A Planning Appeal by AMBER REI HOLDINGS LIMITED

In respect of Former Poultry Processing Plant, HAUGHLEY PARK,

Proof of Evidence of Rupert Lyons

December 2020 The Planning Inspectorate’s Appeal Reference: APP/W3250/W/20/3258516 Mid District Council’s Application Reference: DC/19/02605 District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

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Contents Page

Introduction 1

Scope and Nature of Evidence 4

The Baseline Conditions 6

Relevant Land Use and Transport Planning Policy, Guidance and Precedent 15

The Appeal Proposal 36

Assessment of the Transport Planning Issues Arising from the Appeal Proposal 43

Consideration of the Rule Six Party’s Statement of Case and Third Party Representations 58

Summary Proof of Evidence and Conclusions 60

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List of Tables

Table 3.1 Modal Split of Journeys to Work in the Middle Layer Super Output Area

Table 6.1 Combined Traffic Generation and Attraction of the Appeal Proposal

Table 6.2 Comparison of the Traffic Generation and Attraction of the Appeal Proposal with the Traffic Attraction of the Lawful Use and the Former Use

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List of Appendices

RL-A Schedule of Core Documents

RL-B Photographs of the Access Road to Haughley Park and its Junction with Haughley New Road

RL-C Analysis of Speed Survey Data

RL-D Overlay of the 5 kilometre radius on Figure SCGT/1

RL-E National Rail Enquiries Facilities Report for Station

RL-F National Rail Enquiries Facilities Report for Stowmarket Station

RL-G Analysis of Location of Usual Residence and Place of Work by Method of Travel to Work (MSOA Level)

RL-H Suffolk County Council’s Highways Access Visibility Review, dated 11 December 2020

RL-I Visibility Splay Calculation

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Introduction

1.1 My name is Rupert Titus Beauchamp Lyons and my evidence to this Public Inquiry is concerned with the transport planning and highway engineering issues arising from the Mid Suffolk District Council’s (the District Council and/ or the Local Planning Authority) refusal of an outline planning application (with all matters reserved except for access)1 made by Amber REI Holdings Limited (the Appellant) for a proposed residential-led mixed-use redevelopment (the appeal proposal) of a former poultry processing plant on 11.2 hectares of land at the Haughley Park Estate adjacent to Haughley Park (a Grade I listed dwelling), near Stowmarket (the appeal site).

1.2 Suffolk County Council (the County Council) is the Local Highway Authority and Highways is the Strategic Highway Authority with responsibility for the strategic road network.

1.3 The District Council refused planning permission for the appeal proposal for seven reasons2, the first and fourth of which relate to the remoteness of the appeal site and the dependency that future residents and occupiers of the appeal proposal will have on car travel. It considers that the appeal proposal would amount to “development in the countryside remote from any easily accessible neighbouring settlement”; that “occupiers will inevitably have to rely on the car to access anywhere beyond the immediate development”; and that: “Services and facilities within sustainable settlements in the wider locality are not appropriately accessible”, “contrary to the principles of sustainable movement and climate change/ low carbon transition within the NPPF”.

1.4 I was first instructed by the District Council in September of 2020.

1.5 The evidence that I have prepared and provide for this appeal (reference APP/W3250/W/20/3258516) in this proof of evidence is true and I confirm that the opinions expressed are my true and professional opinions. I will refer to the core documents identified in my Appendix RL-A and my evidence to this Inquiry should be read in conjunction with the District Council’s Statement of Case, the Statement of Common Ground signed by Steven Stroud (on behalf of the District Council) and David Onions (of Pegasus Group, on behalf of the Appellant) (the SoCG), and the Statement of Common Ground on Transportation Issues signed by Craig Rawlinson (of Pegasus Group, on behalf of the Appellant) and me (on behalf of the District Council) (the TSoCG).

1.6 It should also be read in conjunction with the Proof of Evidence of Steven Stroud on planning matters and I will refer to the Statement of Case (prepared by James Bailey Planning) of Robert Williams (a ‘Rule 6’ party to these proceedings).

1 Reference DC/19/02605 2 DC/19/02605 Decision Notice (24 April 2020)

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My Qualifications and Experience

1.7 I have a Master of Science degree in Transportation Planning and Engineering from the University of Southampton. I am a Chartered Member of the Institute of Logistics and Transport, and I am a Liveryman of The Worshipful Company of Carmen – the oldest transport society in the world – and a Patron of the London Transport Museum.

1.8 In 1997, I became a founding Director of Transport Planning Associates Limited (formerly Pinnacle Transportation Limited), a practice of consulting transport planners, traffic engineers and infrastructure designers with offices in Bristol, Cambridge, London, Manchester, Oxford, and Welwyn Garden City. I previously held positions with White Young Green and Ove Arup & Partners, both large multi- disciplinary engineering consultancies.

1.9 During the course of that work, I have advised developers and promoters of a wide range of residential and residential-led development proposals in many regions of the from single dwellings to large urban extensions of up to 4,000 dwellings in mixed-use environments requiring significant investment in new transport infrastructure and services provision.

1.10 I am familiar with The Planning Inspectorate’s Procedural Guide, Planning appeals – England (July 2020), and the content of Annexes F and O.

1.11 I am also familiar with the appeal site and its environs having undertaken a site visit on Monday, 12 October 2020. I have walked from the appeal site to the village of and along several of the public rights of way (PRoW) in the vicinity. I have also driven from the appeal site to the railway stations at Elmswell and Stowmarket.

1.12 I am aware of a previous application for the residential redevelopment of the appeal site3 to provide 149 dwellings that was similarly refused by the District Council in February of 2019 because it considered that:-

. “the proposed redevelopment of the identified site for residential purposes represents an unsustainable form of development in the countryside for which there is no essential justification”; . that the appeal site “is remote from essential facilities and has limited provision of alternative modes of access”; . that, therefore, it “would create a development, the occupiers of which in all likelihood would be significantly reliant on the use of the private motor car”; . that: “Services to ensure sustainable development are also unavailable by reason of lack of lit footways leading to potential conflict with traffic”; and

3 Reference: DC/18/03592

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. that: “There is insufficient access to public transport alternatives available within short walking distance from the site to otherwise outweigh the considerations of the location and poor access to services outlined.”4

4 DC/18/03592 Decision Notice (13 February 2019)

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Scope and Nature of Evidence

2.1 My evidence to this Inquiry relates to the first (principle) and fourth (unsustainable development/ low carbon transition) reasons for the District Council’s refusal of planning permission for the appeal proposal5.

2.2 With reference to the main issues identified by the Inspector in his Case Management Conference Summary Note, it considers:-

. whether the appeal proposal would be in an appropriate location having regard to the development plan and national land use and transport planning policies; . whether it would provide acceptable access to services and facilities; and (although I acknowledge that this issue did not form part of the District Council’s reasons for refusal) . its effect on highway safety.6

The Structure of my Evidence to this Inquiry

2.3 Following these introductory sections, my evidence comprises:-

. Section 3: The Baseline Conditions – providing a short description of the appeal site and the local transport network, the existing opportunities for sustainable travel, together with the identification of the existing travel behaviour of those that reside in proximity to the appeal site; . Section 4: Relevant Land Use and Transport Planning Policy and Guidance – providing the land use and transport planning policy context for the appeal proposal, and identifying relevant guidance pertinent to the scope and extent of the reasons for refusal and the main issues identified; . Section 5: The Appeal Proposal – providing a short description of the appeal proposal and the off-site transport infrastructure improvements proposed by the Appellant, and noting the consultation responses of the local and strategic highway authorities, the District Council’s Case Officer’s assessment, and the first and fourth reasons for refusal; . Section 6: Assessment of the Transport Planning Issues Arising from the Appeal Proposal – providing my assessment of the issues raised by the first and fourth reasons for refusal, and in the Inspector’s Case Management Conference Summary Note; . Section 7: Consideration of the Rule Six Party’s Statement of Case and Third Party Representations – providing my review of the dominant themes related to transport and highway matters expressed in the third party representations received; and . Section 8: Summary and Conclusions – presenting my conclusion that the Local Planning Authority’s first and fourth reasons for refusal are well founded, that the appeal site is not an appropriate location for the appeal proposal having regard to the development plan and national land use and transport planning policies, that the appeal proposal does not provide an

5 DC/19/02605 Decision Notice (24 April 2020) 6 Case Management Conference Summary Note (23 October 2020), §6 (pages 1-2)

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acceptable level of access to the services and facilities that residents will require to meet their day-to-day needs, and that the appeal should be dismissed.

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The Baseline Conditions

The Appeal Site

3.1 The appeal site is described in both the District Council’s Statement of Case7 and in the Appellant’s Statement of Case8, and in the SoCG9. It is identified in Pegasus Group’s Site Location Plan drawing (number P18-0128_01_01, Revision B, dated 23 May 2018).

3.2 I understand from the District Council’s Delegated Report that the former use of the appeal site as a chicken processing plant ceased in 2012 after which it was redundant and that, therefore, it “has been vacant and unused for some eight years”10. I am also aware that it has recently issued a Certificate of Lawful Existing Use that confirms the lawful use of the appeal site as a poultry processing plant (Use Class B2).

3.3 The appeal site lies in the Parish of Haughley but it is not physically related to the village. It is common ground that the village of Haughley is (approximately) a travel distance of 3.5 kilometres (2.2 miles) from the appeal site11.

3.4 The nearest village is Wetherden, which is (approximately) a travel distance of 1.5 kilometres (0.9 miles) away12. It has limited facilities or services comprising a village hall, playing fields (including a play area, tennis courts and sports pitches), bus stops, and formerly a public house that I understand permanently closed in 2019.

3.5 A larger number of facilities and services are provided in Elmswell, which is (approximately) a travel distance of 3.5 kilometres (2.2 miles) away13.

3.6 More extensive facilities and services are provided in Stowmarket, which is (approximately) a travel distance of 7.0 kilometres (4.3 miles) away14.

3.7 The nearest primary school (Elmswell Community Primary School) is situated at Elmswell, and it is common ground that this school is (approximately) a travel distance of 3.8 kilometres (2.4 miles) from

7 The District Council’s Statement of Case (October 2020), Section 2 (page 3) 8 The Appellant’s Statement of Case (August 2020), Section 1 (pages 1- 3) 9 The Statement of Common Ground, Section 1 (page 1) 10 District Council’s Delegated Report (15 April 2020), page 12 11 Statement of Common Ground on Transportation Issues, §2.3 (page 2) 12 Ibid, §2.3 (page 2) 13 Ditto 14 Ibid, §2.2 (page 2)

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the appeal site15. The nearest co-educational secondary schools and sixth forms are in Stowmarket () and at Stowupland near Stowmarket (Stowupland High School). They are (approximately) travel distances of 8.1 kilometres (5.0 miles) and 10.6 kilometres (6.6 miles) away16 (respectively).

3.8 The nearest convenience store ( Co-op) is situated at Elmswell and it is common ground that this store is (approximately) a travel distance of 3.5 kilometres (2.2 miles) from the appeal site17. The nearest supermarket (Asda Stowmarket Superstore) at Stowmarket is (approximately) a travel distance of 7.8 kilometres (4.8 miles) away18.

Vehicular Access to the Appeal Site

3.9 Vehicular access to the appeal site is via a private road from the public highway at Haughley New Road (the U4977). I provide photographs of the road and of the priority junction of the access road with Haughley New Road in my Appendix RL-B. It is common ground that the distance from the public highway to the centre of the site is approximately 780 metres (0.5 mile).

3.10 I understand from Mr Williams’s Statement of Case that the private access road is within the ownership of Haughley Park Limited and that the Appellant has rights of access over it (i.e. to pass and repass at all times and for all purposes) but that such rights do not permit the Appellant to undertake any works to the road19.

Existing Highway Network

3.11 The local and wider highway network in the vicinity of the appeal site is illustrated in Figures 1 (Site Location) and 2 (Local Highway Network) in the Appellant’s Transport Assessment (prepared by Travis Baker). A useful drawing indicating road names, numbers and junctions is provided in Figure 3 (Study Area) in the same document.

15 Statement of Common Ground on Transportation Issues, Appendix SCGT/A 16 Ditto 17 Ditto 18 Ditto 19 Robert Williams’s Statement of Case, §§2.3, 2.4 & 2.6 (page 4) and Appendix 2

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3.12 A written description of the local highway network is also provided in the Transport Assessment20 and, in the context of my evidence, it is noteworthy that the Appellant identifies that:-

. on the southern side of Haughley New Street21, the grass verges vary in width between approximately 1.8 and 2.0m22; . in the vicinity of the appeal site, Haughley New Street is subject to the National Speed Limit (up to 60mph) and is an unlit rural road23; . the northern section of Park Street (between the junctions with Park Avenue and just before Stowmarket Road) is not provided with a footway and is unlit24.

3.13 I note that the County Council refers to what the Appellant’s Transport Assessment, Sustainable Travel Report and Transport Assessment – Addendum calls Haughley New Street as Haughley New Road (and I shall do the same from hereon in) and it advises that it “was formerly the main A45 east / west trunk road and was designed to a high (although superseded) design standard”25. In the vicinity of the Haughley Park access road junction, it is subject to the national speed limit (up to 60mph).

3.14 Based on a survey undertaken between Tuesday, 19 and Monday, 25 June 2018, Table 3.1 (on page 14) in the Transport Assessment provides 24-hour 85th percentile weekday traffic speeds of between 54-55mph (87-89kph) and 50-51mph (80-82kph) for eastbound and westbound traffic (respectively).

3.15 It should be noted that 85th percentile weekday traffic speeds are not the appropriate measure of the speed of traffic approaching the Haughley Park access road junction for the purposes of an assessment of highway safety at the junction. Based on analysis of the speed survey data provided in Appendix C to the Appellant’s Transport Assessment, I have determined that the relevant speeds are:-

. eastbound (measured to the west of the junction): 52.1mph (83.8kph); and . westbound (measured to the east of the junction): 48.1mph (77.4kph) [Appendix RL-C].

3.16 With regard to Park Road, I note the contradiction between the written description in paragraph 3.2.5 of the Appellant’s Transport Assessment that claims “grass verges of 2.0m to the west”, and the dimensions given in its Site Access (Sheet 2 of 2) drawing number /SK05, Revision B (in the Transport Assessment) and Site Access (Sheet 2 of 2) (Alternative Visibility Splays) drawing number /SK07, Revision A (in its Transport Assessment – Addendum) which suggest an available width ranging between 0.8 and 1.3m. It is also inconsistent with my own observation which shows that the latter is the case.

20 Transport Assessment, Section 3.2 (pages 11 to 13) 21 For reasons that I explain I my subsequent paragraph (3.13), I refer to this road as: Haughley New Road 22 Ibid, §3.2.3 (page 12) 23 Ibid, §3.2.4 (page 12) 24 Transport Assessment, §3.2.5 (page 12) 25 The County Council’s letter of 22 January 2020 to the District Council refers

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Existing Sustainable Travel Opportunities

Walking

3.17 The 400m, 1km and 2km pedestrian isochrones of the centroid of the appeal site are identified in Figure 4 (Pedestrian Isochrones and Local Facilities) in the Appellant’s Transport Assessment.

3.18 After referring to a “preferred general maximum walking distance of 2km”26, I note that the Transport Assessment seeks to characterise 2 kilometres as a “desirable maximum walking distance”27. I shall examine the guidance on what are typically referred to as desirable, preferred and maximum walking distances in the next section of my evidence.

3.19 I note also that the Transport Assessment acknowledges that “the most likely destination for pedestrian trips generated” by the appeal proposal “are the local facilities and bus stops in Wetherden”28. It also acknowledges that the local primary schools and shopping facilities in Elmswell and Haughley are beyond 2 kilometres from the appeal site.

Public Rights of Way

3.20 The Appellant’s Transport Assessment29 and Sustainable Travel Report30, and Mr Williams’s Statement of Case31 confirms that there are no PRoWs within or across the appeal site, and that is common ground. I note also from Figure 1 (Site Location) in the Transport Assessment – which shows the available PRoWs in the wider locality based on an extract from the Ordnance Survey – and Figure 4 (Pedestrian Isochrones and Local Facilities) that none abut the site either. Whilst they are traffic-free routes (other than agricultural vehicles where they coincide with farm tracks), it is also the case that they can only be accessed by first proceeding west on Haughley New Road which, as noted above, has no footways.

3.21 I have walked much of the length of the PRoWs between Haughley New Road and Wetherden, and I consider them most likely to be used by leisure walkers only during the hours of daylight.

26 Transport Assessment, §4.1.1 (page 19) 27 Ibid, §4.1.4 (page 19) 28 Ibid, §4.1.6 (page 19) 29 Transport Assessment, §3.1.5 (page 11) 30 Sustainable Travel Report, §3.1.3 (page 9) 31 Robert Williams’s Statement of Case, §2.5 (page 4)

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Cycling

3.22 A 5 kilometre radius from the centroid of the appeal site is identified in Figure 5 (Cycle Catchment and Routes) in the Transport Assessment. It is not explained, however, why it was not considered appropriate to be consistent with the approach taken in identifying the pedestrian isochrones. The 5 kilometre (3.1 miles) and 8 kilometre (5.0 miles) isochrones are provided in Figure SCGT/1 in the TSoCG.

3.23 It should be noted that ‘crow-fly’ distances do not correspond to journey distances on transport networks, and I consider that this drawing misrepresents the extent of the cycling catchment of the appeal site. Guidance published by the Chartered Institution of Highways & Transportation (CIHT) suggests that catchment areas in transport networks will be less than two-thirds of the area described by a circle32.

3.24 In my Appendix RL-D, I provide an overlay of the 5 kilometre radius on the 5 kilometre cycle isochrone of the appeal site that illustrates the extent of the exaggerated perception that crow-fly distances provide. In this case, the area of the 5 kilometre isochrones amounts to 30.08 square kilometres whereas the area of the circle is 78.54 square kilometres33, equivalent to 38.3% (i.e. just over one-third).

Local Bus Services

3.25 The nearest local bus services are accessible in Wetherden. The bus stops are located on Stowmarket Road in the vicinity of the Park Road and Church Street junctions. They are approximately 1.6 kilometres (1.0 mile) from the centroid of the appeal site.

3.26 The bus stops are served by the 384/385 bus service linking and Stowmarket with eight bus services Mondays to Fridays (excluding Bank Holidays) and four bus services on Saturdays. No bus services are available on Sundays.

3.27 In the context of a working (or school) day, the most recent timetable (published on 7 September 2020, and provide at Appendix SCGT/B to the TSoCG) indicates that towards Bury St Edmunds, there are services at 06:45 (first) and 07:25 arriving at various stops in the town at about 07:30 and 08:20 (respectively). Return journeys are available at 17:35 and 18:40 (last) arriving in Wetherden at 18:25 and 19:31 (respectively).

3.28 Towards Stowmarket (and on to Stowupland High School), there is a service at 08:09 (first) arriving at 08:24 (08:33 on School Days) and at Stowupland High School at 08:45 (on School Days). Return

32 Buses in Urban Developments, Section A.4.5 (page 18) 33 Based on πr2

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journeys are available at 15:50 from the High School (on School Days) arriving in Wetherden at 16:20, and from Stowmarket at 17:20 (last) arriving at 17:35.

Local Rail Services

3.29 It is common ground that Elmswell railway station is approximately 3.7 kilometres (2.3 miles) from the appeal site34. It lies on the -to-Ely Line with train services operated by Greater Anglia between Ipswich and Cambridge. There is (approximately) one service per hour in both directions from 05:34 (to Cambridge) and 05:43 (to Ipswich) to 22:44 (from Ipswich) and 23:40 (from Cambridge).

