Hathern Parish Council response to planning application P/15/2289/2

Hathern Parish Council is concerned about the effect on the adjacent rights of way and

access to the Baptist church. These footpaths (K82 and K83) are well used paths and the

presence of five houses (one existing), each perhaps having two cars with delivery

vehicles etc. will present a significant hazard to pedestrians at the confluence of these

footpaths with the access road to the new site. The paths are the main pedestrian access to

and from the bus stops south of the Anchor Inn. It is disappointing that LCC sees no

problem here. There is already a parking issue at this bend of Anchor Lane, and it is

likely that more cars eg visitors, will park on Anchor Lane.

Hathern parish has already taken significantly more than its fair share of new housing

compared to just about every other village parish in Charnwood. The Borough Council

now has a 5 year housing plan covered by existing committed developments. Therefore it

should not agree to yet more development in a parish where, via the Core Strategy, it is

already planned to build around 1500 new houses.

HATHERN PARISH COUNCIL

THE GARENDON PARK AND COUNTRYSIDE PROTECTION GROUP

SHEPSHED TOWN COUNCIL

WEST OF LOUGHBOROUGH SUSTAINABLE URBAN EXTENSION (WoLSUE)

OUTLINE PLANNING APPLICATION TO CHARNWOOD BOROUGH COUNCIL (REF: P/14/1833/2) TECHNICAL NOTE 1: TRANSPORT ISSUES: BASIS OF OBJECTION (HOLDING RESPONSE)

1. Introduction Travis Baker (TB) is appointed by Hathern Parish Council, The Garendon Park and Countryside Protection Group and Shepshed Town Council to review the transport and traffic implications of the proposed West of Loughborough Sustainable Urban Extension (WoLSUE). This Technical Note presents TB’s initial assessment of the technical information submitted in support of the outline planning application for WoLSUE, focussing on the Transport Assessment (TA) prepared by White Young and Green (WYG), but taking into consideration other documentation submitted during the process of preparing the Charnwood Core Strategy. This Technical Note summarises the key transport-related issues of concern and forms the basis for a holding objection to the planning application on the following key grounds:

• Sustainability • Deliverability and Viability • Road Safety and Transport Impact

Further representations will be made on behalf of our clients prior to the proposed planning application determination date in December 2014. 2. Sustainability The site is located on the western outskirts of Loughborough and is relatively unsustainable when assessed against reasonable alternatives. It is considered that the correct means of determining the most appropriate location for development that will meet local needs is the on-going Core Strategy process. This outline planning application is therefore considered to be premature. The site is not considered to be a sustainable location for a development of this scale, for the key reasons summarised below.

• The location of the scheme, being close to the motorway network and some considerable distance from the main railway station at Loughborough, would tend to encourage longer-distance car-based travel. This would be exacerbated by the proposed Strategic Link Road (SLR), which would (if it operates as claimed in the TA) provide rapid access to the motorway at Junction 23. Travel to more local destinations such as the town centre, local employment sites and the railway station by more sustainable travel modes would be at a competitive disadvantage.

• The scheme proposes a mix of land uses and it therefore claimed to be a sustainable development that will reduce the need to travel beyond it. A key element of this claim is the provision of 16 hectares of employment land within WoLSUE. However, none of this employment would be available from “day one”; in fact, 840 dwellings would be provided prior to any on-site employment uses being occupied. The traffic impact of this early stage may not have been assessed realistically. Furthermore, there are significant doubts about the deliverability of key highway infrastructure elements such as the SLR that would be required to serve the employment land, as highlighted below.

• It is claimed that the on-site employment uses could provide approximately 800 jobs. However, whilst the TA assessed a mix of B1, B2 and B8 uses, the actual take-up and delivery of employment will be driven by the needs of the market. A site at this location could be expected to attract distribution-type businesses which have a significantly lower employment density. If a predominantly B8 scheme were to arise, the number of jobs created, and the potential to minimise out-commuting from the residential scheme could be significantly reduced.

• It is claimed that the site would lie within a 2km walking distance and a 5km cycling distance of a range of local facilities including employment, retail and community uses. However, this simplistic assessment fails to take into consideration conditions on the highway network beyond the site. The severance effects of traffic and the physical barrier imposed by the A512 corridor and M1J23 are likely to deter potential walk an cycle this to key destinations such as the University, Science Park and employment areas at Shepshed. As a result, a greater number of shorter-distance car trips are likely to occur.

