Ref:
Borough Plan Main Modifications Representation Form (For official use only)
Name of the Local Plan to which this representation relates:
Borough Plan Main Modifications
Please return to Nuneaton and Bedworth Borough Council by 3rd December 2018 via:
Email: planning .policy@nuneatonandbedworth .gov .uk
Post: Planning Policy Consultation, Town Hall, Coton Road, NUNEATON, CV11 5AA
This form has 2 parts:
Part A – Personal details
Part B – Your representation(s). Please fill in a separate sheet for each representation you wish to make. Part A
1. Personal details* 2. Agent’s details (if applicable) * If an agent is appointed, only the Title, Name and Organisation boxes in section 1. are required. Agent details should be completed in section 2. Title Mr First name Steven Last name Young Job title Chair (where applicable ) Organisation Exhall Residents Association (where applicable) House number (Redacted) Street (Redacted) Town (Redacted) Post code (Redacted) Telephone number (Redacted) Email address (Redacted)
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3. Which of the following age brackets do you fall within?
Up to 15 16-19 20-29 30-39 40-49 50-59 60-69 70-79 80+
Part B – Please use a separate sheet for each representation
4. Name or Organisation Exhall Residents Association
5. To which main modification does this representation relate?
MMC reference MMC28
6. Do you consider the Borough Plan is:
6.(1) Legally compliant
Yes No x
6.(2) Sound
Yes No x
Please mark with an ‘X’ as appropriate
7. Please give details of why you consider the main modifications are not legally compliant or are unsound. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the main modifications, please also use this box to set out your comments.
The main modification to widen School Lane to allow HGV traffic to pass freely and use the lane as a main access to the proposed EMP 7 employment land would not alleviate the traffic problems that EMP7 would create.
Exhall Residents Association have conducted our own traffic survey and modelled the traffic that EMP7 would create if it were to go ahead. Figures used for traffic generation are taken from the STA provided by WCC Highways.
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We took our findings to Warwickshire County Council and a motion passed by the community overview and scrutinies committee, by unanimous vote, that WCC Highways would look again at the advice given to NBBC in the light of the new evidence provided by our report. This decision would cast doubt on whether emp7 would be deliverable in its present state. The action to be taken by WCC was reported in the Nuneaton Evening Telegraph on the 27 th November 2018 the full report is available online. The motion passed also said that NBBC would be notified by letter that WCC Highways would be looking at their advice on School lane again.
The report produced by Exhall Residents Association shows that the extra traffic would overwhelm the busy Bayton Road/ Coventry Road/ School Lane/ Blackhorse Road junction system. School Lane as can be seen from the survey figures is, during the morning peak, the second busiest contributor to the junction system and already suffers from queues that easily tail back to Bruce Road. It is our suggestion that the queues are mainly formed by traffic wishing to turn right from School Lane towards Coventry. The bottle neck formed already overwhelms the junction and is exacerbated whenever a HGV tries to make this manoeuvre. From observations it would appear that only 3 cars can safely make the right turn during the green light period due to traffic either coming straight on from Bayton Road or that the exit route along Coventry Road is already filled.
WCC have put in place plans to mitigate this traffic by adding an extra southern lane on Coventry Road between its junctions with Bayton Road and Black Horse Road. The mitigation works would not start until 2031 after EMP7 would according to the STA be at full capacity. This would mean that not only would the local network have to cope with road infrastructure works but also the added traffic from a fully operational employment site.
Terra Strategic have suggested in their Statement of common ground with NBBC on HSG12
OTH/33.1 - Transport Statement of Common Ground between Terra Strategic and WCC, Statement and Appendix A-I (February 2018 - Highways Authority ) appendix A Transport Statement of common ground between Entran Limited on behalf of Terra Strategic and Warwickshire County Council(highway authority),section 6.22.
“It should be noted that LinSig can only model optimised fixed time and does not include the additional delay savings which would be introduced through a traffic responsive SCOOT-UTC system which can be of the order of 13%. Therefore the results shown in the modelling should be a robust indicator of likely junction performance.”