3.30 National Rail Enquiries reports that cycle stands are provided on platform 1 and that cycle lockers are provided on platform 2 but that no dedicated car park is provided at the station [Appendix RL-E].

3.31 In terms of journey times from the centroid of the appeal site to Elmswell Station, I estimate the following (based on an arrival time of 08:00):-

. Driving – 7 minutes (approximately); . Cycling – 13 minutes (approximately); . Public Transport – 35 minutes (approximately); and . Walking – 48 minutes (approximately).

3.32 The nearest railway station with a car park is at Stowmarket. It is common ground that Stowmarket railway station is approximately 7.4 kilometres (4.6 miles) from the appeal site35. It lies on the Great Eastern Main Line (London Liverpool Street to Norwich).

3.33 National Rail Enquiries reports that cycle parking is provided on each platform and in the car park, and that the station car park has 382 spaces with 7 dedicated for use by disabled persons [Appendix RL- F].

3.34 In terms of journey times from the centroid of the appeal site to Stowmarket Station, I estimate the following (based on an arrival time of 08:00):-

. Driving – 11 minutes (approximately); . Cycling – 25 minutes (approximately); . Public Transport – 47 minutes (approximately, via Elmswell Station); and . Walking – 1 hour, 37 minutes (approximately).

34 Statement of Common Ground on Transportation Issues, Appendix SCGT/A 35 Ditto

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Existing Travel Behaviour

3.35 In considering the propensity of prospective residents at the appeal proposal to use sustainable modes of travel, and with reference to ‘car or van availability’ data for the Lower Layer Super Output Area from the 2011 Census (provided at Appendix C to the District Council’s Statement of Case), 83.67% of households locally have access to at least one car or van and that 46.58% of households have access to two or more. It is common ground that the average number of cars or vans per household is 1.5236.

3.36 I have undertaken an analysis of the ‘location of usual residence and place of work by method of travel to work’ data for the Middle Layer Super Output Area from the 2011 Census (provided at Appendix D to the District Council’s Statement of Case) [Appendix RL-G]. That analysis demonstrates that the propensity for car travel for journeys to work (whether as a car driver or passenger, or as a passenger in a taxi) is in the order of 86%. Recognising that this data relates to the principal mode of travel and that many journeys to work utilise several modes of travel, I estimate that that rises to over 90% if you apply that same proportion of car journeys to the values for ‘bus’ and ‘train’. When considering the application of this data to the appeal site and bearing in mind the distances between it and the nearest bus stops and railway station, that estimate is based on the assumption that 86.2% of people whose principal mode of travel to work is by bus or by train will have either driven to or been driven to those bus stops or the railway station. A summary of my analysis is provided in Table 3.1 (overleaf).

36 Statement of Common Ground on Transportation Issues, §2.6 (page 2)

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Table 3.1 Modal Split of Journeys to Work in the Middle Layer Super Output Area

Place of Work Mode of Travel to Work Total

in

Walk Cycle Bus Train Motorcycle Passenger orCar Taxi DriverCar Other

Suffolk 6.9% 2.1% 2.5% 0.8% 1.1% 5.9% 80.4% 0.2% 100% (74.5%)

No Fixed Place 2.2% 0.7% 0.5% 3.0% 0.0% 4.5% 87.9% 1.2% 100% (12.8%)

Cambridgeshire 0.0% 0.0% 0.0% 6.0% 0.0% 1.7% 92.2% 0.0% 100% (3.7%)

Essex 0.0% 0.0% 0.0% 1.1% 2.3% 5.7% 89.8% 1.1% 100% (2.8%)

Greater London 6.3% 1.3% 1.3% 63.3% 0.0% 3.8% 24.1% 0.0% 100% (2.5%)

Norfolk 0.0% 1.9% 1.9% 9.3% 0.0% 1.9% 85.2% 0.0% 100% (1.7%)

Elsewhere in UK 12.5% 4.2% 0.0% 2.1% 0.0% 0.0% 79.2% 2.1% 100% (1.5%)

Hertfordshire 0.0% 0.0% 0.0% 0.0% 0.0% 8.3% 91.7% 0.0% 100% (0.4%)

Bedfordshire 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100% 0.0% 100% (0.2%)

Total 5.8% 1.8% 2.0% 3.0% 0.9% 5.4% 80.8% 0.4% 100% (100%)

Combined Car Driver 86.2% or Passenger

Estimated Car Driver or Passenger to Bus 1.7% Stop

Estimated Car Driver or Passenger to 2.6% Railway Station

Estimated Total Car 90.5% Driver or Passenger

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3.37 With reference to the ‘trips to school by main mode, trip length and age’ data for England from the 2019 National Travel Survey (provided at Appendix E to the District Council’s Statement of Case), it is clear that there is a tendency for significant decreases in the propensity for school age children to walk to school as the length of those journeys increases.

3.38 For younger children (aged between 5 and 10), 80% walk up to 1 mile (1.6 kilometres). That falls by 76% to 19% if the journey is between 1 and 2 miles (1.6-3.2 kilometres) and further by 95% to 1% for journeys greater than 2 miles (3.2 kilometres).

3.39 For older children (aged between 11 and 16), 95% walk up to 1 mile (1.6 kilometres). That falls by 44% to 53% if the journey is between 1 and 2 miles (1.6-3.2 kilometres) and further by 89% to 6% for journeys greater than 2 miles (3.2 kilometres).

3.40 There are, unsurprisingly in my view, corresponding increases in the use of the car as the length of those journeys increase.

3.41 For younger children, 18% travel by car up to 1 mile (1.6 kilometres). That increases almost four-fold (394%) to 71% if the journey is between 1 and 2 miles (1.6-3.2 kilometres) and further by 23% to 87% for journeys greater than 2 miles (3.2 kilometres).

3.42 For older children, 3% travel by car up to 1 mile (1.6 kilometres). That increases over nine-fold (933%) to 28% if the journey is between 1 and 2 miles (1.6-3.2 kilometres) and further by 32% to 37% for journeys greater than 2 miles (3.2 kilometres).

Concluding Remarks

3.43 On the face of it, therefore, and in the context of its accessibility to sustainable modes of travel, I consider that this site can be reasonably and fairly be described as isolated. In the context of the appeal proposal, I consider that such isolation means that it is remote from the day-to-day services and facilities that future occupiers would need access to such that the only realistic choice of mode of travel will be the private car.

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Relevant Land Use and Transport Planning Policy, Guidance and Precedent

4.1 The relevant land use and transport planning policy is provided in the National Planning Policy Framework (February 2019, as amended by a Written Ministerial Statement in June 2019) (the Framework) and in the development plan framework. The component parts of the development plan framework are identified in section four of the District Council’s Statement of Case.

4.2 Guidance on the provision of sustainable travel opportunities has, most recently, been published by the CIHT and the Department for Transport (DfT). I note that the Appellant acknowledges the guidance provided in Providing for Journeys on Foot (2000) and the Manual for Streets (2007), in particular, the concept of ‘walkable neighbourhoods’37.

4.3 Standards for the geometric design of at-grade priority junctions is provided in the relevant sections of the Manual for Streets and the Design Manual for Roads and Bridges (DMRB). I note also that the Appellant acknowledges the guidance provided in the County Council’s Suffolk Design Guide for Residential Areas (2000) (Suffolk Design Guide), in particular the number of dwellings that can be served by a single point of access38.

The National Planning Policy Framework

4.4 The fourth reason for refusal asserts that the appeal proposal “is considered contrary to the principles of sustainable movement and climate change/ low carbon transition” provided within the Framework.

Achieving Sustainable Development

4.5 The Framework tells us that: “The purpose of the planning system is to contribute to the achievement of sustainable development”39; and “that the planning system has three overarching objectives, which are interdependent”, economic, social and environmental40. It also guides us to “take local circumstances into account”, and “to reflect the character, needs and opportunities of each area”41.

37 Transport Assessment, §§4.1.1 & 4.1.2 (page 19) 38 Ibid, §5.2.3 (page 22) 39 National Planning Policy Framework, §7 (page 5) 40 Ibid, §8 (page 5) 41 Ibid, §9 (page 5)

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4.6 Central to the Government’s ambition “is a presumption in favour of sustainable development”42. In the context of decision-taking, the presumption engages with more than simply transportation matters. I therefore leave it to Mr Stroud to address the operation of the presumption.

Rural Housing

4.7 In applying that philosophy of sustainable development to new housing in rural areas, the Framework guides us to locate new housing “where it will enhance or maintain the vitality of rural communities”. It recognises that: “Where there are groups of smaller settlements, development in one village may support services in a village nearby”43 but steers us against the development of isolated homes in the countryside unless specific circumstances apply44.

4.8 Further in recognising that development proposals “to meet local business and community needs in rural areas may” be beyond existing settlements, and that such locations may not be “well served by public transport”, it maintains the requirement that such development “exploits any opportunity to make a location more sustainable (for example by improving the scope for access on foot, by cycling or by public transport)”45.

Promoting Sustainable Transport

4.9 Paragraph 102 of the Framework includes the core land use and transport planning principle that “opportunities to promote walking, cycling and public transport use are identified and pursued”46 and paragraph 103 that:

“Significant development should be focussed on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.”47

4.10 It is noteworthy that the Framework does recognise that the “opportunities to maximise sustainable transport solutions will vary between urban and rural areas”48, and that this should be taken into account in decision-taking.

42 National Planning Policy Framework, §10 (page 5) 43 Ibid, §78 (pages 21-22) 44 Ibid, §79 (page 22) 45 Ibid, §84 (page 24) 46 Ibid, §102 (page 30) 47 Ibid, §103 (page 30) 48 Ditto

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4.11 It should also be noted that the Framework defines ‘major development’ as “development where 10 or more homes will be provided”49 and ‘sustainable transport modes’ as:

“Any efficient, safe and accessible means of transport with overall low impact on the environment, including walking and cycling, low and ultra low emission vehicles, car sharing and public transport.”50

4.12 The Framework does not define the term ‘car sharing’ and, as a transport planning professional, I take it to mean an arrangement where people take it in turns to collect and drive colleagues to work, or other people’s children to school (for example) in order to avoid the unnecessary use of under- occupied vehicles. In my experience, car sharing is often coordinated by employers and schools on a membership basis. For outbound journeys, therefore, car sharers tend to have different trip origins and a common destination, and the opposite for return journeys.

Considering Development Proposals

4.13 Paragraph 108 of the Framework requires that:

“In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that:

a) Appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location;

b) Safe and suitable access to the site can be achieved for all users; and

c) Any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree.”51

4.14 Paragraph 109 maintains that:

“Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.”52

49 National Planning Policy Framework, Annex 2: Glossary (page 68) 50 Ibid, Annex 2: Glossary (page 72) 51 Ibid, §108 (pages 31-32) 52 Ibid, §109 (page 32)

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4.15 In that context, paragraph 110 tells us that applications for development should, inter alia:-

“a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;

c) Create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards”.53

4.16 Finally, paragraph 111 requires that all “developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed”.54

Mid Suffolk Local Plan (1998) as amended by the First Alteration to the Mid Suffolk Local Plan (on 13 July 2006)

4.17 The Mid Suffolk Local Plan (1998) as amended by the First Alteration to the Mid Suffolk Local Plan (on 13 July 2006) has mostly been superseded by the Core Strategy (2008) and Focused Review (2012). That said, there are a number of saved policies pertinent to the consideration of the appeal proposal.

Policy T10 – Highway Considerations in Development

4.18 When considering planning applications for development, Policy T10 requires the District Council to have regard, inter alia, to the following highway matters:-

. safe access and egress; . the suitability of existing roads giving access to a development, in terms of the safety and freedom of flow of traffic, and pedestrian safety; and . whether the needs of pedestrians and cyclists have been met.

53 National Planning Policy Framework, §110 (page 32) 54 Ibid, §111 (page 32); Transport Statement, Transport Assessment and Travel Plan are defined in Annex 2: Glossary (pages 72-73)

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Policy T12 – Designing for People with Disabilities

4.19 Policy T12 expects “highway schemes, including roads, footways, parking and pedestrian priority areas, to be designed to accommodate the needs of people with disabilities”55.

Core Strategy

4.20 The District Council recognises that: “Reducing the need to travel must be met with accessibility to services and facilities by a range of alternatives to the car and freight transportation. The number of older people and the percentage of the population living in isolated rural areas mean that Mid Suffolk must improve community and public transport options and actively encourage less reliance on private car usage”56.

4.21 Chapter 2 of the Core Strategy (2008)57 describes the District Council’s spatial strategy for Mid Suffolk. approach to delivering sustainable development. It acknowledges that as a result of the rural nature of the district that “the achievement of environmental sustainability will often be limited in transport terms”58.

Core Strategy Focussed Review

4.22 Chapter 3 of the Core Strategy Focussed Review (2012) describes the District Council’s approach to delivering sustainable development. It acknowledges that as a result of the rural nature of the district that “the achievement of environmental sustainability will often be limited in transport terms”59.

Policy FC 1 – Presumption in favour of Sustainable Development

4.23 Policy FC 1 reflects the presumption in favour of sustainable development contained in the Framework, and requires that the appeal proposal is “assessed against the policies in the National Planning Policy Framework taken as a whole”60.

55 Mid Suffolk District Local Plan as amended by the First Alteration to the Mid Suffolk Local Plan, Section 2.7 (Transport), Policy T12 56 Core Strategy, §1.44 (page 12) 57 To be read in conjunction with the Mid Suffolk District Core Strategy Focused Review 58 Core Strategy Focused Review, §3.7 (page 8) 59 Ibid, §3.7 (page 8) 60 Ibid, Policy FC 1 (page 9)

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Policy FC 1.1 – Mid Suffolk Approach to Delivering Sustainable Development

4.24 Policy FC 1.1 describes the District Council’s approach to delivering sustainable development and requires the appeal proposal to “demonstrate the principles of sustainable development”. Further, it requires the appeal proposal to “conserve and enhance the local character f the different parts of the district” and demonstrate how it “contributes to meeting the objectives and policies of the Mid Suffolk Core Strategy and other relevant documents”61.

The Haughley Parish Neighbourhood Plan

4.25 The Neighbourhood Plan was adopted by the District Council in October of 2019 and it now forms part of the development plan framework. It covers the period up to 2036. Its fifth objective is: “To ensure that traffic and transport issues in Haughley Parish are tackled, including enhanced provision for walking and cycling”62.

Policy HAU15 – Rights of Way and Access

4.26 Policy HAU15 of the Neighbourhood Plan requires new housing development to “take every opportunity to provide or improve connections from the development to the existing network of paths and bridleways in the Parish”63.

Relevant Guidance and Standards

Better Planning, Better Transport, Better Places

4.27 Better planning, better transport, better places was published by the CIHT in 2019. It is relevant to the consideration of the sustainability characteristics of the appeal site and to the propensity for residents at the appeal proposal to use sustainable modes of travel.

4.28 It provides a critical review of the integration of planning and transport that starts with the premise that “governments have attempted to encourage a more sustainable approach to transport within spatial planning but have made limited progress”. It acknowledges that the Framework “has moved national policy in the right direction, but practice must also change significantly in a number of ways if we want future developments to provide healthy, successful places for people to live in”. It suggests that:

61 Ibid, Policy FC 1.1 (page 11) 62 Haughley Parish Neighbourhood Plan, §4 (page 6) 63 Haughley Neighbourhood Plan (page 41)

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“Integrating sustainable transport into new developments is key to achieving that outcome” and asserts that:

“Our quality of life depends on transport and easy access to jobs, shopping, leisure facilities, and services. We need an efficient and integrated planning and transport system to not only support a strong and prosperous economy but to reduce carbon emissions.”64

4.29 It expresses “the increasing frustration of a wide range of organisations and opinion formers who have identified that current practice leads to more car-based development, contrary to the stated aims of national planning policy”65 and aims “to provide practical advice for everyone involved in the planning process”66.

4.30 In setting out its objective of supporting the delivery and scale of housing growth required by the Government while delivering more sustainable transport outcomes, it suggests that:

“Housing that is poorly located and inaccessible by sustainable transport modes either [sic] locks residents into long and expensive journeys on congested roads which leads to socio-economic marginalisation and degrades our natural environment.”67

4.31 It tells us that the Government wants “quality housing of the right kind in the right places” and that that means “not just good design but also development that is easily accessible by modes other than [the] car”68.

4.32 In the context of the appeal proposal and at a strategic level, it cautions that site selection “driven purely by the availability of land is likely to result in a highly unsustainable pattern of development”69.

4.33 In setting strategic objectives for sustainable transport planning strategies for rural contexts, it recognises that:

“In rural areas, access to primary, secondary, and post-16 education is likely to be a major issue for local authorities and residents. Any significant development is likely to result in an increase in the number of entitled secondary-age students and should, wherever possible, be directed towards locations where walking and cycling to school are credibly achievable or where public

64 Better planning, better transport, better places, Executive Summary (page 5) 65 Better planning, better transport, better places, §1.1 (page 8) 66 Ibid, §1.2 (page 8) 67 Ibid, §1.3 (page 8) 68 Ibid, §1.3 (page 9) 69 Ibid, §4.1 d (page 19)

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transport options exist or can be provided. Primary children should be able to walk easily and safely to school.”70

4.34 In considering new housing development remote from areas where employment, services and other amenities already exist, it cautions that that “can easily lead to people having to make long journeys to meet even basic day-to-day needs, and the distance and nature of these journeys risks making driving essential for all but the most confident and committed”71.

Building Sustainable Transport into New Developments: A Menu of Options for Growth Points and Eco-towns

4.35 Building Sustainable Transport into New Developments was published by the DfT in 2008. It is also relevant to the consideration of the sustainability characteristics of the appeal site and to the propensity for residents at the appeal proposal to use sustainable modes of travel.

4.36 It tells us that: “In order to influence travel behaviour it is imperative that the future needs of a community are considered and captured through good quality planning before infrastructure is put in place”. Moreover, it asserts that: “Opportunities must be taken within the planning process to make cycling, walking and public transport the modes of choice” and it argues that: “These modes must be made more convenient for the majority of journeys than car usage, in order to promote genuine modal shift”72.

4.37 It provides a ‘Developer checklist’ (on page 6) that reminds us that the integration of housing, employment needs and transport facilities is central to the sustainability of a development and that consideration should be given to its connectivity to larger urban areas, major zones of employment, retail and leisure facilities, and the existing road and rail network. It also advocates the provision of “facilities within the development that will reduce the need to travel”73.

4.38 As with other guidance, that I refer to below, it discusses the concept of a ‘walkable neighbourhood’ as being characterised “as having a range of facilities within 10 minutes’ walking distance (around 800 metres)”. It acknowledges that “the propensity to walk or cycle is not only influenced by distance but also the quality of the experience” and notes that “people may be willing to walk or cycle further where their surroundings are more attractive, safe and stimulating”. Building on that proposition, it suggests that developers “should consider the safety of routes (adequacy of surveillance, sight lines and appropriate lighting)” as well as other factors74. Finally, in respect of this topic, it reminds us that street

70 Ibid, §4.3 c (page 27) 71 Ibid, §4.3 e (page 28) 72 Building Sustainable Transport into New Developments, Good Planning and Design (page 5) 73 Ibid (page 6) 74 Ibid, Street design (page 8)

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design should be “inclusive” (i.e. providing for all people regardless of age and ability) and of the obligations enshrined in the Disability Discrimination Act 200575.