• In this regard it is noted that the proposed SLR would not provide footways or cycle-ways on its southern section, which connects directly to the A512. This could significantly deter pedestrians and cyclists from using the route to reach employment opportunities at the University and Science Park, under-mining the scheme’s sustainability credentials. rent to

The scheme therefore appears not to comply with paragraphs 30 and 34 of the NPPF. 3. Deliverability and Viability There are significant concerns about the potential deliverability of the proposed transport mitigation measures, as follows:

• The first phase of development is programmed for completion by 2017, with the proposed SLR being delivered by 2022. This proposed timescale is considered highly ambitious, particularly given the significant complexity of the SLR scheme, which will require significant technical approval and statutory procedures. Of similar concern is the affordability of the SLR, given that it is to be delivered at a development of just 1200 units. The consequences of any delay to the programmed delivery of the SLR for the adjacent transport network have not been satisfactorily assessed.

• The programmed build-out rate for the scheme is an average of some 230 dwellings per annum, which is also considered highly ambitious. Fluctuations in build-rates are typically encountered, and this could results in a significantly protracted delivery timescale that would lengthen the potential disruptions caused by necessary highway works or compromise the delivery of key transport infrastructure and services required to serve a development of this scale.

• Although new bus services are proposed and have been discussed with local operators, the cost of providing these services would be very significant and no detailed business case or

other assessment of their long-term viability has been provided. There is a significant risk that such services would not be sustained in the longer-term, leading to a less accessible scheme that would generate more a-based travel.

• The key highway improvements to the A512 and M1 Junction 23, including the proposed SLR junction and the extension of dual carriageway to Snells Nook Lane, are to be delivered via financial contributions. The costs of these schemes do not appear to have been fully assessed and are likely to be very significant. The availability of adequate funds to deliver the necessary improvements would be dependent on the phasing of development and there is no certainty that key highway infrastructure would be delivered in a timescale appropriate to the traffic impact of the scheme, or indeed, at all.

• Details of the nature of the proposed SLR have not been provided. Whilst this route has been assessed as a single-carriageway all-purpose road in accordance with the Design Manual for Roads and Bridges (DMRB), it also appears that it is intended to provide local access to development facilities and housing, potentially including direct frontage accesses. To avoid severance effects, frequent pedestrian crossing facilities would also need to be provided. Such features could conflict with the proposed strategic function of the SLR, reducing its attractiveness to through-traffic and negating its claimed benefits.

4. Road Safety and Transport Impact

There are significant concerns as to the robustness and reliability of the traffic forecasting work submitted with the application. Some of these issues are highlighted below:

• Much of the traffic survey data used as a basis for the assessment is out of date, being more than 5-years old.

• The TA adopts a “manual modelling” approach, which makes only very limited use of the strategic Leicester and Leicestershire Integrated Transport Model (LLITM) and is heavily reliant on trip distribution data that has its origins on the now out-of-date 2001 census. This approach appears to be inconsistent with that adopted for the Core Strategy process and with assessments of other SUE proposals in the Borough.

• The base junction assessment models used in the assessments do not appear to have been validated to existing conditions.

• The proportion of trips generated by the proposed employment and retail uses that would remain internal to the site may have been over-estimated, particularly in the light of the sustainability comments made above.

• The residential trip rates adopted in the assessment are considerably lower than those typically used for similar assessments.

• The cumulative impact assessments as presented do not appear to take into account other proposed Core Strategy strategic schemes beyond Loughborough, which might also have an influence on traffic flows within the local area, in particular M1J23, the A512 and the SLR.

• The consequences of delayed delivery of the SLR on the adjacent highway network have not been assessed and could be very significant.

• Cumulatively, the above issues could result in the traffic impact of the scheme having been

significantly under-estimated.

• The proposed A512/SLR junction lies within approximately 500m of M1 Junction 23. The developer’s assessments show that this junction would be operating close to its practical capacity on 2026 and above capacity in 2031. As a result, there is a significant risk that queues at the proposed junction could extend back to and interfere with the operation of M1J23.

Having regard to the above, it is considered that there is a significant risk of severe residual transport and road safety impacts arising from this scheme. Paragraph 32 of the NPPF states that: “All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether: - the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure; - safe and suitable access to the site can be achieved for all people; and - improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.” Having regard to the comments provided in this note, it is considered that these three key requirements have not been addressed and that the application therefore does not comply with the NPPF. Travis Baker 14 October 20