This approach would invariably link all of the junction and thus any generated traffic from development in the area that would contribute to the junction system of Bayton Road/ School Lane/ Coventry Road and Black Horse Road/ Coventry Road. Due to the nature of SCOOT it would not be possible to look at each contributing site individually as one input into the system would have an impact on all the others. Our traffic analysis using real figures, not desktop estimates, proves that the STA figures would add far more than 13% to the system from HSG12 and
3 thus would have an impact on traffic flows feeding into the system From EMP7. The Data obtained from our survey also shows increases eastbound on School Lane from EMP7, to be far in excess of the 13% figure quoted and thus would not be accommodated by using the SCOOT traffic system.
We have included a copy of the full report below the data sets gathered and the STA figures used in the report are contained within the appendixes. All data sets can be supplied in excel format on request.
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Exhall Residents Association
Traffic analysis and modelling report on the road junction system of Coventry Road, Bayton Road, School Lane, Black Horse Road and Longford Road.
12 th November 2018
Prepared and published by: Exhall Residents Association
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Traffic analysis and modelling report on the road junction system of Coventry Road, Bayton Road, School Lane, Black Horse Road and Longford Road.
1. Background 1.1 Coventry Road is a main commuter road between the town of Bedworth and City of Coventry carrying local traffic as well as through traffic between the two, and serving as a link to Junction 3 of the M6 motorway. The industrial area of Bayton Road forms a cross roads with Coventry Road and School Lane. Within 100 meters Coventry Road intersects with Black Horse Road. 1.2 School Lane is semi-rural in character and forms a busy link for the areas to the south west of Bedworth, Ash Green and Keresley for traffic accessing the motorway network and the A444 Trunk road. It is also, as can be seen from the traffic data, an important commuter route that carries as much traffic as Coventry Road. 1.3 Black Horse Road is one of two possible access roads to the village of Hawkesbury, it also forms an important route for commuters using it to travel to areas in the North east of Coventry.
Map showing the area covered by the survey and the relative posi tions of the housing and employment developments EMP7
HSG 6 HSG12
EMP6
fig 1.
2. Purpose of report 2.1 Nuneaton and Bedworth borough plan has identified sites that would affect the junction system. Warwickshire County Council have been consulted on road infrastructure and produced the Strategic Transport Assessment(STA) which has been accepted into the Borough Plan
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Examination Library. It was felt that there was little understanding of what the effects of the traffic generation figures, taken from the STA would have on the junction system and that the only way it could be assessed, would be to take a traffic survey of existing traffic. Once this was completed the STA figures could then be modelled onto the existing traffic and an accurate estimate of future levels could be calculated.
3. list of proposed sites in the borough plan that would have a direct effect on the junction system. EMP7 Church Lane/Bowling Green Lane EMP6 Longford Road HSG6 School Lane HSG12 Hawkesbury Golf Course
4. Method used to gather traffic data 4.1 The monitoring took place on consecutive Wednesdays as this was thought to be a typical working day and would avoid any peaks due to start or end of week 4.2 Monitoring was conducted between 7.30am and 9.30am for the morning peak on the 10 th October 4.3 Monitoring was conducted between 3.30pm and 5.30pm for the afternoon peak on the 17 th October
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4.4 Monitoring of traffic was conducted at the locations shown on the map (fig 2)
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Fig 2. Map showing positions of stations monitored.
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4.4 Data was separated into 7 modes of transport. Bicycle Motor Cycle Car Van Truck Articulated Truck Emergency service Vehicle
4.5 Data was collected over a 2 hour period split into 15 minute segments. Traffic was counted manually using pre printed tally sheets, with one person being responsible for one station. 5. Results 5.1 All tables of results for AM peak traffic survey are in appendix 1 5.2 All tables of results for PM peak traffic survey are in appendix 2 5.3 Graph showing Total traffic entering junction system during AM period. Graph also shows that the peak traffic was captured in the data set.
Fig 3.
Total traffic into junction system
630.00
610.00 604.00
590.00 581.00 570.00
550.00
530.00
Total Vehicles Total 510.00 503.00 490.00
470.00 7:30 7:45 8:00 8:15 8:30 8:45 9:00 9:15 Time
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5.4 Graph showing Total traffic entering junction system during PM period. Graph also shows that the peak traffic was captured in the data set.