4.39 With regard to achieving a reduction in car use, it reminds us that:

“Encouraging a reduction in car dependency is a key component of promoting sustainable transport usage in new developments. Developers will need to decide how best to integrate such measures into the design of their new communities.”76

“In order to encourage a reduction in car use, public transport will need to be frequent, reliable and easily accessible.”77

4.40 In considering access to local bus services beyond the extent of a development itself, it suggest that:

“accessible and reliable bus services will be needed to provide inhabitants with access to local employment, leisure facilities, nearby town centres and connections to key inter-urban routes. This will require close co-operation between the public and private sector to ensure that bus provision matches the community’s need.”78

Planning for Walking

4.41 Planning for Walking was published by the CIHT in 2015. It is, similarly, relevant to the consideration of the sustainability characteristics of the appeal site and to the propensity for residents at the appeal proposal to walk to and from local facilities and services.

4.42 It describes the characteristics of pedestrian journeys, lists the benefits of walking, identifies factors that discourage walking and how they can be overcome, summarises the legal framework that applies to pedestrians, and outlines the way that plans and strategies for pedestrian travel are developed.

4.43 Interestingly, and unsurprisingly in my view, it acknowledges that the propensity for people to walk in rural areas is less than in urban areas:

“At approximately 200 journeys per person per year, walking is remarkably consistent from cities to small towns. Only in rural districts do people walk significantly less.”79

75 Ibid (page 9) 76 Ibid, Reducing car use (page 11) 77 Building Sustainable Transport into New Developments, Providing access to public transport (page 13) 78 Ibid, Buses (page 14) 79 Planning for Walking, §1 (page 4)

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4.44 With regard to the propensity for people to walk, and with reference to the National Travel Survey in 2012, it notes that:

“In 2012 walkers accounted for 79 per cent of all journeys shorter than 1 mile, but beyond that distance cars are the dominant mode; and

For journeys that are 1 to 2 miles long, 26 percent are made on foot, more than by bus; beyond 2 miles, trips on foot are few and are outnumbered by bus trips.”80

4.45 In trying to explain an identified decline in the proportion of pedestrian journeys made (when compared to data for 1972/ 73), it notes a declining trend in the number of journeys that people make that are less than one mile and an increasing trend in the number of journeys that are more than two miles. It concludes, therefore, that it “is not just that people are less likely to make short journeys on foot, but rather that fewer of the journeys they make can be accomplished on foot. Another way of putting this is that the destinations people want to reach are now further apart”81.

4.46 Interestingly, and over a similar time period, it notes that the average length of a pedestrian journey increased from 0.7 to 0.85 miles (1.1 to 1.4 kilometres)82. It acknowledges that the “power of a destination determines how far people will walk to get to it” and, in that context, compares bus stops in residential areas for which “400 metres has traditionally been regarded as a cut-off point” with railway stations where people “will walk up to 800 metres” reflecting “the greater perceived quality or importance of rail services”83.

4.47 Finally, and in the context of promoting walking as a sustainable mode of travel, it reminds us that a Travel Plan “is a long-term management strategy for an occupier or site that seeks to deliver sustainable transport objectives through positive action and is articulated in a document that is regularly reviewed”84.

Designing for Walking

4.48 Designing for Walking was also published by the CIHT in 2015. It explains how facilities for walking should be designed, and it stresses that the expression ‘people walking’ “should be taken as shorthand to include people using wheelchairs and mobility scooters as well as those using pushchairs or even children using scooters”. It emphasises that: “Designing for walking must be a fully inclusive process”

80 Ibid, §2.1 (page 6) – see also Figure 1 81 Planning for Walking, §2.1 (page 6) – see also Figure 2 82 Ditto 83 Ibid, §6.4 (page 30) 84 Ibid, §7 (page 35)

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and recommends that it be read in conjunction with the Manual for Streets (2007) and Manual for Streets 2 (2010)85.

4.49 With regard to footway width, it acknowledges that it “would be wrong to be over prescriptive about footway widths” noting that each location “needs to be assessed to determine the width requirement for pedestrians”. In recommending an absolute minimum width of 1.8m and a desirable minimum width of 2.0m (and a preferred width of 2.6m (especially adjacent to high speed roads)), it does not suggest that “widths less than 1.8m should never be provided, as it is clear that existing narrow footways do provide a level of pedestrian amenity”. It does, however, caution the designer: “there is a lower limit where the footway width is insufficient to accommodate normal walking activity in safety.”86

4.50 With regard to the provision of street lighting, it tells us that:

“Lighting is important to ensure that walking routes remain attractive for use at night in terms of personal security and [to] ensure pedestrians are seen by other road users”.87

Inclusive Mobility – A Guide to Best Practice on Access to Pedestrian and Transport Infrastructure

4.51 Inclusive Mobility – A Guide to Best Practice on Access to Pedestrian and Transport Infrastructure was published by the DfT in 2005 and provides useful guidance on the width of footways. It is relevant to the consideration of the acceptability of the proposed new footways along the southern side of Haughley New Road (from the Haughley Park access junction) and the western side of Park Road (to the Park Avenue junction).

4.52 It advocates that a clear width of 2.0m “should be regarded as the minimum under normal circumstances”. In acknowledging that may not always be possible due to physical constraints, it suggests that a width of 1.5m “could be regarded as the minimum acceptable under most circumstances”. In considering circumstances where there is an obstacle, it suggests that a width of 1.0m should be regarded as the “absolute minimum” and then only for a “maximum length” of 6m88.

Guidelines for Providing for Journeys on Foot

4.53 The Guidelines for Providing for Journeys on Foot was published by the (then) Institution of Highways & Transportation in 2000. It is relevant to the consideration of the sustainability characteristics of the

85 Designing for Walking, §1.1 (page 3) 86 Ibid, §4.2 (page 7) 87 Designing for Walking, §4.5 (page 8) 88 Inclusive Mobility, Section 3.1

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appeal site and to the propensity for residents at the appeal proposal to walk to and from local facilities and services. It reminds us that:

“Walking is the most sustainable form of travel and provides one way of helping to reduce pressures on the environment. It uses less space per person than any other form of travel. It burns no fossil fuels, involves no harmful emissions, and can accommodate peaks in use more easily and at less cost than any other mode.”89

4.54 With regard to the consideration of acceptable walking distances, it tells us that: “An average walking speed of 1.4 m/s can be assumed, which equates to approximately 400m in five minutes or three miles per hour”90.

4.55 Table 3.2 (on page 49) of the guidance “contains suggested acceptable walking distances, for pedestrians without a mobility impairment for some common facilities” and advises that these “may be used for planning and evaluation purposes”91. Those suggested acceptable walking distances are categorised as: ‘desirable’, ‘acceptable’ and ‘preferred maximum’ distances.

4.56 In discussing existing pedestrian routes, it tells us that providing “a satisfactory width of footway, including separation distance from motor vehicles, is important to enable pedestrians to walk at their chosen speed, to escort children, to walk in groups, and to pass others safely”92.

4.57 With regard to footway widths, it, too, recommends an absolute minimum width of 1.8m, a desirable minimum width of 2.0m and a preferred width of 2.6m93. Again, it does not suggest that “widths less than 1.8m should never be provided, as it is clear that existing narrow footways do provide a level of pedestrian amenity”; but it does, however, caution the designer: “there is a lower limit where the footway width is insufficient to accommodate normal walking activity in safety.”94

4.58 Furthermore, and where possible, it suggests “designers should consider widening of footways where pinch points would normally be created”95.

4.59 With regard to shared surfaces, it tells us that: “The key to successful shared areas is to ensure that surfacing does not look like normal carriageway”. Further, that: “Speed restraint is important if vehicles are likely to encounter pedestrians” and that that can be achieved in the horizontal alignment or with

89 Guidelines for Providing for Journeys on Foot, §1.21 (page 16) 90 Ibid, §3.30 (page 48) 91 Guidelines for Providing for Journeys on foot, §3.32 (page 48) 92 Ibid, §3.45 (page 51) 93 Ibid, §5.8 (page 74) 94 Ibid, §5.9 (page 74) 95 Ibid, §5.10 (page 74)

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other traffic calming devices96. In Table 5.1 (on page 76) of the guidance, it provides a summary of examples of traffic speed control measures in shared areas.

Planning for Cycling

4.60 Planning for Cycling was published by the CIHT in 2014. It is also relevant to the consideration of the sustainability characteristics of the appeal site and to the propensity for residents at the appeal proposal to cycle to and from local facilities and services.

4.61 It describes the characteristics and benefits of cycling, summarises the benefits of cycling (on page 6), identifies factors that discourage cycling and how they can be overcome, summarises the legal framework that applies to cyclists, and outlines the way that plans and strategies for cycling are developed.

4.62 It tells us that: ”Cycling is an important part of urban transport”97, and notes that “only 15% of the population cycle once a week or more, and around 65% do not cycle at all”98. It notes also that: “The majority of cycling trips are for short distances, with 80% being less than five miles and with 40% being less than two miles”99.

4.63 In considering the barriers to cycling, it notes that: “Fear of traffic is one of the main factors that discourage people from cycling, and cyclists (along with pedestrians) experience proportionately higher rates of road casualties than any other road users except motorcyclists”100. Recognising that this barrier has more to do with “people’s perceptions and habits”, it identifies that the challenge to encourage more people to cycle is “improving the environment for cycling by making it more attractive and comfortable”101. In that respect, I note that the guidance considers that “it is unrealistic to expect many existing and potential cycle users to find high volume or fast-moving mixed traffic conditions either attractive or comfortable”102.

4.64 With reference to Local Transport Note 02/08 (Cycle Infrastructure Design) now withdrawn and replaced with Local Transport Note 1/20, Cycle Infrastructure Design (2020), it notes that:

“… at speeds of twenty miles per hour and below, cycle traffic and motor traffic readily mixes. At speeds up to thirty miles per hour, it may be appropriate to manage traffic within the

96 Ibid, §§5.19 & 5.20 (page 76) 97 Planning for Cycling, Introduction (page 3) 98 Ibid, Cycling Characteristics, Behaviour and Trends in the UK (page 3) 99 Ibid, Who Cycles and Why? (page 4) 100 Ibid, Road Safety (page 7) 101 Ibid, Road Safety (page 9) 102 Ibid, Overall Principles (page 17)

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carriageway by providing separate lanes for cycle traffic. At speeds greater than thirty miles per hour and for volumes of more than 10,000 vehicles per day, it may be appropriate to provide infrastructure for cycle traffic separate from motor traffic.”103

4.65 In considering recent growth trends in cycling that “has taken place mainly in congested inner urban areas and in leisure cycling”, it notes that: “On-road cycling in suburbs and rural areas has changed little from the low levels of the 1990s”104.

4.66 With regard to the promotion of cycling, the guidance suggests that: “Residential travel plans are also helpful in encouraging more people to cycle”, recognising that “people are most likely to change their travel choices when they experience a life-changing event, such as moving house”105.

Cycle Infrastructure Design (Local Transport Note 1/20)

4.67 Cycle Infrastructure Design (Local Transport Note 1/20) was published by the DfT in 2020. It is also relevant to the consideration of the sustainability characteristics of the appeal site and to the propensity for residents at the appeal proposal to cycle to and from local facilities and services. It tells us that:

“New housing development provides a major opportunity to create new and improved cycle infrastructure.”106

4.68 Helpfully, it identifies “five core design principles which represent the essential requirements to achieve more people travelling by cycle or on foot, based on best practice both internationally and across the UK”107, as: “Coherent; Direct; Safe; Comfortable and Attractive”108. These principles are described in section 4.2 of the guidance (on pages 30 to 31), and further in the ‘Cycling Level of Service Tool (provided at Appendix A (on pages 172 to 177)).

4.69 It, too, recognises that: “Motor traffic is the main deterrent to cycling for many people with 62% of UK adults feeling that the roads are too unsafe for them to cycle on”. Further, it notes that: “On busier and faster highways, most people will not be prepared to cycle on the carriageway, so they will not cycle at all, or some may unlawfully use the footway” 109.

103 Ditto 104 Ibid, Recent Growth Trends (page 10) 105 Planning for Cycling, Residential Travel Plans (page 23) 106 Cycle Infrastructure Design (Local Transport Note 1/20), §14.3.1 (page 155) 107 Ibid, §1.5.1 (page 7) 108 Ibid, §1.5.2 (page 7) 109 Ibid, §4.4.1 (pages 32-33)

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4.70 In Figure 4.1 (on page 33), it summarises “the traffic conditions when protected space for cycling” is appropriate. For speed limits above 40mph and regardless of volume, it notes that expecting cyclists to mix with motor traffic is “suitable for few people and will exclude most potential users and/ or have safety concerns”. In such circumstances, it considers the appropriate provision “suitable for most people” is a fully kerbed cycle track. Importantly, the guidance tells us that:

“Although there may be fewer cyclists and pedestrians in rural areas, the same requirements for separation from fast moving motor vehicles applies.”

“Cycle lanes on the carriageway can be appropriate on less busy roads with lower speed limits, but do not provide any physical protection from motor vehicles and so do not adequately meet the needs of most vehicles on busier and faster roads.”110

4.71 In Table 5-2 (on page 43), the guidance identifies desirable minimum and absolute minimum widths of 2.0m and 1.5m (respectively) for on-carriageway one-way cycle lanes. It also tells us that: “Cycle lanes less than 1.5m wide should not normally be used as they will exclude the use of the facility by larger cycles and are therefore not inclusive”111. Further, and with regard to traffic lane widths for roads with a speed limit of 40mph, Table 7-2 (on page 75) tells us that widths of between 3.2 and 3.9m “are not acceptable for cycling in mixed traffic”.

Buses in Urban Developments

4.72 Buses in Urban Developments was published by the CIHT in 2018. It is also relevant to the consideration of the sustainability characteristics of the appeal site and to the propensity for residents at the appeal proposal to walk or cycle to a bus stop for onward travel by bus.

4.73 The guidance acknowledges that the “use of buses varies considerably” depending on location and that the choice of bus falls to “only 3% in rural towns and fringe areas”112.

4.74 In considering the walking distance to bus stops and the definition of bus catchment areas, it acknowledges that custom and practice for many years has suggested a maximum walking distance of 400m to and from a bus stop. More recently, it has been acknowledged that a more sophisticated approach to bus catchment area planning and evaluation is required in order to successfully reduce car use and increase the use of sustainable travel modes. Such an approach acknowledges that the walking distance is not a stand-alone consideration; that people will tend to be prepared to walk further to fast, direct, or more frequent bus services; and that the proportion of elderly people is

110 Cycle Infrastructure Design (Local Transport Note 1/20), §4.4.4 (page 33) 111 Ibid, §6.4.3 (page 61) 112 Buses in Urban Developments, Section A – Context and policy framework (page 7)

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increasing and that a walking distance of 400m may be excessive when slower walking speeds are taken into account.

4.75 For those reasons, Table 4 (on page 18) recommends a maximum walking distance to bus stops for less frequent routes (compared to other situations) of 300m in order “to enable the bus to compete effectively with the car and to benefit a wide range of people with differing levels of motivation and walking ability”113.

Manual for Streets

4.76 The Manual for Streets was published on behalf of the DfT in 2007 and it replaced previously published guidance. It focuses on “lightly-trafficked residential streets” and acknowledges that many of its key principles may be applicable to other types of streets (such as high streets and lightly-trafficked lanes in rural areas). It cautions transport planning practitioners (and others) “to ensure that its application to the design of streets not specifically covered is appropriate”114.

4.77 It is relevant to the consideration of both the accessibility of the appeal site and to the propensity for residents to walk along the Haughley Park access road to the proposed new footway along Haughley New Road.

4.78 The Manual for Streets draws a clear distinction between streets and roads noting that roads “are essentially highways whose main function is accommodating the movement of motor traffic” while streets have a “place function”115.

4.79 In Section B (Design Principles) and in discussing layout and connectivity, it includes a sub-section entitled: ‘The walkable neighbourhood’. As with other guidance, it characterises such neighbourhoods as “having a range of facilities within 10 minutes’ (up to about 800m) walking distance of residential areas which residents may access comfortably on foot”. It goes on to acknowledge that this value is not an upper limit, and that “walking offers the greatest potential to replace short car trips, particularly those under 2 km”116.

4.80 In Section B (Detailed Design Issues) and in discussing street users’ needs, it seeks to promote inclusive design and it reminds us that that “means providing for all people regardless of age or ability”117. With specific regard to pedestrians, it says that the “propensity to walk is influenced not only by distance, but

113 Ibid, (page 18) 114 Manual for Streets, Status and application (page 5) 115 Ibid, §2.2.1 (page 15) 116 Ibid, §4.4.1 (page 45) 117 Ibid, §6.1.1 (page 63)

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also by the quality of the walking experience”118 and reminds us that the term pedestrians includes “wheelchair users and people pushing wheeled equipment such as prams”119. It advises us that routes for pedestrians “need to be direct and match desire lines as closely as possible”120 and that “the minimum unobstructed width for pedestrians should generally be 2 m”121. For further guidance on minimum footway widths, the Manual for Streets directs the reader to Inclusive Mobility.

4.81 With regard to the siting of bus stops, it says that these “should be based on trying to ensure they can be easily accessed on foot” and that they “must be accessible by disabled people”122.

4.82 In discussing street geometry and, in particular, shared surface streets, it advises us that subject “to making suitable provision for disabled people” they are likely to work well “in short lengths” and “where the volume of motor traffic is below 100 vehicles per hour (vph)”123. It refers to research undertaken by TRL for Transport for London that “concluded that there is a limiting factor on pedestrians sharing space with motorists, of around 100vph. Above this, pedestrians treat the general path taken by motor vehicles as a ‘road’ to be crossed rather than as a space to occupy”. In considering the applicability of that research to other scenarios, the Manual for Streets states that “it is reasonable to assume that these factors are relevant to other shared spaces schemes” 124.

4.83 In discussing stopping site distances, visibility requirements and visibility splays at junctions, it provides guidance for streets “where 85th percentile speeds are up to 60 km/h. At speeds above this, the recommended SSDs in the Design Manual for Roads and Bridges may be more appropriate”125.

Manual for Streets 2: Wider Application of the Principles

4.84 Manual for Streets 2 was published by the CIHT in 2010 and it forms a companion guide to the Manual for Streets – it does not supersede it126. In referring to the Manual for Streets, it explores “in greater detail how and where its key principles can be applied to busier streets and non-trunk roads, thus helping to fill the perceived gap in design guidance between MfS1 and the Design Manual for Roads and Bridges”127.

118 Ibid, §6.3.1 (page 63) 119 Ibid, §6.3.2 (page 63) 120 Ibid, §6.3.6 (page 64) 121 Ibid, §6.3.22 (page 68) 122 Manual for Streets, §6.5.10 (page 73) 123 Ibid, §7.2.14 (page 82) 124 See box on page 83 125 Ibid, §7.5.1 (page 90) 126 Manual for Streets 2, §1.1.2 (page 7) 127 Ibid, Status and Application (page 4)

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4.85 In discussing SSDs and the methodology for determining the application of appropriate values, it tells us that “it is only where actual speeds are above 40mph for significant periods of the day that DMRB parameters for SSD are recommended”128. Conversely, and particularly in respect of rural highways subject to the national speed limit, it says that “where speeds are lower than 40mph, MfS SSD parameters are recommended”129. Furthermore, and in Chapter 10 (Visibility), this threshold is reinforced in Table 10.1 (Summary of Recommended SSD Criteria) and in the graph showing recommended SSD values (allowing for bonnet length) beneath it for absolute minimum and desirable minimum SSDs130. For a design speed above 60kph (37mph), it refers to a predecessor document to the current relevant component of the DMRB.

4.86 With regard to the ‘X’ distance (i.e. the distance back along the minor arm from which visibility is measured), it tells us that a dimension of 2.4m “should normally be used” as it “represents a reasonable maximum distance between the front of a car and the driver’s eye”131.

