THIS REPORT WAS WRITTEN BEFORE THE AMENDED PLANNING APPLICATION WAS SUBMITTED - A NEW REPORT WILL BE PUBLISHED SOON.OBJECTION TO PLANNING APPLICATION 21/01961/OUT
PROPOSED RESIDENTIAL DEVELOPMENT OF UP TO 1,200 HOMES, 88 BEDROOM UNITS OF RESIDENTIAL CARE USE, NEIGHBOURHOOD CENTRE, COMMUNITY CENTRE, BUSINESS FLOORSPACE, PRIMARY SCHOOL AND 5 SERVICED PLOTS FOR TRAVELLING SHOW PEOPLE
Specialist Transport Planning consultants SCP have been instructed by South Woodham Ferrers Infrastructure Group to review and advise on the transport Impacts of the above planning application. We have reviewed the plans, Design and Access Statement and in particular the Transport Assessment undertaken by Mayer Brown, attached to this letter is a report of our findings.
In line with NPPF paragraph 111, we believe that the planning application as submitted should be refused on highway and transport grounds. In summary this is because:•
The Transport Assessment has not modelled the junctions correctly or considered the effect of one junction on another. In particular:
- The base flow models are not calibrated against observed traffic queues, in most cases the junction models understate the queue and delay at each junction.
- The junction models do not correctly model HGV traffic, this is shown by the error messages in the model outputs. This means the results understate the junction performance. This is especially material here as HGV flows are up to 17%, which is very high compared to many roads.
- No account is taken of committed developments which will add traffic to the base network. PPG “Travel Plans, Transport Assessments and Statements” makes clear such developments should be considered. This means the future year scenario is modelled without the known additional traffic from these sites.
- 2026 is assessed as the future year scenario. This is unrealistic, given the need to secure Reserved Matter consent and taking account of typical house builder build rates, 2035 is a more realistic future year. Again, this is contrary to the advice set out in the aforementioned PPG.
- It is also important to understand the interaction between the assorted junctions and crossings, only the junctions have been considered and these have been assessed in isolation, a calibrated micro-simulation model is required to assess the cumulative effect of traffic on the local network. The consequence of the above modelling deficiencies is that the impact of the traffic generated by the development are materially underestimated and the impact will be materially greater. Without a robust assessment and proper and planned mitigation put in place the traffic generated by the development will have a severe impact on the local highway network, result in drivers taking excess risk at junctions and cause pollution. This is contrary to paragraph 111 of NPPF.
Great play is made of the location of the site and access to the local railway station and facilities, suggesting people will choose to walk rather than drive. The measurements quoted are from the site access point rather than the furthest dwelling or at the very least a mid-point location. This means that overly optimistic assumptions are being made with regard to modal choice. Therefore, without further demonstration that the site is genuinely accessible on foot and by bike the site fails the test set out in paragraphs 110 and 112 of the NPPF.
As currently submitted SCP believe there are sufficient grounds to refuse the application on highways safety grounds and due to the likely severe impact the extra traffic will have on the transport network in terms of capacity and congestion. Having regard to paragraphs 110 and 111 of the NPPF the inadequate nature of the submitted proposals and the likely severe residual impact which will result even with the mitigation measures outlined, are not deemed to be sufficient to prevent a severe residual adverse cumulative impact.
Therefore, we request that this application is refused or, significant additional Transport Assessment work is undertaken which address the above points and bring forward a long term mitigation plan that properly addresses the impact of the traffic expected to be generated. HOW TO RESPOND TO THE ORIGINAL PLANNING APPLICATION(ADVICE ON RESPONDING THE THE CURRENT/REVISED PLANNING APPLICATION -
To submit your response use this link: https://tinyurl.com/4j82yx74 ... and enter 21/01962/out ) The deadline is December 10th 2022 )
There are some detailed (and somewhat complicated) directions on how to comment on or criticise the 'hybrid' planning application below. The simplest way, however, is to concentrate on the comments made (above) by the Specialist Transport Planning consultant as anything other than these is unlikely to be listened to when it comes to the important planning decision. A single sentence or paragraph is FAR better than not making any comment at all. Those who fail to comment are playing into the hands of the developers.
To comment paste this into your browser: tinyurl.com/2kne4avt
... Then (1) click on 'select' and answer the question - & then click GO and (2) where it says "Enter a keyword, reference number, postcode" etc - search for: 21/01961/OUT - then (3) click on 'Make a comment'. (Alternatively go to QR code no 3 (below). You must submit your comments by 7th January 2022 at the very latest (but ideally ASAP).