Fig 4 Total traffic into junction system
670.00 650.00 648.00 630.00 610.00 590.00 573.00 570.00 550.00 534.00
Total Vehicles Total 530.00 510.00 490.00 470.00
Time
5.5 Total traffic traveling Eastbound on School Lane Fig 5 School Lane total traffic eastbound PM peak 160 150 140 130 120 110 100 90 80
Total all/h
6. Traffic modelling for EMP7 (Bowling Green Lane) and its effect on School Lane westbound 6.1. Significant increases in traffic were found at both the AM and PM peak periods. The PM period was considered to be the greatest increase and modelled in the following way. 6.2 The STA figures for traffic generation output from EMP7 during the PM peak period are for a 3 hour period. For the purposes of modelling a mean average per hour was adopted. There is no weighting of the mean average to allow for peaks in flows and as such the percentage increase in traffic would naturally be higher than the resultant modelled figures, thus giving a lower figure than would be expected had the STA figures been weighted for peaks in flows.
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6.3 As School Lane will the only route for LGV’s the STA figures needed to be weighted with traffic that would have no alternative but to travel via School Lane. It was decided to use a donor site to obtain an average percentage of LGV to other traffic. The donor site chosen was the exit to Bayton Road Industrial estate during its peak PM period. The figures obtained used in the calculation are shown in Appendix 1 station 5 Bayton Road westbound Table 1.
Table showing percentage of vehicles leaving Bayton Road Industrial Estate during PM peak
Number of vehicles percentage Total traffic 580 100% Cars /Vans/buses 452 77.93% LGV 128 22.07%
22.07% was obtained from table 1 and used in the modelling of the output of LGV traffic from EMP7. This figure does not include bicycles. 6.4 It is assumed for the purposes of modelling that all LGV traffic would be prohibited from using other routes as agreed by WCC during the examination process into NBBC Borough Plan Examination. 6.5 The figures obtained from the STA traffic generation for EMP7 Bowling green Lane ( appendix 3) Table 2. Table showing the STA traffic generation EMP7 mean average figures over 1,2 and 3 hour periods for both trucks and other vehicles
AM PM In Out In Out 3 hour 1,856 448 349 1646
1 hour mean average 618 149 116 548
2 hour mean average 1237 298 232 1097 2 hour mean average excluding LGV na na na 855 2 hour mean average for LGV at na na na 242 22.07%
6.6 Traffic generation figures for School Lane were arrived at by firstly taking the STA average 2 hourly rate of trucks (which will be prohibited from taking other routes other than School Lane from EMP7) and adding them to the 2 hour mean average of counted figures from the survey. The projections where then based on the effect the remaining traffic, which can choose to use two other routes to exit the area were modelled into the baseline figure of existing and LGV figures.
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6.7 Table showing projections at varying percentages of traffic from EMP7 and its effect on existing School Lane westbound traffic during the 2 hour PM peak period 15.30-17-30 Table 3.
Numbers of Vehicles Percentage increase after EMP7 traffic is added Counted traffic 771 Counted traffic + Epm7 LGV 1013 generation Total + 20% other traffic 413 53.6% Total + 30% other traffic 498 64.5% Total + 40% other traffic 584 75.7% Total +50% other traffic 669 86.8%
7. Hawkesbury HSG12 7.1 The village of Hawkesbury is served by one main through road. The approach used was to count the traffic input to the village during the PM peak, We then modelled the expected increase using the traffic generation figures shown in Table. 7.2 As no traffic generation figures were available from the STA for Hawkesbury, the same methodology was used to estimate the PM peak from housing as was applied to other housing sites in the STA. 7.3 The figure of 1.01 per dwelling was found to be the average for most sites in the STA over a 3 hour period during the PM peak, and was used to calculate the traffic generation for HSG12
Table 4
Number of dwellings Number of vehicles generated into HSG12 during PM Peak
398 401
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7.4 Graph showing the traffic input into Hawkesbury during the PM peak 15.30 to 17.30 Fig 6
Traffic coming into Hawkesbury
180.00
160.00
140.00
120.00
100.00
80.00
all road totals
Table and projection for Hawkesbury during the PM input peak between 15.30 and 17.30
Table 5
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Appendices Appendix 1.
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Appendix 2.