4.87 With regard to the consideration of obstacles to visibility, and with specific reference to trees, it tells us that these “should be assessed in terms of their impact on the overall envelope of visibility”. It does, however, acknowledge that “occasional obstacles to visibility that are not large enough to fully obscure a whole vehicle or a pedestrian, including a child or wheelchair user, will not have a significant impact on road safety”132.

Design Manual for Roads and Bridges

4.88 The DMRB is a suite of documents “which contains requirements and advice relating to works on motorway and all-purpose trunk roads”133. GG101, Revision 0 (2018) of the DMRB provides information on the use of the DMRB.

4.89 That said, and in the context of the consideration of the appeal proposal, it is relevant because Manual for Streets 2 suggests that where recorded speeds are above 40mph (64kph) for significant periods of the day then the “DMRB parameters for SSD are recommended”134. CD 123, Revision 2 (2020) of the DMRB provides the requirements for the geometric design of at-grade priority and signal controlled junctions. With regard to stopping sight distances (SSDs), it refers to CD 109, Revision 0 (2019) of the DMRB that provides desirable minimum (and one step below desirable minimum) SSDs and other

128 Ibid, §1.3.6 (page 8) 129 Ibid, §1.3.7 (page 8) 130 Manual for Streets 2, Pages 74 & 75 131 Ibid, §10.5.6 (page 78) 132 Ibid, §10.7.2 (page 80) 133 GG 101, Revision 0 (2018) of the DMRB, Introduction (page 4) 134 Manual for Streets 2, §1.3.7 (page 8)

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design speed related parameters in Table 2.10 (on page 15). The speed limit/ design speed relationship is set out in Table 2.5 (on page 12).

4.90 Paragraph 3.4 (on page 21) of CD 123 says that: “Unobstructed visibility shall be provided at all priority junctions and direct accesses by a visibility spay formed between the following three points, as illustrated in Figure 3.4”. It goes on to identify those points as: ‘W’, ‘X’ and ‘Y’:-

. ‘W’ corresponds to the intersection point between the centreline of the minor road and the edge of the carriageway of the major road; . ‘X’ represents a distance along the centreline of the minor road from the edge of the carriageway of the major road; and . ‘Y’ represents a distance along the nearside edge of the major road carriageway, corresponding to the desirable minimum SSD for the speed of the major road from point ‘W’.

4.91 Paragraph 3.8 (on page 22) of CD 123 gives a minimum distance of point ‘X’ as 2.4m for simple priority junctions. That value corresponds to the value given in paragraph 10.5.6 (on page 78) of Manual for Streets 2 as representing “a reasonable maximum distance between the front of a car and the driver’s eye”.

4.92 The national speed limit (60mph/ 96kph) corresponds to a design speed in kilometres per hour of 100A135. The desirable minimum SSD for a design speed of 100kph is 215m and one step below that desirable minimum is 160m136. It should be noted, however, that for “direct accesses and priority junctions that do not form part of a through route” the speed of the major road for determining point ‘Y’ can be based either on the desirable minimum SSD or speed measurement137.

4.93 Speed measurement of an existing major road involves calculating the 85th percentile speed of traffic in accordance with the requirements provided in CD 185, Revision 0 (2019).

Suffolk Design Guide for Residential Areas

4.94 The Suffolk Design Guide “is intended to make a positive contribution to improving the quality of housing development in Suffolk”138. Both the Appellant’s Transport Assessment and the County Council (in its pre-application response) refer to the Suffolk Design Guide.

135 Suffixes A and B indicate higher and lower categories (respectively) – see Note 1 to Figure 2.1 (on page 9) 136 CD 109, Table 2.10 (page 15) 137 CD 123, §3.5 (3) (page 22) 138 Suffolk Design Guide for Residential Areas, §1.0.3 (page 3)

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4.95 One of its stated aims is to “ensure the provision of a road, cycle and footway network which is safe and convenient to use”139. With regard to the accessibility of facilities, it says that: “Smaller estates should be integrated into existing communities, with thought being given to appropriate links to existing facilities nearby”140.

4.96 In considering different types of road and the access requirements of development, it says that:

“From the point of view of safety and the need to consider access in emergencies, not more than 150 dwellings will normally be served by a single means of access.”141

4.97 It describes shared surface roads as “residential roads without footways that would not normally serve more than 50 dwellings if looped or 25 in the form of a cul-de-sac”142. In considering those in more detail, it identifies a target maximum speed “well below 20mph”, a block paved or surface dressed finish, and a maximum distance between speed restraint measures of 40m143. In discussing appropriate speed restraint measures, the guidance suggests that: “Normally changes in horizontal alignment will be the only means necessary to control vehicle speeds. Speed tables and raised junctions (extended flat top road humps) may also be considered”144.

Concluding Remarks

4.98 There is a clear land use and transport planning policy requirement that new development is sustainable, and that it should occur in locations that are or can be made sustainable, that they should limit the need to travel and offer access to a genuine choice of sustainable modes of transport.

4.99 The CIHT acknowledges that policy framework but is critical of practitioners and decision-makers. It worries that current practice gives rise to development that is poorly located and perpetuates car dependency. It cautions against providing new housing remote from the employment opportunities, and service and facilities that people need to access in order to meet their day-to-day needs.

4.100 In the relevant guidance, there are consistent themes that seek to positively influence transport planning practitioners to make walking, cycling and public transport the modes of choice so that those are more convenient than car usage for the majority of journeys that people need to make. It uses the words like: ‘attractive’, ‘easy’, ‘genuine’, ‘inclusive’, ‘quality’, ‘safe’, and ‘stimulating’, to describe what we all need to think about in order to encourage sustainable travel behaviour. In its consideration of

139 Ibid, §1.0.4 (page 3) 140 Ibid, §1.5.1 (page 5) 141 Suffolk Design Guide for Residential Areas, §3.3.9 (page 16) 142 Ibid, §3.3.6 (page 16) 143 Ibid, §6.3.1 (page 102) 144 Ibid, §3.5.2 (page 19)

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dimensions (both length and width), it promotes desirable maximums and minimums in order to assist in the achievement of those objectives.

4.101 As a transport planning professional, I welcome the five core design principles of coherence, directness, safety, comfort, and attractiveness identified in Local Transport Note 1/20 (Cycle Infrastructure Design), and I consider that they can and should be reasonably applied to all facets of transport infrastructure design because it is through their application that we can encourage sustainable travel behaviour.

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The Appeal Proposal

5.1 The appeal proposal is described in both the District Council’s Statement of Case145 and in the Appellant’s Statement of Case146, and in the SoCG147. It is illustrated in Pegasus Group’s Illustrative Masterplan drawing (number P18-0128_004, Revision I, dated 18 June 2018).

5.2 I note, however, that the Appellant’s Transport Assessment and Sustainable Travel Report refers to “a residential development of 134 dwellings, small scale employment units, a community building, playing fields and public open space”148 rather than the description of the appeal proposal provided in paragraph 2.1 of the Appellant’s Statement of Case. For the avoidance of doubt, and where necessary, I have accounted for the reduction in the number of dwellings proposed to 120 in my evidence to this Inquiry.

Proposed Site Access Arrangements

5.3 The proposed site access arrangements comprise the use of the existing Haughley Park access road to gain access to the appeal proposal. The Appellant’s Transport Assessment asserts that “it is considered fit-for-purpose as it currently exists and suitable to serve the proposed development”149. For reasons that I will explain in the next section of my evidence, I do not agree.

5.4 With regard to the junction of the Haughley Park access road with Haughley New Road, the Appellant initially advocated a reduction in the speed limit of Haughley New Road from the existing national speed limit to 40mph, and it agreed to fund (up to £10,000) the necessary process. Recognising the inherent risk that such a process may not be successful, and with the benefit of speed survey data for Haughley New Road its own measurement of the available visibility for emerging traffic at the Haughley Park access road junction, in its Transport Assessment – Addendum, the Appellant states that the “reduced SSD values would be comfortably achieved from a set-back (x-distance) of 2.4m, based on the measurements undertaken on 22/11/19”150. For reasons that I will explain in the next section of my evidence, there appears to be doubt as to whether, or not, adequate visibility is available at the junction.

5.5 Curiously, in my view, the Appellant proposes that: “The internal layout of the development would be designed to create a safe and low-speed environment that gives priority to pedestrians and encourages walking”151 and that the internal roads within the appeal proposal would be provided “in accordance

145 The District Council’s Statement of Case (October 2020), Section 3 (page 4) 146 The Appellant’s Statement of Case (August 2020), Section 2 (pages 4-5) 147 The Statement of Common Ground, §§3.10-3.12 (page 8) 148 The Appellant’s Transport Assessment & Sustainable Travel Report, §1.2.1 (page 1) (both) 149 The Appellant’s Transport Assessment, §5.2.4 (page 22) 150 The Appellant’s Transport Assessment – Addendum, §2.2.9 (page 3) 151 Ibid, §5.4.2 (page 23)

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with the Manual for Streets and other relevant local design guidance”152, yet it does not (or, as I understand it, cannot) apply this same philosophy to the existing Haughley Park access road.

5.6 Further, and with regard to access for pedestrians and cyclists, the Appellant’s Transport Assessment asserts that the existing access road is “sufficiently wide to operate satisfactorily as a shared-surface route”153. Similarly, I do not agree.

Proposed Transport Infrastructure and Services Improvements

5.7 As illustrated in the Appellant’s Site Access (Sheet 1 of 2) and Site Access (Sheet 2 of 2) drawings (number T16026/SK04, Revision A and /SK05, Revision B) in its Transport Assessment, and Site Access (Sheet 1 of 2) (Alternative Visibility Splays) and Site Access (Sheet 2 of 2) (Alternative Visibility Splays) drawings (number /SK06, Revision A and /SK07, Revision A) in its Transport Assessment – Addendum, the Appellant proposes the provision of a new footway from the Haughley Park access road junction along the southern side of Haughley New Road (as far as the junction with Park Road), an informal pedestrian crossing of Haughley New Road and a new footway along the western side of Park Road (as far as the junction with Park View).

5.8 The Appellant asserts that this will encourage “safe pedestrian movement between the development and the existing amenities and local bus services in Wetherden”154. I do not agree.

5.9 The Appellant identifies the existing PROW from the end of Park View in Wetherden to Mill Gardens in Elmswell (illustrated in its Walking Route from Site to Elmswell Primary School drawing (number T16026/SK09) provided in its Transport Assessment – Addendum) as “a viable route to and from Elmswell, particularly during the summer months”155. It asserts that the “un-paved section of the route could also potentially be up-graded using gravel or a similar loose material” and suggests that this work “could potentially be funded (in whole or in part) by a fair and reasonable contribution from the developer in lieu of the [school] bus service contribution”156. For reasons that I will explain in the next section of my evidence, I do not consider that it is appropriate to divert funds from the County Council’s statutory obligation to fund school transport in the circumstances that apply in this case nor that this is a viable walking route from the appeal site to Elmswell Primary School.

152 Transport Assessment - Addendum, §5.4.3 (page 23) 153 Ibid, §5.4.1 (page 22) 154 Ibid, §5.4.3 (page 23) 155 Ibid, §5.2.2 (page 9) 156 Ibid, §5.2.3 (pages 9-10)

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Bus Services

5.10 The Appellant proposes the diversion of the route of the 384/ 385 local bus service via Haughley New Road and Park Road, together with the provision of new bus stops east of the junction of Park Road with Haughley New Road and the relocation of the existing bus stops in the centre of Wetherden to new locations west of the Park Road and Church Street junctions with Stowmarket Road157.

5.11 I note that the Appellant is “willing to fund the provision of new bus stops”158 by way of a planning obligation rather than undertake the works to provide them. I note also from the email correspondence between Travis Baker and Stephensons of Essex (the local bus service operator) provided in Appendix C to the Appellant’s Transport Assessment – Addendum that the cost of providing this diversion “would be around £150 per day”159.

5.12 What I cannot see in the Appellant’s evidence base is a commitment to fund the diversion of the local bus services.

Proposed Travel Planning Initiatives

5.13 The Appellant proposes that a condition is imposed upon any planning permission grant requiring the submission and approval (by the District Council) of a Residential Travel Plan prior to occupation of the appeal proposal160.

5.14 A Framework Travel Plan is provided at Appendix SCGT/C to the TSoCG.

The Highway Authorities’ Consultation Responses

5.15 The writer (Luke Barber) of the County Council’s final consultation response (as local highway authority) provided to the District Council acknowledges that the appeal proposal comprises “a complex case with several conflicting factors shaping the potential for development on this site”. He notes that “previous SCC response letters have indicated that planning permission should be refused on highway grounds” and he acknowledges “the developers’ consultants have addressed the fundamental issues around the site access safety and have a variety of mitigation options” 161.

157 The Appellant’s Transport Assessment, Figure 6 158 Ibid, §4.3.5 (page 20) 159 The Appellant’s Transport Assessment – Addendum, Appendix C (Email from Bill Hiron (Stephensons of Essex) to Sean McGregor (Travis Baker) on 7 November 2019 refers) 160 Ibid, §4.2.1 (page 8) 161 Suffolk County Council’s letter of 22 January 2020 to Mid Suffolk District Council refers

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5.16 Based on the content of the Appellant’s Transport Assessment - Addendum and subject to “suitable highways mitigation measures being secured by Planning Condition or Planning Obligation”, the County Council’s officer recommended that planning permission was not refused on highways grounds.

5.17 Those “suitable highways mitigation measures” are identified by the County Council as:-

. Road Safety – Access Visibility Splay; and . Sustainable Access to Services

5.18 It is noteworthy that the County Council‘s officer’s recommendation was subject to the following caveat:-

“However, should the highways mitigation measures set out in this letter not be achieved, the development as currently planned would result in a Severe Impact, contrary to Paragraph 109 of the revised National Planning Policy Framework (2019), and therefore permission should be refused.”162

5.19 Pertinently, in the context of my evidence to this Inquiry and in his final sentence, the County Council’s officer notes that “the site is clearly very remote from key services” and he suggests “the full range of NPPF paragraphs should be used to assess the sustainability of the site and the suitability for this form of development”163.

5.20 Unusually, in my experience, the County Council does not suggest the imposition of a condition requiring the implementation of a Travel Plan nor seeks an obligation from the Appellant to do so. I note also, with reference to the County Council’s previous consultation response of 28 October 2019 that it considers that “a traditional Travel Plan is unlikely to work on this site, due to the rural location with extremely limited sustainable transport options”164. Consequently, therefore, it suggested the application of available funds to the provision of hard infrastructure.

5.21 More recently, and following the receipt of information provided to it by Mr Williams’s transport planning consultant (Cannon Consulting Engineers), the County Council has provided the District Council with its Highway Access Visibility Review [Appendix RL-H] which I consider in the following section of my evidence.

162 Suffolk County Council’s letter of 22 January 2020 to Mid Suffolk District Council refers 163 Ditto 164 Ditto (page 3)

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5.22 Highways England (the strategic highway authority) does not object to the appeal proposal because it considers it unlikely “that it will have a severe affect upon the Strategic Road Network”165.

The Strategic Housing Officer’s Consultation Response

5.23 With regard to her consideration of the provision of affordable housing in the appeal proposal, I note that the District Council’s Strategic Housing officer is of the view that:

“due to the location of this site in relation to public footpaths, cycle routes, public transport and access to shops and public facilities, the provision of on-site affordable housing is not considered to be sustainable for lower income households”166.

5.24 Consequently, she objected to the granting of planning permission for the appeal proposal because she determined that the appeal site is not “a sustainable or inclusive location for affordable housing or for households with a reliance on public transport”167.

The Case Officer’s Assessment

5.25 The author (Vincent Pearce) of the District Council’s Delegated Report for Consideration under Chief Executive’s Emergency Powers as Duly Authorised during the Present Coronavirus Pandemic dated 15 April 2020 recommended the refusal of outline planning permission for the appeal proposal.

The Principle of the Appeal Proposal

5.26 In his assessment, the appeal proposal “is isolated from any settlement in the wider locality and bears no functional relationship with them”168, and he concluded that:

“the proposed residential development is in and of itself contrary of the land use planning policies of the Council insofar as the site is within countryside remote from and not easily accessible to facilities and services necessary to sustain a new community without the use of the car”.169

165 Highways England’s Formal Recommendation to an Application for Planning Permission, dated 9 August 2019 166 Memorandum, dated 3 September 2019 (page 2) 167 Ibid (page 3) 168 Delegated Report (page 14) 169 Ibid (page 18)

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Highway Impacts

5.27 He acknowledges that the County Council does not object to the appeal proposal and concludes that it “is acceptable from a highway safety and capacity perspective”, and stresses that does not include consideration of its sustainability credentials170.

Sustainability

5.28 In his consideration of the sustainability credentials of the appeal proposal, he expressed the view that:

“The site does not provide sustainable access to local facilities many of which are in excess of 2 miles away. There will be an unacceptable over reliance on the car as the preferred means of travel contrary to the advice within the NPPF to encourage travel by sustainable means of transport in new development”171.

5.29 More particularly, in considering the distances from the appeal site to Wetherden (that he describes as “a small village with very few amenities”) and Elmswell (for the “nearest basic facilities”), and the safety and attractiveness of the available routes, he concludes that:

“it is clear that walking and cycling would not be attractive modes of travel from this site, resulting in rather ‘car dominated’ travel patterns and very few trips are likely to be carried out by sustainable modes”172.

5.30 With reference to Table 3.2 (on page 49) of the CIHT’s Guidelines for Providing for Journeys on Foot (2000), he determined that “the walking distances from this site to key services will be far in excess of these maximum figures”, and he concluded that the appeal proposal is not consistent with the requirements of Section 9 of the Framework173.

Conclusion

5.31 In balancing the various issues, he feels that:

“The fact that the proposal generates no highway safety and no highway capacity issues sufficient to warrant a refusal of planning permission and the offer to provide footpath connections to Wetherden and Elmswell from the site entrance on the main road should be ascribed modest weight because for any proposed development to be acceptable it must pass

170 Delegated Report (page 38) 171 Ibid (page 39) 172 Ibid (page 40) 173 Ibid (pages 40-41)

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basic highway safety and capacity tests and the offer to extend footpaths can only attract low weight because the distances involved are such as to limit the extent to which they will ever be used by pedestrians and even cyclists.”174

5.32 He recommended that the planning application for the appeal proposal should be refused.

The Decision

5.33 The planning application for the appeal proposal was refused by notice dated 24 April 2020 for six reasons.

5.34 Of relevance to my evidence to this Inquiry, the first reason relates to the principle of the appeal proposal insofar as the appeal site “is in the countryside remote from any easily accessible neighbouring settlement [or defined settlement boundary] where necessary facilities and services are available”, contrary, inter alia, to Policy FC1.1.

5.35 The fourth reason relates to the sustainability of the appeal proposal “as a result of its remote, isolated location” where “occupiers will inevitably have to rely on the car to access anywhere beyond the immediate development” because services and “facilities within sustainable settlements in the wider locality are not appropriately accessible”, contrary to the Framework and Policy FC1.1.

174 Delegated Report (page 50)

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Assessment of the Transport Planning Issues Arising from the Appeal Proposal

6.1 As I said in my introduction, my evidence is concerned with the transport planning and highway engineering issues arising from the District Council’s reasons for refusing to grant planning permission for the appeal proposal. In particular, to the first (principle) and fourth (unsustainable development/ low carbon transition) reasons for refusal.

6.2 More particularly, in his Case Management Conference Summary Note, the Inspector identifies the main land use and transport planning issues arising from the appeal proposal as:-

. whether the appeal proposal would be in an appropriate location having regard to the development plan and national land use and transport planning policies; . whether it would provide acceptable access to services and facilities; and . its effect on highway safety.175

Appropriate Location for the Appeal Proposal

6.3 It is common ground that the centre of the appeal site is approximately 780m from the public highway; 1.5 kilometres (0.9 of a mile) from Wetherden; 3.5 kilometres (2.2 miles) from Elmswell; and 7.0 kilometres (4.4 miles) away from Stowmarket.

6.4 Remembering that the average length of a pedestrian journey is circa 0.85 mile (1.4 kilometres)176, and that the Manual for Streets and Building Sustainable Transport into New Developments both discuss the concept of the ‘Walkable Neighbourhood’ being 800m, there must immediately be a concern that the appeal site is remote from the range of day-to-day facilities and services that residents at the appeal proposal should be able to access comfortably on foot. Those facilities and services are considerably beyond the ‘preferred maximum’ walking distances identified in the Guidelines for Providing for Journeys on Foot.

6.5 With reference to the observation made in Better Planning, Better Transport, Better Places that for sustainable transport planning in rural areas, access to primary, secondary, and post-16 education is likely to be a major issue, it is clear that implementation of the appeal proposal would increase the number of primary- and secondary-age children entitled to funded school transport. It is not, in my view, a location from where primary-age children could walk easily and safely to school, or “where

175 Case Management Conference Summary Note (23 October 2020), §6 (pages 1-2) 176 Planning for Walking, §2.1 (page 6)

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walking and cycling to school are credibility achievable or where public transport options exist or can be provided”177.

6.6 Haughley New Road is currently subject to the national speed limit but even in the scenario whereby that speed limit is reduced to 40mph, without the provision of protected space for cyclists, only a small minority of residents at the appeal proposal will consider cycling. Most potential cyclists will be excluded because they will fear cycling on the carriageway.

6.7 Even if new bus stops are provided in the vicinity of the Park Road junction with Haughley New Road, and service numbers 384/385 diverted for a period of time, it is common ground that they will remain approximately 1.1 kilometres from the appeal site. That is almost four times the recommended maximum walking distance of 300m provided in Buses in Urban Developments required “to enable the bus to compete effectively with the car and to benefit a wide range of people with differing levels of motivation and walking ability”178. Such a distance would entail a walking journey time of just over 13 minutes, ignoring any waiting time once the bus stop had been reached.

6.8 Better Planning, Better Transport, Better Places says that encouraging a reduction in car dependency is a key component of promoting sustainable transport usage in new developments. Given the locational characteristics of the appeal site, I consider that it is poorly located and inaccessible by sustainable transport modes. It is my view that implementation of the appeal proposal would result in a highly unsustainable pattern of development.

6.9 In the context of the Framework, therefore, I consider that the appeal site is not a location that is, or can be made, sustainable through limiting the need to travel by offering a genuine choice of transport modes.

The Use of Haughley Park Access Road to Access the Appeal Proposal

6.10 I accept that the existing Haughley Park access road is of adequate horizontal and vertical alignment to accommodate the vehicular traffic likely to be generated by or attracted to the appeal proposal. It is common ground that with the exception of the 56m length of the road that narrows to 4.1m or less in width to the rear of Haughley Park, the remainder of the road is sufficiently wide to comfortably accommodate the passing of two cars, and of a car and a heavy goods vehicle.

6.11 My concern relates to the likelihood, by virtue of the number of vehicles that will use the road, its character and alignment, that residents at the appeal proposal will walk or cycle along it.

177 Better planning, better transport, better places [CD??], §4.3 c (page 27) 178 Buses in Urban Developments, Table 4 (page 18)

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6.12 Notwithstanding that the Suffolk Design Guide suggests that shared surface roads would not normally serve more than 50 dwellings179, I recognise that the Manual for Streets says that they are likely to work well “in short lengths” and “where the volume of motor traffic is below 100 vehicles per hour (vph)”180.

6.13 I have re-worked the traffic generation calculation provided in Table 6.5 (on page 28) of the Appellant’s Transport Assessment to account for the reduced number of dwellings in the appeal proposal and supplemented it with information relating to 12-hour generation based upon the agreed trip rates provided in the TSoCG181. Those calculations are provided in my Table 6.1 (below).

Table 6.1 Combined Traffic Generation and Attraction of the Appeal Proposal

Arrivals Departures Time Land Use Total Period 85th%ile Traffic 85th%ile Traffic Trip Rate Flow Trip Rate Flow

Residential 0.243 per 0.595 per 120 29 71 AM Peak dwelling* dwelling* Hour dwellings 128*** (08:00- 1.950 per 0.100 per Employment 09:00) 100m2 27** 100m2 1** 1,400m2 GFA GFA** GFA**

Residential 0.519 per 0.259 per 120 62 31 PM Peak dwelling* dwelling* Hour dwellings 123 (17:00- 0.212 per 1.939 per Employment 18:00) 100m2 3** 100m2 27** 1,400m2 GFA GFA** GFA**

Residential 3.609 per 3.695 per 120 433 443 dwelling**** dwelling*** 12-Hour dwellings (07:00- 1,131*** 9.248 per 9.024 per 19:00) Employment 100m2 129 100m2 126 1,400m2 GFA GFA**** GFA***

* Source: Table 6.1 (on page 26) of the Appellant’s Transport Assessment ** Source: Table 6.3 (on page 27) of the Appellant’s Transport Assessment *** The discrepancy between these values and the total sum of the equivalent values provided in the TSoCG arises due to rounding **** Source: Appendix SCGT/E of the Statement of Common Ground on Transportation Issues

179 Suffolk Design Guide for Residential Areas, §3.3.6 (page 16) 180 Manual for Streets, §7.2.14 (page 82) 181 Statement of Common Ground on Transportation Issues, Tables 4.2 and 4.3 (page 14)

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6.14 The combined traffic generation and attraction of the appeal proposal amounts to 128 vehicles per hour in the AM peak hour and 123 vehicles per hour in the PM peak hour, and it should be remembered that those values do not include for any traffic associated with the activities undertaken at Haughley Park itself. At that level, and in the context of the advice given in the Manual for Streets (regardless of other considerations that weigh against the proposition), I do not consider that it is reasonable to expect the Haughley Park access road to function satisfactorily as a shared-surface route, as the Appellant suggests182. To the contrary, I consider that during the peak hours (when the majority of primary trips to workplaces and schools will occur), and as the Manual for Streets suggests, residents at the appeal proposal would consider the Haughley Park access road as a ‘road’ “to be crossed rather than as a space to occupy”183.

6.15 Add to that the absence of any proposed surface treatment works to identify the proposed change in character of the existing Haughley Park access road in order to differentiate it from Haughley New Road and the internal estate road network of the appeal proposal, I do not consider that any user of the road will recognise it as a shared-surface at any time of day. Further, in the absence of the provision of any speed restraint measures, I do not consider that it will be possible to limit the speed of vehicular traffic along the road to a target maximum speed “well below 20mph” as suggested by the Suffolk Design Guide184.

6.16 In considering the five core design principles of coherence, directness, safety, comfort, and attractiveness, I do not consider that the Appellant has applied any of those to its consideration of the propensity for residents at the appeal proposal to walk along the Haughley Park access road.

6.17 With regard to coherence, the absence of works to differentiate the access road as a shared-surface, or the provision of a footway and lighting means that residents at the appeal proposal are unlikely, in my view, to recognise it as a route to the public highway that is available to them.

6.18 With regard to directness, and accepting the Appellant’s proposition that: “The only viable destination for regular pedestrian trips generated by the development are the local facilities and bus stops in Wetherden”185, it can be seen from the Appellant’s Figure 2 (Local Highway Network) in its Transport Assessment, that the access road turns west and away from Wetherden before it intersects with Haughley New Road. That is clearly not a direct route, and I estimate that adds circa 540m to a journey when compared with a straight line from the access road to the Park Road junction with Haughley New Road.

6.19 With regard to safety, and in addition to my earlier comment regarding the absence of any change in the character of the access road (to identify it as a shared surface), footway or speed management

182 Ibid, §5.4.1 (page 22) 183 Manual for Street, see box on page 83 184 Ibid, §6.3.1 (page 102) 185 Ibid, §4.4.3 (page 16)

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measures, the absence of any street lighting is likely to discourage residents from walking along the road during the hours of darkness because they are unlikely to be seen by other road users.

6.20 With regard to comfort, the absence of any seating means that a proportion of the residents at the appeal proposal will simply not be able to walk along the access road. That clearly ignores the requirement for inclusivity.

6.21 In terms of attractiveness, there is undoubtedly an absence of frontage activity along the road such that, in my view, while the road may attract the occasional leisure walk, it is does not represent an attractive route for routine and regular journeys. Add to that, the time penalty insofar as it takes 9’17” to walk 780m (at 1.4 metres per second) but only 1’56” to drive (at 15mph (equivalent to 6.7 metres per second)) – almost five times as long – means that residents are unlikely to consider walking as an attractive alternative to driving (or being driven).

6.22 Taken together, the volume of traffic along the Haughley Park access road and the absence of any application of any of the five core design principles means that it is highly unlikely that any resident of the appeal proposal other than the most committed pedestrian or cyclist will choose to regularly walk or cycle along it as a matter of routine.

6.23 It is therefore, highly likely that residents at the appeal proposal will consider that their only realistic choice for travel to and from the appeal site is by car (either as a driver or a passenger). For that reason, I do not consider that the appeal site is an appropriate location for the appeal proposal.

6.24 In the context of Policy FC 1.1 of the Core Strategy Focused Review, therefore, and in my view, the appeal proposal cannot demonstrate the principles of sustainable development.

Acceptable Access to Services and Facilities

6.25 The Appellant’s Sustainable Travel Report acknowledges that the Appeal “site is not located within close proximity and walking distance of a large range of local amenities and employment opportunities”186. As I noted earlier, it asserts that: “The only viable destination for regular pedestrian trips generated by the development are the local facilities and bus stops in Wetherden” and it confirms that “a new footway is proposed as part of the site access strategy to connect the site to Wetherden via Park Road”187.

186 The Appellant’s Sustainable Travel Report, §1.3.4 (page 2) 187 Ibid, §4.4.3 (page 16)

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Walking

6.26 Any assessment of the propensity of residents of the appeal proposal to walk from their homes to the services and facilities that they require to meet their day-to-day needs is a function of their ability to do so (in terms of the availability of adequate infrastructure) and the distances involved (recognising that people’s motivation to walk is interdependent on the attractiveness of the destination).

6.27 Firstly, the trip attractors in Wetherden are identified in Figure 4 (Pedestrian Isochrones and Local Facilities) of the Appellant’s Transport Assessment as being the Wetherden Village Hall, the playing fields (with a play area, a tennis court and sports pitches), the Maypole public house (now closed), and the bus stops. I note from the Illustrative Masterplan provided as Appendix A to the Appellant’s Sustainable Travel Report that the appeal proposal includes a building for sports and community use, and an area (annotated “7. Play space”) marked with two sports pitches. It occurs to me, therefore, that these two facilities are likely to compete with the existing facilities in Wetherden (as opposed to complementing them). The provision of competing (rather than complementary) facilities to those already provided in Wetherden is likely to reduce significantly the propensity for trip making between the appeal proposal and the village.

6.28 I note also that the Appellant is not proposing to complete a footway link all the way to Wetherden Village Hall or to the centre of the village. There is currently no footway between the Park View junction with Park Road and a point approximately 70m from the Park Road junction with Elmswell Road and Stowmarket Road – a distance of approximately 150m. I also note that there is a car park provided in the centre of the village.

6.29 The pedestrian route to the existing bus stops is, therefore, incomplete and I note from Figure 6 (Local Bus Routes) of the Appellant’s Transport Assessment that it is proposing to provide new bus stops to the east of the junction of Park Road with Haughley New Road, and to relocate the existing bus stops to a new location west of the Park Road junction with Elmswell Road and Stowmarket Road.

6.30 Curiously, however, I note that the Appellant is not proposing to complete the footway connection to either of the bus stops on Haughley New Road. In any event, I will consider the likelihood of residents of the appeal proposal to walk to the bus stops later in this section of my evidence.

6.31 The proposed new footway is illustrated in the Appellant’s Site Access (Sheet 1 of 2) and Site Access (Sheet 2 of 2) drawings (number T16026/SK04/A and /SK05/B) provided in its Transport Assessment and at Appendix B to its Sustainable Travel Report. A variant of the proposed new footway is also illustrated in its Site Access (Sheet 1 of 2) (Alternative Visibility Splays) and Site Access (Sheet 2 of 2) (Alternative Visibility Splays) drawings (number /SK06/A and /SK07/A) provided in its Transport Assessment – Addendum.

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6.32 Those drawings illustrate the provision of a new footway of variable width along the southern side of Haughley New Road, an informal crossing of Haughley New Road (west of the Park Road junction) and a new footway of variable width along the western side of Park Road to a point that ties into an existing footway at the junction of Park View with Park Road.

6.33 Along Haughley New Road, the dimensions given for the width of the proposed footway vary between 1.3m and 2.0m in width, and along Park Road, between 0.8m and 1.3m. However, and bearing in mind that these drawings are subject to the caveat: “Proposed Footway to be provided within Highway Boundary”, on the basis that these drawings have been prepared on an Ordnance Survey base (rather than a topographical survey), I do not consider that these dimensions can necessarily be relied upon.

6.34 I also note that a small triangular area of land required to provide the proposed new footway on the eastern side of the bell-mouth of the Haughley Park access road junction appears to fall outside of both the extent of the existing public highway and the red-line of the appeal proposal188. There is, therefore, some doubt as to whether, or not, the 2.0m width of new footway can be delivered in that location.

6.35 In any event, the width of the proposed new footway needs to be considered in the context of relevant guidance.

6.36 Between ‘Cutline 2’ and ‘Cutline 3’ in the Appellant’s drawings (number T16026/SK05/B and /SK07/A), the width of the length of the proposed new footway along the southern side of Haughley New Road falls below the recommended minimum width of 1.5m given in Inclusive Mobility and further below the recommended absolute minimum width of 1.8m given in the Guidelines for Providing for Journeys on Foot and Designing for Walking.

6.37 Of greater concern is that beyond ‘Cutline 3’ in those same drawings, the width of the length of the proposed new footway along the western side of Park Road falls below the suggested “absolute minimum” width of 1.0m for more than the “maximum length” of 6m189 recommended in Inclusive Mobility.

6.38 The width proposed is indicated as being 1.0m or less for, at least, a length of more than 24m, and is less than the minimum width of 1.5m (given in Inclusive Mobility) and the absolute minimum width of 1.8m (given in Designing for Walking and the Guidelines for Providing for Journeys on Foot) for a length of, at least, 105m.

188 See the Appellant’s Site Access (Sheet 1 of 2) drawing (number T16026/SK04, Revision A) and Site Access (Sheet 1 of 2) (Alternative Visibility Splays) drawing (number T16026/SK06, Revision A) 189 Inclusive Mobility, Section 3.1

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6.39 Overall, therefore, and regardless of the propensity for new residents at the appeal proposal to actually use the proposed new footway, it falls considerably below the minimum width recommended by the relevant guidance. For that reason, I do not consider that residents of the appeal proposal are likely to consider this route comfortable or attractive, and that some may not consider it safe.

6.40 I consider that latter point to be particularly relevant given that the Appellant identifies this in its Figure 6 (Walking Route to Elmswell Primary School) as a route for primary-age children.

6.41 Staying with that theme, and in the context of the advice given in Better Planning, Better Transport, Better Places, that: “In rural areas, access to primary, secondary, and post-16 education is likely to be a major issue for local authorities and residents”, and that: “Primary children should be able to walk easily and safely to school”190, I note that the Appellant’s suggested route is 3.7 kilometres (2.3 miles).

6.42 With reference to the ‘trips to school by main mode, trip length and age’ data for England from the 2019 National Travel Survey (provided at Appendix E to the District Council’s Statement of Case), it can be seen that only 1% of younger children (aged between 5 and 10) walk more than 2.0 miles (3.2 kilometres) to school. The over-whelming majority of them (87%) are driven to school.

6.43 There is no reason to consider that travel behaviour for residents at the appeal proposal will be any different to this, at best, and several reasons to consider that in reality the travel behaviour in this case will be even more heavily skewed to the car, having regard to the nature and shortcomings of the available pedestrian route as I have outlined above.

6.44 Similarly, it is common ground that the nearest secondary schools are 5.0 and 6.6 miles (8.1 and 10.6 kilometres) away. It can be seen that no older children (aged between 11 and 16) walk more than 5 miles (8 kilometres) to school. The majority of them travel by bus (including private buses (i.e. funded school transport)).

6.45 The Appellant does not argue that residents of the appeal proposal will walk further than Wetherden in order to access local services and facilities, and acknowledges that such services and facilities are limited. It acknowledges the preferred maximum walking distance for trips with a ‘commuting, educational or sight-seeing’ purpose of 2.0km given in Table 3.2 (Suggested Acceptable Walking Distances) in the Guidelines for Providing for Journeys on Foot. Albeit, it does endeavour to characterise it as a “desirable maximum walking distance” at paragraph 4.1.4 (on page 19) of its Transport Assessment.

190 Inclusive Mobility, §4.3 c (page 27)

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6.46 It is clear also, from the Appellant’s Figure 4 (Pedestrian Isochrones and Local Facilities) in its Transport Assessment, that the very limited services and facilities in Wetherden lie beyond the preferred maximum walking distance of 1.2km given for trips with an ‘elsewhere’ trip purpose.

6.47 For that reason, and regardless of the Appellant’s proposed provision of new footways, I do not consider it likely that any resident at the appeal proposal (other than the most committed pedestrian or those without access to a car) will choose to walk to any local services or facilities. That conclusion is reinforced when regard is also had to my separate concerns about the unattractiveness of the Haughley Park access road as a route for pedestrian trips.

Cycling

6.48 Conspicuous by their absence from the appeal proposal are any proposals to provide any infrastructure for cyclists that would encourage residents to choose to cycle to services and facilities that they need to routinely access.

6.49 The simple reason for that, in my view, is that the opportunities to do so are limited and would require significant civil engineering works on land that lies outside of the existing public highway and the boundary of the appeal proposal.

6.50 Bearing in mind that Planning for Cycling identifies that: “Fear of traffic is one of the main factors that discourage people from cycling”191 and that “it is unrealistic to expect many existing and potential cycle users to find high volume or fast-moving mixed traffic conditions either attractive or comfortable”192; also, that Cycle Infrastructure Design (Local Transport Note 1/20) says that for speed limits above 40mph and regardless of volume, the appropriate provision “suitable for most people”193 is a fully kerbed cycle track, I consider it highly unlikely that any resident at the appeal proposal will choose to cycle to access local services and facilities.

Local Bus Services

6.51 Similarly, and mindful of the guidance in Buses in Urban Developments that recommends a maximum walking distance of 300m to bus stops for less frequent routes (compared to other situations), I do not consider it realistic to expect that residents at the appeal proposal will walk nearly four times further (1.15 kilometres) to a bus stop.

191 Planning for Cycling, Road Safety (page 7) 192 Ibid, Overall Principles (page 17) 193 Cycle Infrastructure Design (Local Transport Note 1/20), Figure 4.1 (page 33)

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6.52 For that reason, I consider it highly unlikely that any resident at the appeal proposal other than those without access to a car would choose to take a bus to access local services and facilities. That conclusion is reinforced when the frequency of the bus service is considered.

6.53 For example, a resident at the appeal proposal working a traditional 09:00 to 17:30 weekday in Bury St Edmunds would have to catch the bus either at 06:.45 or 07:25 to arrive at various stops in the town at about 07:30 or 08:20 (respectively) knowing that if they missed the later bus, the next available service is not for another two hours, at 09:25 arriving at about 10:10. The return journeys at 17:35 or 18:40 arrive back in Wetherden at 18:25 and 19:31 (respectively). Add to that the circa 13 minutes’ walk to the relocated bus stops along unlit roads means that a resident would have to leave their home at circa 07:00 and not return home until circa 18:40. The equivalent journey by car from the appeal site would be circa 21 minutes194 meaning that a resident could leave at circa 08:30 and return home at circa 18:00, a daily journey time saving of over two hours.

6.54 In any event, I do not consider it appropriate for the Appellant to seek to secure the provision of new bus stops and the relocation of others by way of a financial contribution pursuant to a planning obligation. Quite simply, and not least, because the Appellant has not advanced the design in sufficient detail to enable the derivation of a reliable enough estimate of the cost of those works. To do so would, effectively, place the burden of the economic risk upon the County Council which, in my view, is both unnecessary and unacceptable. The consequences of under-estimating the cost of such works, therefore, is that the bus stops would not be provided and that the diversion of the bus service would not be secured.

6.55 Similarly, the cost of diverting the local bus service amounts to circa £45,600 per annum195 and it is not clear how the Appellant expects this to be funded. In my experience, developers would typically expect to provide the funding to pump-prime such service diversions from an early threshold of occupation (say the tenth dwelling) in order to establish sustainable travel behaviour and for a period of five years from the last occupation. In this case, and assuming three years between occupation of the tenth and final dwellings, that would be equivalent to £364,800 (without indexation). Without such a commitment, and in my opinion, the diversion of the bus service is unlikely to ever be delivered. Even if the Appellant funds the diversion of the bus service, I consider that the patronage will be so low as to render it uneconomically viable without ongoing subsidy. In my view, without such subsidy, the additional fuel cost and time penalty mean it likely that the bus operator will revert to the current route once funding ceases.

194 Based on IP14 3JY (Haughley Park) to Bury St Edmunds (centre) to arrive by 09:00 on a weekday 195 Based on £150 (per day) x 6 (days per week) x 52 (weeks per year) - £1,200 to account for no service being provided on Bank Holidays (based on £150 x 8 (Bank Holidays per annum)

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Local Rail Services

6.56 The analysis summarised in my Table 3.1 (on page 13) suggests that 3% of residents at the appeal proposal are likely to travel by train to their place of work, of those and mindful of the likely journey times by different modes of travel from the appeal site to Elmswell Station, I consider it most likely that rail passengers will travel there (or to Stowmarket Station) by car.

6.57 It is noteworthy that Elmswell Station does not have a car park so, in my view, it is likely to attract kiss- and-ride type trips where rail passengers are dropped-off and picked-up. Such travel behaviour is likely to result in a doubling of primary trip types.

Concluding Remarks

6.58 Overall, nothing in my assessment leads me to conclude that residents at the appeal proposal would be likely to display travel behaviour any different to the estimate (based on my analysis of the ‘location of usual residence and place of work by method of travel to work’ data for the Middle Layer Super Output Area from the 2011 Census) that I provide in my Table 3.1.

6.59 The relevant guidance on maximising the use of sustainable travel opportunities in support of the aims and objectives of the Framework and development plan policy uses the expressions: ‘easily accessible by modes other than the car’; ‘credibly achievable’; ‘making cycling, walking and public transport the modes of choice’; ‘convenience’; ‘genuine’; ‘quality of experience’; ‘positive action’; ‘desirable’, ‘acceptable’ and ‘preferred’; ‘comfortable’; and ‘attractive’. In my view, the appeal proposal does not come close to achieving any of those. To the contrary, it unrealistically endeavours to stretch the concepts of preferred maximum distances and asserts that people’s travel behaviour will, somehow, be different to long established norms.

6.60 For that reason, I cannot find any evidence that leads me to believe that even as much as 9.5% of residents will travel to or from the appeal proposal by sustainable modes of transport and in reality I expect that the proportion will be less than this, bearing in mind the shortcomings outlined above. I agree entirely with the District Council’s case officer when he concluded that it would result in a ‘car dominated’ form of development.

6.61 I consider, therefore, that the first and fourth reason for refusal are well founded.

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The Fall-back Position

6.62 Notwithstanding that each development proposition should be judged on its merits in accordance with prevailing transport and land use planning policy and guidance, I consider (below) the fall-back position of a resumption of the lawful use of the appeal site.

6.63 Noting that the Appellant’s view is that the lawful use of the appeal site could attract a higher number of trips196, I have compared the agreed traffic generation and attraction characteristics of the appeal proposal with the traffic attraction calculation provided in Table 4.1 (on page 14) of the TSoCG for the lawful use, and with the traffic attraction data for the former use provided in Appendix SCGT/D of the TSoCG. I note that Mr Stroud, in his evidence, expresses doubts about the realism of the lawful use resuming in any meaningful way. Since that concerns wider planning issues rather than transport matters, that is not a question that I have addressed. However, if Mr Stroud’s views are accepted, it will follow that my own comparison is looking at a theoretical position only. That comparison is provided in my Table 6.2 (below).

Table 6.2 Comparison of the Traffic Generation and Attraction of the Appeal Proposal with the Traffic Attraction of the Lawful Use and the Former Use

Time Period

Land Use AM Peak Hour PM Peak Hour 12-Hour (08:00-09:00) (17:00-18:00) (07:00-19:00)

The Appeal Proposal* 128 123 1,131

The Lawful Use** 104 114 783

The Former Use*** 50 50**** 390

The Appeal Proposal +24 +9 +348 versus The Lawful Use (+23.1%) (+7.9%) (+44.4%)

The Appeal Proposal 78 +73 +741 versus The Former Use (+156.0%) (+146.0%) (190.0%)

* Source: Table 6.1 (on page 43) above ** Source: Table 4.1 (on page 12) of the Statement of Common Ground on Transportation Issues *** Source: Appendix SCGT/D of the Statement of Common Ground on Transportation Issues **** assumes that all 16:00 to 18:00 trips occur in the PM Peak Hour (a best case scenario for the purposes of this calculation)

6.64 My comparison reveals that the appeal proposal is likely to be circa 25% more traffic generative and attractive than the lawful use and more than one and half times more traffic generative and attractive

196 Statement of Common Ground on Transportation Issues, §4.3 (page 12)

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than the former use during the AM Peak Hour. In considering the typical weekday 12-hour day (07:00 to 19:00), it will be circa 40% more traffic generative and attractive that the lawful use and almost twice as traffic generative and attractive than the former use. It will, inevitably, give rise to an intensification of use of the Haughley Park access road and its junction with Haughley New Road.

Highway Safety

6.65 Matters relating to highway safety do not form part of the District Council’s reasons for refusal, and I make the following observations because the Inspector has identified highway safety as a main issue.

6.66 The road traffic accident history illustrated in the collision plan provided at Appendix D to the Transport Assessment for the area defined in Figure 3 (Study Area) shows that no accidents occurred at the Haughley Park access road junction between 1 February 2013 and 1 February 2018. On the basis that the appeal site has, effectively, been dormant for a number of years, I would have expected the Appellant to have provided data that related to a time period that included a five year period when the appeal site was operational.

6.67 It is common ground that, with reference to the CrashMap database for the 21 years between 1999 and 2019 that there were serious accidents in March 2011 and October 2013, and slight accidents in May 2000 and February 2008 on Haughley New Road between the Warren Lane and Park Road junctions197. That does not indicate to me that there is an inherent highway safety issue.

6.68 The Appellant’s most recent consideration of the visibility splays at the Haughley Park access road junction is provided in Section 2 of the Transport Assessment – Addendum (on pages 2-4). Notwithstanding the advice provided in CD123 and based upon a hybrid (DMRB and Manual for Streets) approach, the Appellant advocates the provision of visibility splays of:-

. ‘X’ = 2.4m, ‘Y’ = 132.6m to the east; and . ‘X’ = 2.4m, ‘Y’ = 195.9m to the west.

6.69 Those visibility splays are illustrated in the Appellant’s Site Access (Sheet 1 of 2) (Alternative Visibility Splays) and Site Access (Sheet 2 of 2) (Alternative Visibility Splays) drawings (number T16026/SK06, Revision A and /SK07, Revision A) (respectively).

197 Statement of Common Ground on Transportation Issues, §2.13 (page 4)

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6.70 The Appellant claims to have measured the existing visibility splays available at the Haughley Park access road junction on 21 November 2019 as:-

. ‘X’ = 2.4m, ‘Y’ = 158m to the east; and . ‘X’ = 2.4m, ‘Y’ = 188m to the west198.

6.71 It noteworthy that paragraph 2.2.5 of the Appellant’s Transport Assessment – Addendum asserts that these visibility splays are “achievable” [its emphasis], and it appears from its consultation response to the District Council of 22 January 2020, that the Highway Authority has accepted these measurements in good faith.

6.72 The Appellant then argues (based on a miss-application, in my view, of the guidance provided in the DMRB) that the appropriate visibility splays are:-

. ‘X’ = 2.4m, ‘Y’ = 122.0m to the east; and . ‘X’ = 2.4m, ‘Y’ = 180.5m to the west.

6.73 With reference to the County Council’s consultation response of 22 January 2020, and it accepting the Appellant’s measurement of the available visibility splays, I note that the local Highway Authority considers that these reduced dimensions are acceptable. In my opinion, and regardless of whether I agree that it is appropriate, or not, I recognise that the Highway Authority is perfectly entitled to accept what it considers to be an acceptable visibility splay.

6.74 It was not appropriate for the Appellant to use 24-hour weekday average traffic speeds of 54.0mph (eastbound, west of the Haughley Park access road junction) and 50.0mph (westbound, east of the junction). CD 185 requires that speed measurements should be undertaken outside of peak traffic flow periods and identifies those as “typically between 10am and noon and 2pm and 4pm”199 and “in dry weather conditions”200.

6.75 With reference to the traffic speed survey data provided in Appendix C to the Appellant’s Transport Assessment, I have re-worked the calculation provided in Appendix B to the Appellant’s Transport Assessment – Addendum [Appendix RL-I] and determined that the appropriate visibility splays are:-

. ‘X’ = 2.4m, ‘Y’ = 125.7m to the east; and . ‘X’ = 2.4m, ‘Y’ = 186.0m to the west.

198 Transport Assessment – Addendum, §2.2.5 (page 3) 199 CA 185, §2.8.2, Note 1 (page 9) 200 Ibid, §2.5.1 (page 9)

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6.76 That said, while the Appellant’s drawings demonstrate that the visibility splays accepted by the County Council appear achievable in the horizontal plane, they do not demonstrate that they can be achieved in the vertical plane.

6.77 That question has been further examined by the County Council in response to information provided to it by Mr Williams’s transport consultant (Cannon Consulting Engineers). The County Council has provided an updated position in its Highways Access Visibility Review dated 11 December 2020 [Appendix RL-H]. Whilst the County Council has not altered its recommendation, it has spelt out in more detail what measures are required in order to ensure that adequate visibility is secured. Essentially, the County Council considers that either there need to be substantial engineering works to achieve the visibility that is appropriate to the measured traffic speeds, or a reduction in the speed limit to 40mph needs to be secured.

6.78 Notwithstanding this clarification of the County Council’s position, it remains my view that the matter could be addressed by the imposition of a Grampian-type condition to prevent the commencement of the implementation of the appeal proposal until either of the measures identified by the County Council (engineering works to re-profile Haughley New Road or a reduction of the speed limited) has been delivered.

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Consideration of the Rule Six Party’s Statement of Case and Third Party Representations

7.1 I consider below the dominant themes related to transport and highway matters expressed in the Rule 6 Party’s (Robert William’s) Statement of Case, and other third party representations that I have had sight of.

Robert Williams’s Statement of Case

7.2 I note from Mr Williams’s Statement of Case that the right of way that has been granted in respect of the use of the Haughley Park access road between the appeal site and the public highway “is limited in terms of both physical extent and use”201.

7.3 Mr Williams also confirms that there “are no public footpaths, cycleways, bridleways, or other forms of public access points across either Haughley Park or the appeal site”202, and he states that “the Appellant is unable to either alter, extend, or amend the existing access road for any form of physical improvements without the explicit consent of the landowner”203 (Haughley Park Limited).

7.4 That is important because it would appear, therefore, that the Appellant is unable to respond positively to my criticisms of its suggested use of the Haughley Park access road as a shared surface consistent with the guidance provided in the Manual for Streets and in the Suffolk Design Guide without the consent of a third party.

The Local Parish Council

7.5 In its submission to the Planning Inspectorate of 8 October 2020, Haughley Parish Council confirms that it excluded the residential development of the appeal site from the Neighbourhood Plan “because there were more appropriate sites”. It highlights the absence of public transport provision, and pedestrian and cycle routes to the shopping facilities in Haughley, Elmswell and Woolpit, and is concerned that, consequentially, a “significant increase in traffic movement from the proposed site can be expected”.

201 Mr Robert Williams’s Statement of Case, §1.7 (page 2) 202 Ibid, §2.5 (page 4) 203 Ibid, §2.6 (page 4)

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7.6 In terms of the sustainability credentials of the appeal site, the local Parish Council draws comparison with recent housing development in Elmswell and Woolpit that it considers represent sustainable forms of development.

Neighbouring Parish Councils

7.7 In its submission to the Planning Inspectorate of 8 October 2020, Wetherden Parish Council expresses its view that increased pedestrian traffic along Park Road would be unsafe “due to its restricted width and the complete lack of footpaths for the majority of its length”. I note, also, that it considers that the “current bus service cannot be routed via Park Road, Wetherden due to width and weight restrictions” and that the “roads around the village are dangerous for pedestrians and cyclists”.

7.8 I do not consider that Wetherden Parish Council is correct when it says that the weight restriction imposed upon Park Road would prohibit buses. The road sign indicating the weight restriction is to diagram 622.1A of The Traffic Signs Regulations and General Directions 2016 (Statutory Instrument 2016 No 362), as amended. It means: ”Goods vehicles exceeding the maximum gross weight indicated prohibited”204. As I understand it, it does not prohibit the passage of buses or coaches, and I note that a separate sign (diagram 952)205 is used to do that.

Other Third Party Representations

7.9 I have not read any other third party representations that raise any issues that I have not addressed elsewhere in my evidence.

204 The Traffic Signs Regulations and General Directions 2016, as amended, Item 13 (page 71) 205 Ibid, Item 17 (page 71)

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Summary Proof of Evidence and Conclusions

8.1 My name is Rupert Lyons and my evidence to this Public Inquiry is concerned with the transport planning and highway engineering issues arising from the District Council’s refusal of an outline planning application made by the Appellant for the appeal proposal at the appeal site.

8.2 The District Council refused planning permission for the appeal proposal for seven reasons206, the first and fourth of which relate to the remoteness of the appeal site and the dependency that future residents and occupiers of the appeal proposal with have on car travel.

My Qualifications and Experience

8.3 I have a Master of Science degree in Transportation Planning and Engineering from the University of Southampton and I am a Chartered Member of the Institute of Logistics and Transport. In 1997, I became a founding Director of Transport Planning Associates. I have advised developers and promoters of a wide range of residential and residential-led development proposals in many regions of the United Kingdom.

8.4 I am familiar with the appeal site and its environs having undertaken a site visit on Monday, 12 October 2020.

Scope and Nature of Evidence

8.5 My evidence to this Inquiry relates to the first and fourth reasons for the District Council’s refusal of planning permission for the appeal proposal207 and to the main issues identified by the Inspector in his Case Management Conference Summary Note:-

. whether the appeal proposal would be in an appropriate location having regard to the development plan and national land use and transport planning policies; . whether it would provide acceptable access to services and facilities; and (although I acknowledge that this issue did not form part of the District Council’s reasons for refusal) . its effect on highway safety.208

206 DC/19/02605 Decision Notice (24 April 2020) 207 Ditto 208 Case Management Conference Summary Note (23 October 2020), §6 (pages 1-2)

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The Baseline Conditions

8.6 The appeal site lies in the Parish of Haughley but it is not physically related to the village. It is common ground that the village of Haughley is (approximately) a travel distance of 3.5 kilometres (2.2 miles) from the appeal site209.

8.7 The nearest village is Wetherden, which is (approximately) a travel distance of 1.5 kilometres (0.9 miles) away210. It has limited facilities or services comprising a village hall, playing fields (including a play area, tennis courts and sports pitches), bus stops, and formerly a public house that I understand permanently closed in 2019.

8.8 A larger number of facilities and services are provided in Elmswell, which is (approximately) a travel distance of 3.5 kilometres (2.2 miles) away211.

8.9 More extensive facilities and services are provided in Stowmarket, which is (approximately) a travel distance of 7.0 kilometres (4.3 miles) away212.

8.10 The nearest primary school (Elmswell Community Primary School) is situated at Elmswell, and it is common ground that this school is (approximately) a travel distance of 3.8 kilometres (2.4 miles) from the appeal site213. The nearest co-educational secondary schools and sixth forms are in Stowmarket (Stowmarket High School) and at Stowupland near Stowmarket (Stowupland High School). They are (approximately) travel distances of 8.1 kilometres (5.0 miles) and 10.6 kilometres (6.6 miles) away214 (respectively).

8.11 The nearest convenience store (East of England Co-op) is situated at Elmswell and it is common ground that this store is (approximately) a travel distance of 3.5 kilometres (2.2 miles) from the appeal site215. The nearest supermarket (Asda Stowmarket Superstore) at Stowmarket is (approximately) a travel distance of 7.8 kilometres (4.8 miles) away216.

209 Statement of Common Ground on Transportation Issues, §2.3 (page 2) 210 Ibid, §2.3 (page 2) 211 Ditto 212 Ibid, §2.2 (page 2) 213 Ibid, Appendix SCGT/A 214 Ditto 215 Ditto 216 Ditto

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Vehicular Access to the Appeal Site

8.12 Vehicular access to the appeal site is via a private road from the public highway at Haughley New Road (the U4977). I understand that the private access road is within the ownership of Haughley Park Limited and that the Appellant has rights of access over it but that such rights do not permit the Appellant to undertake any works to the road217.

Existing Highway Network

8.13 The local and wider highway network in the vicinity of the appeal site is illustrated in Figures 1 (Site Location) and 2 (Local Highway Network) in the Appellant’s Transport Assessment.

8.14 Based a survey undertaken between Tuesday, 19 and Monday, 25 June 2018, I have determined that the 85th percentile traffic speeds along Haughley New Road are:-

. eastbound (measured to the west of the junction): 52.1mph (83.8kph); and . westbound (measured to the east of the junction): 48.1mph (77.4kph) [Appendix RL-C]

Existing Sustainable Travel Opportunities – Walking

8.15 The Appellant’s Transport Assessment acknowledges that “the most likely destination for pedestrian trips generated” by the appeal proposal “are the local facilities and bus stops in Wetherden”218. It also acknowledges that the local primary schools and shopping facilities in Elmswell and Haughley are beyond 2 kilometres from the appeal site.

8.16 The Appellant’s Transport Assessment219 and Sustainable Travel Report220, and Mr Williams’s Statement of Case221 confirms that there are no PRoWs within or across the appeal site, and that is common ground.

Existing Sustainable Travel Opportunities – Local Bus Services

8.17 The nearest local bus services are accessible in Wetherden. The bus stops there are served by the 384/385 bus service linking Bury St Edmunds and Stowmarket with eight bus services Mondays to

217 Robert Williams’s Statement of Case, §§2.3, 2.4 & 2.6 (page 4) and Appendix 2 218 Ibid, §4.1.6 (page 19) 219 Transport Assessment, §3.1.5 (page 11) 220 Sustainable Travel Report, §3.1.3 (page 9) 221 Robert Williams’s Statement of Case, §2.5 (page 4)

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Fridays (excluding Bank Holidays) and four bus services on Saturdays. No bus services are available on Sundays.

Existing Sustainable Travel Opportunities – Local Rail Services

8.18 It is common ground that Elmswell railway station is approximately 3.7 kilometres (2.3 miles) from the appeal site222 and that the nearest railway station with a car park is at Stowmarket, approximately 7.4 kilometres (4.6 miles) from the appeal site223.

Existing Travel Behaviour

8.19 I have undertaken an analysis of the ‘location of usual residence and place of work by method of travel to work’ data for the Middle Layer Super Output Area from the 2011 Census (provided at Appendix D to the District Council’s Statement of Case). That analysis demonstrates that the propensity for car travel for journeys to work (whether as a car driver or passenger, or as a passenger in a taxi) is in the order of 86%. Recognising that this data relates to the principal mode of travel and that many journeys to work utilise several modes of travel, I estimate that that rises to over 90% if you apply that same proportion of car journeys to the values for ‘bus’ and ‘train’. When considering the application of this data to the appeal site and bearing in mind the distances between it and the nearest bus stops and railway station, that estimate is based on the assumption that 86.2% of people whose principal mode of travel to work is by bus or by train will have either driven to or been driven to those bus stops or the railway station.

Relevant Land Use and Transport Planning Policy, Guidance and Precedent

8.20 The relevant land use and transport planning policy is provided in the Framework and in the development plan framework.

8.21 Guidance on the provision of sustainable travel opportunities has, most recently, been published by the CIHT and the DfT. Standards for the geometric design of at-grade priority junctions is provided in the relevant sections of the Manual for Streets and the DMRB. I note also that the Appellant acknowledges the guidance provided in the Suffolk Design Guide224.

222 Statement of Common Ground on Transportation Issues, Appendix SCGT/A 223 Ditto 224 Ibid, §5.2.3 (page 22)

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The National Planning Policy Framework

8.22 Paragraph 103 of the Framework includes the core land use and transport planning principle that: “Significant development should be focussed on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.”225

8.23 Paragraph 108 of the Framework requires, inter alia, that:

“In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that:

d) Appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location; and that

e) Safe and suitable access to the site can be achieved for all users”226

8.24 In that context, paragraph 110 tells us that applications for development should, inter alia:-

“a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;

d) Create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards”.227

Core Strategy Focussed Review

8.25 Chapter 3 of the Core Strategy Focussed Review (2012) describes the District Council’s approach to delivering sustainable development. Policy FC 1.1 requires the appeal proposal to “demonstrate the principles of sustainable development”228.

225 National Planning Policy Framework, §103 (page 30) 226 Ibid, §108 (pages 31-32) 227 Ibid, §110 (page 32) 228 Ibid, Policy FC 1.1 (page 11)

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Relevant Guidance and Standards

8.26 In my view, the relevant guidance and standards pertinent to the consideration of the appeal proposal are provided in the following documents:-

. Better planning, better transport, better places; . Building Sustainable Transport into New Developments; . Planning for Walking; . Designing for Walking; . Inclusive Mobility – A Guide to Best Practice on Access to Pedestrian and Transport Infrastructure; . the Guidelines for Providing for Journeys on Foot; . Planning for Cycling; . Cycle Infrastructure Design (Local Transport Note 1/20); . Buses in Urban Developments; . the Manual for Streets; . Manual for Streets 2; . the Design Manual for Roads and Bridges; and . the Suffolk Design Guide for Residential Areas.

The Appeal Proposal

8.27 I note that the Appellant’s Transport Assessment and Sustainable Travel Report refers to “a residential development of 134 dwellings, small scale employment units, a community building, playing fields and public open space”229 rather than the description of the appeal proposal provided in paragraph 2.1 of the Appellant’s Statement of Case. For the avoidance of doubt, and where necessary, I have accounted for the reduction in the number of dwellings proposed to 120 in my evidence to this Inquiry.

Proposed Site Access Arrangements

8.28 The proposed site access arrangements comprise the use of the existing Haughley Park access road to gain access to the appeal proposal.

8.29 With regard to the junction of the Haughley Park access road with Haughley New Road, the Appellant initially advocated a reduction in the speed limit of Haughley New Road from the existing national speed limit to 40mph, and it agreed to fund (up to £10,000) the necessary process.

229 The Appellant’s Transport Assessment & Sustainable Travel Report, §1.2.1 (page 1) (both)

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8.30 With regard to access for pedestrians and cyclists, the Appellant’s Transport Assessment asserts that the existing access road is “sufficiently wide to operate satisfactorily as a shared-surface route”230. I do not agree.

Proposed Transport Infrastructure and Services Improvements

8.31 The Appellant proposes the provision of a new footway along the southern side of Haughley New Road, an informal pedestrian crossing of Haughley New Road and a new footway along the western side of Park Road (as far as the junction with Park View).

8.32 The Appellant identifies the existing PROW from the end of Park View in Wetherden to Mill Gardens in Elmswell as “a viable route to and from Elmswell, particularly during the summer months”231. It asserts that the “un-paved section of the route could also potentially be up-graded using gravel or a similar loose material”232. I do not consider that this is a viable walking route from the appeal site to Elmswell Primary School.

Bus Services

8.33 The Appellant proposes the diversion of the route of the 384/ 385 local bus service via Haughley New Road and Park Road, together with the provision of new bus stops on Haughley New Road and the relocation of the existing bus stops in the centre of Wetherden233.

Proposed Travel Planning Initiatives

8.34 A Framework Travel Plan is provided at Appendix SCGT/C to the TSoCG.

The Highway Authorities’ Consultation Responses

8.35 Based on the content of the Appellant’s Transport Assessment - Addendum and subject to “suitable highways mitigation measures being secured by Planning Condition or Planning Obligation”, the County Council’s officer recommended that planning permission was not refused on highways grounds.

230 The Appellant’s Transport Assessment - Addendum, §5.4.1 (page 22) 231 Ibid, §5.2.2 (page 9) 232 Ibid, §5.2.3 (pages 9-10) 233 The Appellant’s Transport Assessment, Figure 6

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8.36 It is noteworthy that the County Council‘s officer’s recommendation was subject to the following caveat:-

“However, should the highways mitigation measures set out in this letter not be achieved, the development as currently planned would result in a Severe Impact, contrary to Paragraph 109 of the revised National Planning Policy Framework (2019), and therefore permission should be refused.”234

8.37 Pertinently, in the context of my evidence to this Inquiry and in his final sentence, the County Council’s officer notes that “the site is clearly very remote from key services” and he suggests “the full range of NPPF paragraphs should be used to assess the sustainability of the site and the suitability for this form of development”235.

The Case Officer’s Assessment

8.38 The author of the District Council’s Delegated Report for Consideration under Chief Executive’s Emergency Powers as Duly Authorised during the Present Coronavirus Pandemic dated 15 April 2020 recommended the refusal of outline planning permission for the appeal proposal.

8.39 In his assessment, the appeal proposal “is isolated from any settlement in the wider locality and bears no functional relationship with them”236, and he concluded that:

“the proposed residential development is in and of itself contrary of the land use planning policies of the Council insofar as the site is within countryside remote from and not easily accessible to facilities and services necessary to sustain a new community without the use of the car”.237

8.40 He acknowledges that the County Council does not object to the appeal proposal and concludes that it “is acceptable from a highway safety and capacity perspective”, and stresses that does not include consideration of its sustainability credentials238.

8.41 In his consideration of the sustainability credentials of the appeal proposal, he expressed the view that:

“The site does not provide sustainable access to local facilities many of which are in excess of 2 miles away. There will be an unacceptable over reliance on the car as the preferred means of

234 Suffolk County Council’s letter of 22 January 2020 to Mid Suffolk District Council refers 235 Ditto 236 Delegated Report (page 14) 237 Ibid (page 18) 238 Ibid (page 38)

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travel contrary to the advice within the NPPF to encourage travel by sustainable means of transport in new development”239.

8.42 With reference to Table 3.2 (on page 49) of the CIHT’s Guidelines for Providing for Journeys on Foot (2000), he determined that “the walking distances from this site to key services will be far in excess of these maximum figures”, and he concluded that the appeal proposal is not consistent with the requirements of Section 9 of the Framework240.

8.43 In balancing the various issues, he feels that:

“The fact that the proposal generates no highway safety and no highway capacity issues sufficient to warrant a refusal of planning permission and the offer to provide footpath connections to Wetherden and Elmswell from the site entrance on the main road should be ascribed modest weight because for any proposed development to be acceptable it must pass basic highway safety and capacity tests and the offer to extend footpaths can only attract low weight because the distances involved are such as to limit the extent to which they will ever be used by pedestrians and even cyclists.”241

8.44 He recommended that the planning application for the appeal proposal should be refused.

The Decision

8.45 The planning application for the appeal proposal was refused by notice dated 24 April 2020 for seven reasons.

8.46 Of relevance to my evidence to this Inquiry, the first reason relates to the principle of the appeal proposal insofar as the appeal site “is in the countryside remote from any easily accessible neighbouring settlement [or defined settlement boundary] where necessary facilities and services are available”, contrary, inter alia, to Policy FC1.1.

8.47 The fourth reason relates to the sustainability of the appeal proposal “as a result of its remote, isolated location” where “occupiers will inevitably have to rely on the car to access anywhere beyond the immediate development” because services and “facilities within sustainable settlements in the wider locality are not appropriately accessible”, contrary to the Framework and Policy FC1.1.

239 Ibid, (page 39) 240 Ibid, (pages 40-41) 241 Ibid, (page 50)

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Appropriate Location for the Appeal Proposal

8.48 It is common ground that the centre of the appeal site is approximately 780m from the public highway; 1.5 kilometres (0.9 of a mile) from Wetherden; 3.5 kilometres (2.2 miles) from Elmswell; and 7.0 kilometres (4.4 miles) away from Stowmarket.

8.49 The appeal site is remote from the range of day-to-day facilities and services that residents at the appeal proposal should be able to access comfortably on foot. Those facilities and services are considerably beyond the ‘preferred maximum’ walking distances identified in the Guidelines for Providing for Journeys on Foot.

8.50 Haughley New Road is currently subject to the national speed limit but even in the scenario whereby that speed limit is reduced to 40mph, without the provision of protected space for cyclists, only a small minority of residents at the appeal proposal will consider cycling. Most potential cyclists will be excluded because they will fear cycling on the carriageway.

8.51 Even if new bus stops are provided in the vicinity of the Park Road junction with Haughley New Road, and service numbers 384/385 diverted for a period of time, they will be almost four times the recommended maximum walking distance of 300m provided in Buses in Urban Developments.

8.52 Given the locational characteristics of the appeal site, I consider that it is poorly located and inaccessible by sustainable transport modes. It is my view that implementation of the appeal proposal would result in a highly unsustainable pattern of development.

8.53 In the context of the Framework, therefore, I consider that the appeal site is not a location that is, or can be made, sustainable through limiting the need to travel by offering a genuine choice of transport modes.

The Use of Haughley Park Access Road to Access the Appeal Proposal

8.54 I accept that the existing Haughley Park access road is of adequate horizontal and vertical alignment to accommodate the vehicular traffic likely to be generated by or attracted to the appeal proposal.

8.55 My concern relates to the likelihood, by virtue of the number of vehicles that will use the road, its character and alignment, that residents at the appeal proposal will walk or cycle along it.

8.56 Taken together, the volume of traffic along the Haughley Park access road and the absence of any application of any of the five core design principles means that it is highly unlikely that any resident

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of the appeal proposal other than the most committed pedestrian or cyclist will choose to regularly walk or cycle along it as a matter of routine.

8.57 It is therefore, highly likely that residents at the appeal proposal will consider that their only realistic choice for travel to and from the appeal site is by car (either as a driver or a passenger). For that reason, I do not consider that the appeal site is an appropriate location for the appeal proposal.

8.58 In the context of Policy FC 1.1 of the Core Strategy Focused Review, therefore, and in my view, the appeal proposal cannot demonstrate the principles of sustainable development.

Acceptable Access to Services and Facilities

8.59 Any assessment of the propensity of residents of the appeal proposal to walk from their homes to the services and facilities that they require to meet their day-to-day needs is a function of their ability to do so (in terms of the availability of adequate infrastructure) and the distances involved (recognising that people’s motivation to walk is interdependent on the attractiveness of the destination).

8.60 The Appellant does not argue that residents of the appeal proposal will walk further than Wetherden in order to access local services and facilities, and acknowledges that such services and facilities are limited.

8.61 Regardless of the Appellant’s proposed provision of new footways, I do not consider it likely that any resident at the appeal proposal (other than the most committed pedestrian or those without access to a car) will choose to walk to any local services or facilities.

8.62 Conspicuous by their absence from the appeal proposal are any proposals to provide any infrastructure for cyclists that would encourage residents to choose to cycle to services and facilities that they need to routinely access.

8.63 I consider it highly unlikely that any resident at the appeal proposal will choose to cycle to access local services and facilities.

8.64 Similarly, and mindful of the guidance in Buses in Urban Developments, I consider it highly unlikely that any resident at the appeal proposal other than those without access to a car would choose to take a bus to access local services and facilities.

8.65 The analysis summarised in my Table 3.1 (on page 13) suggests that 3% of residents at the appeal proposal are likely to travel by train to their place of work, of those and mindful of the likely journey

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times by different modes of travel from the appeal site to Elmswell Station, I consider it most likely that rail passengers will travel there (or to Stowmarket Station) by car.

8.66 Nothing in my assessment leads me to conclude that residents at the appeal proposal would be likely to display travel behaviour any different to the estimate (based on my analysis of the ‘location of usual residence and place of work by method of travel to work’ data for the Middle Layer Super Output Area from the 2011 Census) that I provide in my Table 3.1.

8.67 The relevant guidance on maximising the use of sustainable travel opportunities in support of the aims and objectives of the Framework and development plan policy uses the expressions: ‘easily accessible by modes other than the car’; ‘credibly achievable’; ‘making cycling, walking and public transport the modes of choice’; ‘convenience’; ‘genuine’; ‘quality of experience’; ‘positive action’; ‘desirable’, ‘acceptable’ and ‘preferred’; ‘comfortable’; and ‘attractive’. In my view, the appeal proposal does not come close to achieving any of those. To the contrary, it unrealistically endeavours to stretch the concepts of preferred maximum distances and asserts that people’s travel behaviour will, somehow, be different to long established norms.

8.68 For that reason, I cannot find any evidence that leads me to believe that any more than 9.5% of residents will travel to or from the appeal proposal by sustainable modes of transport. I agree entirely with the District Council’s case officer when he concluded that it would result in a ‘car dominated’ form of development.

8.69 I consider, therefore, that the first and fourth reason for refusal are well founded.

The Fall-back Position

8.70 Noting that the Appellant’s view is that the lawful use of the appeal site could attract a higher number of trips242, I have compared the agreed traffic generation and attraction characteristics of the appeal proposal with the traffic attraction calculation provided in Table 4.1 (on page 14) of the TSoCG for the lawful use, and with the traffic attraction data for the former use provided in Appendix SCGT/D of the TSoCG.

8.71 That comparison reveals that the appeal proposal is likely to be circa 25% more traffic generative and attractive than the lawful use and more than one and half times more traffic generative and attractive than the former use during the AM Peak Hour. In considering the typical weekday 12-hour day (07:00 to 19:00), it will be circa 40% more traffic generative and attractive that the lawful use and almost twice

242 Statement of Common Ground on Transportation Issues, §4.3 (page 12)

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as traffic generative and attractive than the former use. It will, inevitably, give rise to an intensification of use of the Haughley Park access road and its junction with Haughley New Road.

Highway Safety

8.72 That said, while the Appellant’s drawings demonstrate that the visibility splays accepted by the County Council appear achievable in the horizontal plane, they do not demonstrate that they can be achieved in the vertical plane.

8.73 That question has been further examined by the County Council in response to information provided to it by Mr Williams’s transport consultant. The County Council has provided an updated position in its Highways Access Visibility Review [Appendix RL-H]. The County Council considers that either there need to be substantial engineering works to achieve the visibility that is appropriate to the measured traffic speeds, or a reduction in the speed limit to 40mph needs to be secured.

8.74 Notwithstanding this clarification of the County Council’s position, it remains my view that the matter could be addressed by the imposition of a Grampian-type condition to prevent the commencement of the implementation of the appeal proposal until either of the measures identified by the County Council (engineering works to re-profile Haughley New Road or a reduction of the speed limited) has been delivered.

Consideration of the Rule Six Party’s Statement of Case and Third Party Representations

8.75 I note from Mr Williams’s Statement of Case that the right of way that has been granted in respect of the use of the Haughley Park access road between the appeal site and the public highway “is limited in terms of both physical extent and use”243.

8.76 Mr Williams also confirms that “the Appellant is unable to either alter, extend, or amend the existing access road for any form of physical improvements without the explicit consent of the landowner”244 (Haughley Park Limited).

8.77 That is important because it would appear, therefore, that the Appellant is unable to respond positively to my criticisms of its suggested use of the Haughley Park access road as a shared surface consistent

243 Mr Robert Williams’s Statement of Case, §1.7 (page 2) 244 Ibid, §2.6 (page 4)

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with the guidance provided in the Manual for Streets and in the Suffolk Design Guide without the consent of a third party.

Other Third Party Representations

8.78 I have not read any other third party representations that raise any issues that I have not addressed elsewhere in my evidence.

Conclusions

Appropriate Location for the Appeal Proposal

8.79 In the context of the Framework, the appeal site is not a location which is or can be made sustainable or that offers access to a genuine choice of transport modes. There are no meaningful opportunities for the promotion of sustainable travel that can be taken up. It is not able to give priority to pedestrian and cycle movements to neighbouring areas, and it lies outside the realistic catchment areas for bus services. It cannot minimise the conflicts between pedestrians, cyclists and vehicles along the Haughley Park access road. Similarly, its location will not help in the reduction of greenhouse gas emissions.

8.80 For those reasons, therefore, and with regard to the main issues identified by the Inspector in his Case Management Conference Summary Note, I conclude that the appeal site is not an appropriate location for the appeal proposal having regard to the development plan and national land use and transport planning policies.

Acceptable Access to Services and Facilities

8.81 The appeal site, hence the appeal proposal, lies beyond the widely recognised and acknowledged preferred maximum walking distances to any local services or facilities. The consequences of which are that adult residents at the appeal proposal would be highly dependent on the private car (as a driver or a passenger) in order to access local services and facilities to meet their day-to-day needs.

8.82 The overwhelming majority of younger children will be driven to school and the majority of older children will rely on school funded transport to access secondary education. A substantial minority will also be driven to school.

8.83 I estimate that in excess of 90% of residents will rely on the private car (as a driver or a passenger) for part of their journey to work, and that more than 86% will rely on cars for their entire journeys.

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8.84 The Appellant’s proposed investment in improved transport infrastructure and services is inadequate and unlikely to have any meaningful impact on the modal choice of residents at the appeal proposal such that it can be rightly characterised as a ‘car dependent’ development.

8.85 For those reasons, therefore, and with regard to the main issues identified by the Inspector in his Case Management Conference Summary Note, I conclude that the appeal proposal does not provide an acceptable level of access to the services and facilities that residents will require to meet their day-to- day needs.

Highway Safety

8.86 I acknowledge that the existing highway network in the vicinity of the appeal site does not have an adverse road safety record.

8.87 I also acknowledge that the County Council has previously accepted in good faith the dimensions of the available visibility splays at the existing Haughley Park access road junction with Haughley New Road in the horizontal plane. That question has been further examined by the County Council in response to information provided to it by Mr Williams’s transport consultant. The County Council now considers that either there need to be substantial engineering works to achieve the visibility that is appropriate to the measured traffic speeds, or a reduction in the speed limit to 40mph needs to be secured.

8.88 Notwithstanding this clarification of the County Council’s position, it remains my view that the matter could be addressed by the imposition of a Grampian-type condition to prevent the commencement of the implementation of the appeal proposal until either of the measures identified by the County Council (engineering works to re-profile Haughley New Road or a reduction of the speed limited) has been delivered..

The First and Fourth Reasons for Refusal

8.89 For all of those reasons, I conclude that the first and fourth reasons for refusal are well-founded, and that the Appellant’s appeal should be dismissed.

Transport Planning Associates 2009-010/POE/01 | December 2020 74 | 74 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-A

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-A Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

A Planning Appeal by

AMBER REI HOLDINGS LIMITED In respect of

Former Poultry Processing Plant, HAUGHLEY PARK, STOWMARKET

Proof of Evidence of Rupert Lyons Schedule of Core Documents

Number Document Published/ Prepared by Front Cover, Date plus page numbers Appeal Documents

01 the Appellant’s Statement of Case Pegasus Group August 2020

02 the District Council’s Statement of Case Mid Suffolk District Council

03 Mr Robert Williams’s Statement of Case James Bailey Planning October 2020

04 Statement of Common Ground on Transportation Craig Rawlinson (Pegasus Group on November 2020 Issues behalf of the Appellant) and Rupert Lyons (Transport Planning Associates on behalf of Mid Suffolk District Council) 05 Statement of Common Ground David Onions (Pegasus Group on November 2020 behalf of the Appellant) and Steven Stroud (on behalf of Mid Suffolk District Council) Application Documents

Transport Planning Associates Appendix RL-A 2009-010/POE/01 | December 2020 Sheet 1 of 4 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

06 The Appellant’s Transport Assessment – Addendum Travis Baker 10 December 2019

07 the Appellant’s Travel Accessibility report Pegasus Group August 2019

08 the Appellant’s Transport Assessment Travis Baker 10 May 2019

09 the Appellant’s Sustainable Travel Report Travis Baker 10 May 2019

10 the Appellant’s Planning Statement Pegasus Group April 2019

Planning Policy

11 the Haughley Parish Neighbourhood Plan Haughley Parish Council 6; 41 June 2019 (adopted by Mid Suffolk District Council on 24 October 2019)

12 The National Planning Policy Framework the Ministry of Housing, 5; 21-22; 24; 30; 31-32; February 2019 (as Communities & Local Government 68; 72-73 amended by a Written Ministerial Statement in June 2019)

13 The Mid Suffolk District Core Strategy Focused Mid Suffolk District Council 7-11 December 2012 Review 14 The Mid Suffolk District Core Strategy [To be read in Mid Suffolk District Council 15-26 September 2008 conjunction with: Core Strategy Focused Review Adopted December 2012 (see sheet inside front cover) 15 the District Council’s Mid Suffolk Local Plan (1998) Mid Suffolk District Council 13 July 2008 as amended by the First Alteration to the Mid Suffolk Local Plan Other Policy

Transport Planning Associates Appendix RL-A 2009-010/POE/01 | December 2020 Sheet 2 of 4 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

16 School Travel Policy; 2019/2020; 2020/2021 Suffolk County Council 3-5; 11; 14-15; 20-22 19 June 2018

Design Manual for Road and Bridges

17 The Design Manual for Roads and Bridges, Road Highways England 4 June 2018 Layout, Design: GG101 Revision 0), Introduction to the Design Manual for Roads and Bridges (formerly GD 01/15) 18 The Design Manual for Roads and Bridges, Road Highways England 12; 15-16 March 2020 Layout, Design: CD109 Revision 1), Highway Link Design (formerly TD 9/93, TD 70/08) 19 The Design Manual for Roads and Bridges, Road Highways England 19-25 August 2020 Layout, Design: CD123 Revision 2, Geometric design of at-grade priority and signal-controlled junctions (formerly TD 41/95, TD 42/95, TD 40/94, and those parts of TD 50/04 and TD 70/08 relating to priority and signal-controlled junctions) 20 The Design Manual for Roads and Bridges, Road Highways England 4; 8-10 November 2019 Layout, Design: CA185 Revision 0), Vehicle speed measurement (formerly TA 22/81) Guidance

21 LTN 1/20 Cycle infrastructure design the Department for Transport 7; 32-33; 61; 155: 172- 27 July 2020 177 22 Better planning, better transport, better places the Chartered Institution of Highways 5-9; 19; 27; & 36-40 August 2019 & Transportation 23 Buses in Urban Developments the Chartered Institution of Highways 5-6; 18-19; 25-27; & January 2018 & Transportation 32-33 24 Planning for Walking the Chartered Institution of Highways 4-6; 8-9; 14-15; & 24- April 2015 & Transportation 35 25 Designing for Walking the Chartered Institution of Highways 3; 7-8; & 38 March 2015 & Transportation

Transport Planning Associates Appendix RL-A 2009-010/POE/01 | December 2020 Sheet 3 of 4 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

26 Planning for Cycling the Chartered Institution of Highways 3-4; 7; 9-10; 17; 23 October 2014 & Transportation 27 Manual for Streets 2 – Wider Application of the the Chartered Institution of Highways 4; 7-8; 74-75; 78; 80 September 2010 Principles & Transportation 28 Building Sustainable Transport into New the Department for Transport 5-6; 8-9; 11; 13-14 2008 Developments: A Menu of Options for Growth Points and Eco-towns 29 Manual for Streets the Department for Transport 45; 61-64; 68; 71-73; 2007 81-83; 90-94; 122-125 30 Inclusive Mobility the Department for Transport Section 3.1 December 2005

31 the Suffolk Design Guide for Residential Areas Suffolk County Council 3; 5; 16; 19; 102 2000

32 Guidelines for Providing for Journeys on Foot the Institution of Highways & 16; 48; 51; 74; 76 2000 Transportation

Transport Planning Associates Appendix RL-A 2009-010/POE/01 | December 2020 Sheet 4 of 4 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-B

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-B Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

A Planning Appeal by AMBER REI HOLDINGS LIMITED In respect of Former Poultry Processing Plant, HAUGHLEY PARK, STOWMARKET

Proof of Evidence of Rupert Lyons

Photographs of the Access Road to Haughley Park and its Junction with Haughley New Road

Plate 1 – Haughley Park Access Road looking north-west towards Haughley New Road

Transport Planning Associates Appendix RL-B 2009-010/POE/01 | December 2020 Sheet 1 of 4

Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

Plate 2 – Haughley Park Access Road looking north towards junction with Haughley New Road

Plate 3 – Haughley Park Access Road Junction looking west along Haughley New Road

Transport Planning Associates Appendix RL-B 2009-010/POE/01 | December 2020 Sheet 2 of 4

Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

Plate 4 – Haughley Park Access Road Junction looking east along Haughley New Road

Plate 5 – Haughley New Road looking south along Haughley Park Access Road

Transport Planning Associates Appendix RL-B 2009-010/POE/01 | December 2020 Sheet 3 of 4

Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

Plate 6 – Haughley New Road looking east at Haughley Park Access Road Junction

Plate 7 – Haughley New Road looking west at Haughley Park Access Road Junction

Transport Planning Associates Appendix RL-B 2009-010/POE/01 | December 2020 Sheet 4 of 4

Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-C

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-C Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

A Planning Appeal by AMBER REI HOLDINGS LIMITED In respect of Former Poultry Processing Plant, HAUGHLEY PARK, STOWMARKET Proof of Evidence of Rupert Lyons

Analysis of Speed Survey Data

Recorded 85th Percentile Traffic Speeds (in mph) Weekday Weekday Average Average Time Day Tuesday Wednesday Thursday Friday Monday 85th%ile Time 85th%ile Period Date 19/06/2018 20/06/2018 21/06/2018 22/06/2018 25/06/2018 Traffic Period Traffic Speed Speed ATC 1 (West of junction)

10:00-11:00 Westbound 47 49 44 48 49 47.4 10:00-12:00 Westbound 47.2 Eastbound 50 50 52 51 51 50.8 Eastbound 51.2 11:00-12:00 Westbound 44 50 49 47 45 47 Eastbound 50 52 51 53 52 51.6

14:00-15:00 Westbound 49 52 45 48 48 48.4 14:00-16:00 Westbound 48.7 Eastbound 51 54 50 50 52 51.4 Eastbound 52.1 15:00-16:00 Westbound 48 50 50 49 48 49 Eastbound 52 51 56 52 53 52.8

ATC 2 (East of junction)

10:00-11:00 Westbound 47 49 46 45 50 47.4 10:00-12:00 Westbound 46.9 Eastbound 52 50 54 53 52 52.2 Eastbound 52.5 11:00-12:00 Westbound 44 49 48 47 44 46.4 Eastbound 52 53 53 53 53 52.8

14:00-15:00 Westbound 49 50 44 48 48 47.8 14:00-16:00 Westbound 48.1 Eastbound 53 55 53 53 51 53 Eastbound 53.5 15:00-16:00 Westbound 49 49 47 48 49 48.4 Eastbound 53 54 55 55 53 54

Note: Survey data sourced from Appendix C to the Appellant's Transport Assessment (May 2019) (prepared by Travis Baker)

Transport Planning Associates Appendix RL-C 2009-010/POE/01 | December 2020 Sheet 1 of 1 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-D

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-D KEY N

Approximate Site Boundary

8 Kilometre Cycle Distance Isochrone

5 Kilometre Cycle Distance Isochrone

Centre of Site

Nearest Bus Stops

Railway Station

Post Office

Library

Doctors Surgery

Pharmacy

Leisure

A BC Pre School

Primary School

Secondary School

Public House

Convenience Store

Supermarket

Dentist

National Cycle Route (NCR) 51

Elmswell NOTE: Isochrones assessed using road routes only and not segregated paths

A BC

Wetherden

Woolpit NCR 51

Haughley

NCR 51

Stowmarket

First Floor, South Wing, Equinox REV DATE BY DESCRIPTION CHK APD North Great Park Road, Almondsbury, Bristol , BS32 4QL

01454 625945 www.pegasusgroup.co.uk Planning | Design | Environment | Economics

CLIENT: SCALE @ A1: CHECKED: APPROVED: AMBER REI 1:20,000 PROJECT: HAUGHLEY PARK, HAUGHLEY, SUFFOLK DATE: DESIGN-DRAWN: DRAWING TYPE: 18/11/2020 ADWS SK

PROJECT No: DRAWING No: REV: TITLE: INDICATIVE 5 KILOMETRE AND 8 KILOMETRE ISOCHRONE CYCLING DISTANCE P17-1438 FIGURE SCGT/1 -

Copyright Pegasus Planning Group Ltd. Crown copyright. All rights reserved. Ordnance Survey Copyright Licence number 100042093. Promap Licence number 100020449. Emapsite Licence number 0100031673 Standard OS licence rights conditions apply. Pegasus accepts no liability for any use of this document other than for its original purpose, or by the original client, or following Pegasus’ express agreement to such use. T 01285 641717 www.pegasuspg.co.uk Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-E

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-E Elmswell (ESW) Managed by Greater Anglia

Elmswell station Station Road Elmswell Suffolk IP30 9HA Station facilities

Post box

Elmswell

Local area maps

TrainTrackerText™

Live departures

Live arrivals

Stations made easy Route planning around the station including maps and platforms

Show [ESW] route

Getting to and from the station Bicycle parking

Stands

Storage sheltered Yes

Storage location Cycle stands on platform 1, cycle lockers on platform 2

Storage spaces 6

Storage CCTV No

Car Park No

Accessible taxis Details of nearest taxis are shown on station information poster

Impaired mobility set No down / pick up points available Ticket buying and collection

Ticket Office No

Ticket machines Yes

Accessible ticket There are accessible ticket machines at this station machines Yes, from ticket machine Collection of pre- purchased tickets No Smartcards Yes, at self-service ticket machine Smartcards issued No Smartcards top-up Staffing and general services Smartcards validators

Information available Monday - Friday Closed from staff Saturday Closed Sunday Closed Information services - opening times Yes Customer help points Available on each platform

Lost Property Yes

Monday - Friday 09:00 - 17:00

Customer Services Monday-Saturday 08:00-20:00 Sunday 10:00-20:00 Bank Holidays 09:00-18:00

The hours shown are for the Customer Relations team on 0345 600 7245 (option 8).

Closed on Christmas Day and Boxing Day. Ticket gates No

CCTV Yes

Location for Rail Replacement transport stop at the bus stop on School road, opposite Co-Op. Replacement Services Facilities

ATM Machine No

Pay phones Yes

Pay phones type Cards and Coins

Toilets No

Waiting Rooms No

Accessibility and mobility access

Helpline Contact 0800 028 28 78

Assisted travel As an alternative to the above number, please use 0345 600 7245 (option 4) if calling from a mobile.

Helpline opening Monday - Sunday 08:00 - 20:00 hours 08:00 - 20:00

Staff help available Yes

Station is not staffed, assistance can be provided to get on and off the train, by the conductor onboard. Booking is recommended.

Staff help available Monday - Sunday Closed opening times A guard/conductor is on each train.

Ramp for train Yes access Yes Step free access coverage This station has step free access to both platforms via the level crossing on station road and approximately 50 metres walk. Step free access note This station is a category B1 station according to ORR station classification system. https://www.orr.gov.uk/media/10955

Assistance meeting point is the platform.

Wheelchairs available No

Station Map

Station plan View larger version

Stations made easy Show [ESW] route Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-F

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-F Start of main content

Stowmarket (SMK) Managed by Greater Anglia

Stowmarket station Station Road East Stowmarket Suffolk IP14 1RQ Station facilities

Stowmarket

Local area maps

TrainTrackerText™

Live departures

Live arrivals

Stations made easy Route planning around the station including maps and platforms

Show [SMK] route Station Message: Alert! Step free access between platforms is via the level crossing, although some wheelchair users may find this route difficult so are advised to access the station via Creeting Road West for journeys towards Colchester and London, and Prentice Road when heading towards Diss and Norwich.

Getting to and from the station Bicycle parking

Lockers,Stands,Wheel Racks

Storage sheltered Yes

Storage location cycle storage in the car park and on each platform

Storage spaces 74

Storage CCTV No

Car Park Station Car Park

Operator National Car Parks Ltd

Address - -

Web address http://www.ncp.co.uk

Email address [email protected]

Opening hours Monday - Friday 24 Hours a Day Saturday 24 Hours a Day Sunday 24 Hours a Day

Number of spaces 382 with 7 accessible spaces available

Accessible car park Wheelchair users can use car park equipment at this station unaided equipment No Free of charge £6.50 Daily rate £4.00 Off peak rate £3.50 Saturday rate £3.50 Sunday rate £30.00 Weekly rate £118.00 Monthly rate £337.00 3 Monthly rate £1180.00 Annual rate No CCTV Coverage Local bus services Onward travel information There is a taxi firm located by the car park entrance. Taxi Details of nearest taxis are shown on station information poster Accessible taxis Impaired mobility set No down / pick up points available Ticket buying and collection

Ticket Office Yes

Opening hours Monday - Friday 06:15 - 19:30 Saturday 07:20 - 16:30 Sunday 09:15 - 18:30

Height adjusted ticket Height adjusted ticket counter is available at this station office counter This office has an induction loop Induction loop Yes Ticket machines There are accessible ticket machines at this station Accessible ticket machines Yes, from ticket machine

Collection of pre- Yes purchased tickets Yes, at either ticket office or self-service ticket machine Smartcards Yes Smartcards issued Greater Anglia Smartcards can be obtained from www.greateranglia.co.uk/smart Smartcards top-up Penalty fares apply for Greater Anglia Smartcards validators Staffing and general services Penalty fares

Information available from staff Monday - Friday 05:00 - 21:30 Saturday 05:00 - 21:30 Information services - Sunday 07:00 - 22:15 opening times

Passenger Departure screens, Announcements, Arrival screens Information Systems Yes Customer help points Help points available on platforms 1 and 2

Lost Property Yes

Monday - Friday 09:00 - 17:00

Customer Services Monday-Saturday 08:00-20:00 Sunday 10:00-20:00 Bank Holidays 09:00-18:00

The hours shown are for the Customer Relations team on 0345 600 7245 (option 8).

Closed on Christmas Day and Boxing Day.

Ticket gates No CCTV Yes

Location for Rail Substitute buses stop outside mainstation entrance (Prentice Road) Replacement Services Facilities

ATM Machine Yes

Located by the ticket office

Pay phones Yes

Pay phones type Cards and Coins

Post box Yes

Outside the station

Public Wi-Fi Yes

Find WiFi Hotspots around Stowmarket station

Refreshment facilities Yes

Coffee kiosk Cold drinks vending machine Food vending machine

Shops Yes

Type of shops News agent available Yes Toilets The toilets are located on Platform 2. Toilets Location Yes Accessible toilets Yes Baby changing facilities

Baby changing Yes facilities location No National key toilets Accessibility and mobility access Waiting Rooms 0800 028 28 78 Helpline Contact As an alternative to the above number, please use 0345 600 7245 (option 4) if calling Assisted travel from a mobile.

Helpline opening Monday - Sunday 08:00 - 20:00 hours 08:00 - 20:00

Staff help available Yes

Assistance at this station is provided by a member of platform staff. Outside of these hours on board train staff will provide assistance. Booking is recommended.

Staff help available opening times Monday - Friday 06:15 - 19:30 Saturday 07:20 - 16:30 Sunday 09:15 - 18:30 Platform Staff MON-SAT 05:00 to 22:15 SUN 07:00 to 22:15

Ramp for train Yes access This station has step free access between platforms via the level crossing. For journeys Step free access note towards Diss and Norwich use Creeting Road West and for journeys towards Colchester and London please use Prentice Road. Distance between the two platforms is approximately 600 metres of 5 minutes walk.

This station is a category B3 station according to ORR station classification system. https://www.orr.gov.uk/media/10955

Assistance meeting point is the ticket office.

Wheelchairs available No

Station Map

Station plan View larger version

Stations made easy Show [SMK] route Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-G

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-G A Planning Appeal by AMBER REI HOLDINGS LIMITED

In respect of Former Poultry Processing Plant, HAUGHLEY PARK, STOWMARKET

Proof of Evidence of Rupert Lyons

Analysis of Location of usual residence and place of work by method of travel to work (MSOA level) Usual Residence = E02006266 : Mid Suffolk 006 (2011 Super Output Area - Middle Layer)

Place of Work Mode of Travel County District Walk Bicycle Bus Train Motorcycle Passenger in Car Driver Other Total District County Car or Taxi

Babergh 2 2 5 103 112 3.5% Forest Heath 1 1 2 6 135 145 4.6% Ipswich 2 1 2 6 4 9 201 1 226 7.1% Mid Suffolk 150 39 25 7 14 62 853 4 1,154 36.5% St Edmundsbury 6 8 32 12 12 77 962 1 1,110 35.1% Suffolk Coastal 6 1 1 1 74 83 2.6% Waveney 3 7 10 0.3% Suffolk 162 50 58 20 26 140 1,896 5 2,357 74.5% Modal Share 6.9% 2.1% 2.5% 0.8% 1.1% 5.9% 80.4% 0.2% 100.0%

Breckland & Thetford Forest 1 43 44 1.4% Broadlands & Broads 1 6 7 0.2% Greater Yarmouth 0 0.0% King's Lynn & West Norfolk 1 4 5 0.2% South Norfolk and Waveney Valley 1 1 1 33 36 1.1% North Norfolk 1 1 0.0% Norwich 5 12 17 0.5% