that are affected by the proposed development. This calculation area should therefore 
include the worst-affected residential properties in Cranage Parish.

RAG comment, This paragraph refers to the calculation areas for noise and refers to this being 600 m from the motorway: this is significant in that RAG have documents that clearly state that highways used a distance of 300 m and discounted any properties beyond this .

Again residents have been disadvantaged by this action.

Below are some further comments from RAG over details in the report from Apex

3.7 Highlights the length of time just 3hrs that sample recordings of the noise were taken for Oak Tree Lane with no reference to if the motorway was running or the weather and wind direction

This seems at face value to be very poor practice for such a big project and its implications.

3.11 The results of an HD 213.11 assessment are presented as a table but no night time results are presented, again this shows a lack of care in executing what is required especially given the numbers of residents in RAG’s survey who reported losing sleep due to the excessive noise from the motorway.

3.13 The results presented show a NOEL level is anticipated but this report states that the absolute noise level is calculated to be above the SOEL level which should be avoided in line with government policy.

This is in line with previous statements by highways that the proposed work to the M6 would not materially make a significant worsening of the noise levels, totally ignoring the fact that the existing levels are above those required for safe health under the government guidelines.

3.14 This states that most dwellings would experience an increase in noise nuisance but no results are included for the receptors in Cranage so the extent cannot be determined. Again this is not acceptable for such a huge project.

Details below are the conclusions by Apex Acoustics and what RAG will be defining under a Freedom of Information request

4 Further information required for a full review.

4.1 Several components of the report which form part of the HD 213/11 minimum reporting requirements are referenced within the text but were not provided for
review and are not publicly available on the HE website.

4.2 This includes Volume 3: Drawings, which is listed in Chapter 1.5 as one of the four volumes that make up the full EAR. The following drawings are referenced in the text
of Chapter 8:

  • Drawing 8.1 – study and calculation areas used for the noise and vibration assessment of the proposed scheme
    • Drawing 8.2 – illustrates the locations at which noise monitoring was undertaken
  • Drawing 8.3 – identifies ten sample receptors within the study area
    • Drawing 8.4 – identifies the approximate locations of proposed noise barriers
    • Drawing 8.5 – noise change contours in the short term with the effect of proposed noise barriers
    • Drawing 8.6 – noise change contours in the long term with the effect of proposed noise barriers

4.3 Drawings 8.1, 8.5 and 8.6 in particular should be presented under the HD 213/11 minimum reporting requirements.

4.4 Chapter 8 of the main text of the report also references Appendix A8.3: Predicted Noise Levels at Receptor Points. This appendix is not included in the final version of
the EAR report appendices.

4.5 The supporting information listed above should help to clarify the report contents and conclusions. This information should be presented based on the finalised mitigation
proposals, if any, and details of the proposed mitigation measures should be provided.

4.6 It should be queried whether an assessment of entitlement under The Noise Insulation Regulations has been conducted and, if so, its results requested.

4.7 No significant inconsistencies have been noted in the methodology or results presented in the EAR and, aside from the omissions discussed above, the report
generally provides greater detail than would be required under HD 213/11.

4.8 As such, we (Apex Acoustics) would not recommend that a detailed review of the calculations is conducted as this would not be anticipated to change the findings of the report, namely that the proposed scheme would not be expected to cause a perceptible change in conditions in Cranage Parish, but that the current and future noise impact with or without the scheme is significant.

4.9 To conduct a full review of the calculations Apex Acoustics would need to be provided with the following for the section of motorway between junctions 18 and 19:
• 18-hour annual average weekday traffic flows
• Percentage of heavy vehicles
• Traffic speeds
• Road gradient.

A full copy of the Apex report is available on request.

RAG are still actively seeking donations from residents to make up the shortfall required of £1450 to carry out the second part of the detailed analysis that will be required, if you can help in anyway no matter how small a donation it will be gratefully received.

payment can be made by cheque to Residents’ Action Group and send it with the slip below to either

RAG chairman    Peter Wild     Woodlea   oak tree lane Cranage CW10 9LU
RAG Treasurer      Inam Choudhry    Acorns oak tree lane Cranage CW10 9LU

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Residents Action Group  (RAG ) committee members

Chairman Peter Wild ,

Treasurer   Inam Choudhry ,

Andrew Kolker  CE Councillor,

Mike Hodge  Cranage Parish Councillor,

Stuart Jackson .

Secretary Joan Wild,

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