Proof of Evidence of Rachel Hooper

On behalf of Parish Council and Langley Burrell Residents Association (Joint Rule 6 Status)

Traffic on the B4069

Planning Appeal in respect of Land to the North and East of Barrow Farm,

The Town and Country Planning Act 2000 (as amended)

Town and Country Planning (Hearings and Inquiries Procedure) () (Amendment and Revocation) Rules 2015

PINS Ref AP 3139183

Wiltshire Council Reference 14/10433/OUT

This paper was drafted by Rachel Hooper, who was significantly supported and helped in the presentation of argument and evidence by Edward Barham, David Mannering, Richard Walker, Robert Whitrow, Robert Woodward and other members of the Langley Burrell Parish Council and Residents Association

1 Introduction

1.1 The primary author of this Proof of evidence is Dr Rachel Hooper, resident of

Langley Burrell since 1996. I have been supported in this effort by a team of residents of the village representing the villagers who will be significantly impacted in their everyday lives if this Development goes ahead.

1.2 We have faced considerable challenges in putting together our case. None of us are legal professionals and we have very little experience in participating in processes like this. I hope all parties will bear our ‘first timer’ status in mind. Equally, we will try to hold ourselves to the customs and rules of the process.

1.3 We are mindful of our obligation to provide objective evidence to this hearing.

Our evidence is largely non-technical, and is more qualitative than quantitative in nature.

However, we have striven to give evidence behind all our assertions and we speak from a position of great expertise about the experience of living in Langley Burrell village.

1.4 Our fundamental objection to this Planning Application is that it “would have an unacceptable impact upon the tranquil nature of this part of the countryside, the setting of listed buildings at Maud Heath Causeway as well as its relationship to the nearby villages of Langley Burrell and Kington Langley.”1 We believe the proposal is therefore contrary to the provisions of policies CP10, CP51, CP52 and CP58 of the Core

Strategy 2015, the NPPF as well as section 16(2) and 72(1) of the Planning (Listed

Building and Conservation Area) Act 1990. In this proof we put the case that the increased traffic on the B4069 has not been sufficiently modelled in the face of multiple proposed developments and many potential issues. If the

Development is approved, a better alternative would be to make the primary access point through the Northern Distributor Link road (NDL).

1 Para 5, Statement of Case

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2 Traffic on the B4069

2.1 This Proof focuses on the impact the Barrow Farm Development will have on the

B4069. We are ever mindful of the fact that, while we are trying to present evidence in the format required by this process, we are not experts in transport planning. We are trying to reflect our genuine, day-to-day experience of using this road and roads in the area.

2.2 This proof will cover the following points

1. The B4069/Maud Heath Junction

2. Cumulative development impact on traffic on the B4069 south of the Maud

Heath Junction

3. Roundabout access from the Development onto the B4069

4. Other issues with the B4069

5. Access off the NDL

3 B4069/Maud Heath junction

3.1 Of specific concern for the Residents, in all the evidence produced for this Planning

Application, there is no modelling of the impact of the additional traffic from the

Development on the junction of the B4069 and Maud Heath’s Causeway2, through the village of Langley Burrell. This junction serves not only Langley Burrell, but also a large

‘hinterland’ including Peckingell, Kellaways, Avon, East Tytherton, Tytherton Lucas,

Foxham and Charlcutt, being variously the shortest way to Chippenham or the M4. The

Queue Length modelling on Page 39 of the Transport Assessment stops at the proposed

Barrow Farm junction.

3.2 We commissioned our own assessment of traffic flow through this junction, at

Appendix G. We believe this is indicative of about 230 vehicles per peak period, per day,

2 Maud Heath’s Causeway in fact, runs from well behind Langley Burrell, through the village and turns left down the side of the B4069 into the top of Chippenham. However, the only other name for this road is ‘The Common’ which is equally imprecise as it also described the fields in question around Barrow Farm. For simplicity, in this proof, the road running east-west through Langley Burrell village will be referred to as Maud Heath’s Causeway.

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trying to turn both into and out of this junction, into the increasingly busy B4069.

3.3 Our experience is that, year-on-year, it gets more difficult to turn through this junction because of the volume of traffic already on the B4069. The implementation of a

50mph speed limit has produced some small improvement, but the volume of traffic, especially at peak times, means waits to turn out of Maud Heath’s Causeway south onto the B4069 and north on the B4069 turning into the Causeway are noticeably lengthening.

We are very concerned that, with the additional traffic from this Development and all the others being considered in this short length of road, the efficient of this junction will reduce.

3.4 The natural rise and bend of the road north of this junction, and any queueing created on the southbound B4069’s plethora of new junctions, will mean that rash decisions, made under pressure of time to turn left out of, or right into, the Causeway will significantly increase the risk of accidents at this junction.

4 Cumulative development impact on traffic on the B4069 south of the Maud

Heath Junction

4.1 We make no claim to technical knowledge on traffic modelling, but express our concern that what modelling has been carried out, has failed to consider the cumulative impact of all the potential developments that will directly impact the B4069. We question if enough detail has gone into the Transport Assessment for the B4069 in particular.

4.2 In the immediate area, we currently have proposals for –

1. An expansion of the workforce and HGV traffic at Wavin’s

2. The North Chippenham Consortium Development

3. The Barrow Farm Development

4. The Rawlings Green Development

5. Plans for Langley Park, including residential, retail and light industry use

6. A Northern Distributor Link road

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We cannot see that the Wavin expansion and the Langley Park Development have been included in the model.

4.3 Based on the planning proposals currently under discussion, in the 1000m between the B4069/Maud Heath junction and the B4069/Birch Grove junction in north

Chippenham, drivers, cyclists and pedestrians will face

1. The new Barrow Farm roundabout

2. The new NDL roundabout through the North Chippenham Development

3. A revised access for HGVs from Wavins

4. The existing Hill Corner Road junction

5. The new Cocklebury Link Road Scheme (extending the NDL)

6. The existing Pew Hill mini roundabout

7. A new double roundabout outside Langley Park and Birch Grove

4.4 Based on all the above factors, we do not think that the Paramics modelling results at Section 5 of the Transport Assessment are likely to be representative of the real case for the following reasons

1. There is no inclusion into the calculation of the function of the B4069/Maud

Heath’s Causeway junction.

2. Two localised, but significant traffic inputs from Wavins growth and Langley

Park Development have been omitted.

3. The model creates a break along this length of this road. It measures as route

8, the ‘B4069 between Eastern Link Road and B4122’ and 10, the ‘B4069 Langley

Road between Eastern Link Road and B4158 Road’.

4.5 A simple additive calculation3 of routes 8 and 10 suggests that morning, South

Bound journey times across all 3 models might exceed thresholds. We believe that, if the Paramics model included the stretch from Point 5/6 in the village data set – ie the eastern end of the village, through to the B4158 Malmesbury Road at Hathaway Retail

3 We accept this might not be a legitimate methodology for all data, but it seems intuitive in regard of change in journey time, if not GEH.

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Park, included the proposed growth of Wavin and the Langley Park Development, and all the new junctions along the route, there would be a severe increase in many of the model journey times. We would like to see these conditions modelled.

4.6 In our opinion, the cumulative effects of the developments listed above on traffic levels on the B4069 will significantly impact the safe and effective use of this road for drivers using both the B4069/Maud Heath’s Causeway junction and the length or road south of this junction. There seems to have been no modelling done to support or disprove our position.

5 Roundabout access from the Development onto the B4069

5.1 We interpret the reason the roundabout has been pulled into the Development site is in order to achieve the appropriate deflection on the approaches to the junctions. This creates a major realignment of the B4069.

5.1.1 One of our concerns is the fact that most of the hedgerow on the west side

of the B4069, south of the Maud Heath Causeway junction will need to be

removed to allow the roundabout to be constructed, along with visibility

requirements and footways and street lighting. This will have a severe impact on

the rural characteristics of the B4069 Maud Heath’s Causeway as well as the

environmental and ecological issues resulting from the loss of mature hedgerows.

5.1.2 Our second concern is that realignment of the eastern pavement also

represents realignment of Maud Heath’s Causeway. Although this is nowadays

only visible in the pavement edging, it is, nevertheless, a well-known historic

feature of this stretch of road.