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Appendix 3 Table copied from WCC Highways Strategic Traffic Assessment 2016 and placed in the Nuneaton and Bedworth Borough Council Borough Plan Examination Library. EMP7 traffic generation figures used for modelling are arrowed and highlighted.
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This document was prepared by, Exhall Residents Association 12 th November 2018
C/O The Secretary, Mr Steven Driver 76 c Coventry Road Exhall Coventry Warwickshire CV7 9EU
Email: [email protected] Tel: 07804 829370
(Continue on a separate sheet / expand box if necessary)
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8. Please set out what modification(s) you consider necessary to make the Borough Plan legally compliant or sound, having regard to the matter you have identified at 7 above where this relates to soundness. You will need to say why this modification will make the Borough Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.
To make the plan deliverable the road network would have to be looked at and real infrastructure developed, much of which would need to be in place before the site was brought into use. The particular problems of queue lengths can only be mitigated through two methods.
1. School Lane would need to have extra capacity to allow for waiting traffic the only way to achieve this would be to widen it enough to allow the inclusion of an extra lane in the eastbound direction. Further work on queue lengths would be required to determine how much extra lane would be required 2. A large traffic island to disperse traffic freely at the junction of Coventry Road/ Bayton Road/ School Lane. The island would need to be large enough to allow HGV traffic to feely negotiate it.
(Continue on a separate sheet / expand box if necessary
Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support and justify the representation and the suggested modification, as there will not normally be a subsequent opportunity to make further representations.
After this stage, further submissions will be only at the request of the Inspector, based on the matters and issues he/she identifies for examination.
9.
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Signature: Steven James Young (If you are filling in an electronic copy, (Chair Exhall Residents Association) please just type your name) Date: 02/12/2018
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Guidance notes for Representation Form 1. Introduction
1.1 The Planning and Compulsory Purchase Act 2004 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements and is sound. The publication of the Schedule of Proposed Main Modifications to the Borough Plan Publication (2017) document is a formal stage in the Examination process. Representations should relate specifically to the legal compliance and soundness of the proposed main modifications. The Council has prepared a schedule setting out the proposed Main Modifications it considers necessary in order for the Borough Plan to be found sound. This document, along with an updated Sustainability Appraisal Report and Habitats Regulations Assessment have now been published for public consultation, alongside other updated documents that helped inform the modifications.
2. Legal Compliance
2.1. The Inspector will first check that the plan meets the legal requirements under s20(5)(a) of the PCPA before moving on to test for soundness.
2.2. You should consider the following before making a representation on legal compliance:
• The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed. The LDS is effectively a programme of work prepared by the LPA, setting out the Local Development Documents (LDDs) it proposes to produce. It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination. If the plan is not in the current LDS it should not have been published for representations. The LDS should be on the LPA’s website and available at its main offices.
• The process of community involvement for the plan in question should be in general accordance with the LPA’s Statement of Community Involvement (SCI) (where one exists). The SCI sets out the LPA’s strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications.
• The plan should comply with the Town and Country Planning (Local Planning) (England) Regulations 2012 (the Regulations). On publication, the LPA must publish the documents prescribed in the Regulations, and make them available at its principal offices and on its website. The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified.
• The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan. This should identify the process by which the Sustainability Appraisal has been carried out, and the baseline information used to inform the process and the outcomes of that process. Sustainability Appraisal is a tool for appraising policies to ensure they reflect social, environmental, and economic factors.
3. Soundness
3.1. Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF, 2012). The Inspector has to be satisfied that the plan is positively prepared, justified, effective and consistent with national policy:
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• Positively prepared: This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
• Justified: The plan should be the most appropriate strategy when considered against reasonable alternatives, based on proportionate evidence.
• Effective: The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
• Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF.
4. General advice
4.1. If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance and the four requirements of soundness set out above. You should try to support your representation by evidence showing why the plan should be modified. It will be helpful if you also say precisely how you think the plan should be modified. Representations should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested modification, as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at the main modifications stage. After this stage, further submissions will be only at the request of the Inspector, based on the matters and issues he/she identifies for examination.
4.2. Where there are groups who share a common view on how they wish to see a plan modified, it would be very helpful for that group to send a single representation which represents the view, rather than for a large number of individuals to send in separate representations which repeat the same points. In such cases, the group should indicate how many people it is representing and how the representation has been authorised.
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