6. Other difficult points on B4069

6.1 We believe there has been insufficient modelling and assessment of the impact of additional traffic on the whole length of the B4069 between the Hathaway roundabout

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and Junction 17 of the M4. This is a rural B road, with few major junctions, but many direct turnings from properties. It twists and turns in a number of notable points and is already a challenging and busy road to drive along. If traffic enters the B4069 near

Chippenham, then a large majority of it will then travel along the entire stretch of the

B4069 to Junction 17. The whole stretch of road should therefore be considered in respect of the impact from all the proposed developments.

6.2 We note and support the concerns expressed by the residents of Kington Langley4 about the junction with the road leading through their village. Figure 3.3 of the

Transport Assessment records the 4 accidents on the B4069 in Kington Langley.

6.3 We would extend these concerns to three other sites along the B4069 in particular.

6.3.1 The Stein Brook dip – this is the bend and dip immediately to the north

on the Parish Church, and intersected by Jacksoms Lane and the driveway of a

domestic property. This is a very narrow, curving and descending stretch or road

with steep banks on both sides and over-shadowed by woodland. It is passable

with relative ease when there are smooth flows of vehicular traffic, save for the

geometry and sudden changes in light conditions. However, with no pavement

and no margin at all to the road between the banks, if a pedestrian or cyclist is

encountered in this stretch, there is an immediate challenge to all road users as

rapid breaking is the only option for vehicles. Figure 3.3 of the Transport

Assessment records 1 pedestrian accident in this area. Any increase in vehicular

traffic and pedestrian/cyclist use of this stretch will only increase the number of

conflicts in this area. The new boundary to the urban area would bring the very

narrow, pavement-less dip in the B4069 at Stern Brook into closer proximity for

more pedestrians and cyclists. We would encourage the Inspector to closely

observe this stretch of road with a view to the safety it affords non-vehicular road

users in particular. If the Development is built, more pedestrians and cyclists will

need to traverse this stretch of road in order to create many circular routes,

4 Letter from Kington Langley Parish Council at Appendix E

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possibly encouraged there by the northern emergency exit from the Development.

6.3.2 The Corner, where the B4069 divides to go either into

Draycot Cerne, up to Junction 17 or continue through Sutton Benger is a well- known trouble spot. Local experience (again supported by Kington Langley PC) is that cars frequently mis-judge the corner and overshoot into the hedge to the north-east of the junction. More pertinently, it is getting increasingly congested and difficult to turn either from the motorway, right onto the B4069 and from

Sutton Benger, right towards the motorway. Other than the turning in Kington

Langley and to private properties, there are no options for traffic once north of the

B4069/Maud Heath junction to do anything but drive through the Sutton Benger

Corner in some direction. We believe that the impact of increased traffic from all the developments proposed to the north or Chippenham should be carried out on this junction.

6.3.3 The road between the Household Recycling Centre and the growing Draycot Lorry Park. When viewed from the motorway, the Council

Salt Depot and the Household Recycling Centre (HRC) have entry/exit turnings on the left/outside of a sweeping right hand bend. The Lorry Park has a turning, almost directly opposite, on the inner, right/inside of the turn. Critically, because of the geometry and hedgerow, the Lorry Park is mainly hidden from view when travelling both north and south. Not only does significant queueing occur on most mornings, before the HRP opens, but during the day the operators of the HRP frequently close the gates, creating impromptu queues back onto the road, or demand and the pace of throughput in the HRC creates long queues in both directions. Cars coming south off the motorway on an otherwise open, free- flowing road with a 60mph speed limit, frequently face a queue of stationary traffic in the main carriageway, a completely hidden turn for vehicles trying to exit the HRC, a queue of north-facing, stationery traffic sitting on the central slip-lane of the road, and large lorries and northbound traffic in the oncoming northbound

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lane. The potential for a traffic light system controlling traffic flow through

Junction 17 will do nothing to improve this issue, and indeed, has the potential to

increase queuing back from the junction for northbound traffic, such that the

situation becomes even more complex.

6.4 Just as with Junction 17 situation, we accept that none of these issues are created exclusively by the proposed Development. However, as currently configured, with exits onto the B4069, the Development will indisputably add more traffic pressure to this rural

B road. We ask that a proper investigation of the impact increased traffic flow will have at all these points along the B4069 up to Junction 17 is completed before a decision is made on this Development.

7. Access off the NDL

7.1 The NDL will be a purpose built distributor road, designed to current standards and capable of servicing this additional capacity. The B4069 has none of these advantages.

We understand there is a roundabout proposed on the NDL, south of Barrow Farmhouse and we believe the Developers should create a new junction on the link road, as indicated on the sketch below, and not exit directly onto the B4069.

We think this alternative access arrangement will have a number of benefits:

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7.1.1 The traffic from the Development would be shared east – west onto the

B4069 and A350 more evenly avoiding severe impacts on any one road. The

current layout places all the traffic onto the B4069 where some of it will head

south then turn left onto the NDL unnecessarily, increasing movement through

the new junction proposed at the B4069/NDL/Parsonage Way.

7.1.2 Another benefit of accessing the Barrow Farm Development off the new

link road, is that it will be more fully integrated with the North Chippenham

scheme and trips between the two proposals (eg to the education, retail facilities

etc) can be made with any additional trips on the B4069 or A350.

7.1.3 The new North Chippenham scheme incorporates bus stops and

presumably new bus routes. Therefore, a new access road with footways directly

linking the two development proposals will provide easier access for pedestrians

from the Development to access bus stops at North Chippenham. It could also

allow the scheme to be serviced by those same bus services visiting the North

Chippenham scheme. We note that none of these new bus routes visit Langley

Burrell village.

7.2 We would also ask for protection by time, much like the arrangement being made at

Junction 17 of the M4. The Transport Assessment provided by PFA for the North

Chippenham scheme, demonstrates that there is a need for the NDL to be in place prior to completion of that scheme in order to avoid severe impact on the B4069. We also understand that only a limited amount of the North Chippenham Development is permitted off the A350 and/or B4069 before the NDL is completed. Therefore, if this proposal is permitted, we ask that it should also be subject to the same conditions requiring the NDL to be complete prior to any further development.

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8 Summary

8.1 The B4069/Maud Heath junction In all the evidence produced for this Planning

Application, we can find no detailed modelling of the impact of the additional traffic from the Development, on the junction of the B4069 and Maud Heath’s Causeway. We are very concerned that, with the additional traffic from this Development, the proper function of this junction at peak times will simply stall, with the obvious risks of drivers making impatient and imprudent decisions.

8.2 Cumulative development impact on traffic on the B4069 south of the Maud

Heath Junction We believe there are significant failures in the modelling to date, to show the true impact of this Development and others, on transport through Langley

Burrell village. There is no inclusion into the calculation of the function of the

B4069/Maud Heath’s Causeway junction, two localised, but significant traffic inputs been omitted (Wavins growth and Langley Park) and the model creates a break along this length of this road, potentially reducing the cumulative journey time and queuing data for journeys from Langley Burrell village to ‘B4069 Langley Road between Eastern Link

Road and B4158 Malmesbury Road’. We would like to see this modelling data before a decision is made on this Development.

8.3 Roundabout access from the Development onto the B4069 We believe the proposed roundabout on the B4069 creates unacceptable damage to the hedgerow and rural perspective of this stretch or road and creates an unnecessary diversion in the historic course of Maud Heath’s Causeway.

8.4 Other issues on the B4069 We believe there has been insufficient modelling and assessment of the impact of additional traffic on the whole length of the B4069 between the Hathaway roundabout and Junction 17 of the M4. Traffic exiting this Development, and any of the other developments have very few options other than to travel the whole of this road length. We have specific concerns about increased traffic though the Stein

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Brook dip, Kington Langley junction and bends, the Sutton Benger Corner and the stretch between the Household Recycling Centre and Draycot Lorry Park.

8.5 Access off the NDL. The NDL will be a purpose built distributor road, designed to current standards and capable of servicing the additional capacity created by this

Development. The B4069 has none of these advantages. Therefore, it is the wish of the residents of Langley Burrell that, if the Development is allowed to proceed, it should be accessed off the NDL and development of the site be limited until the NDL is operational and the access has been created.

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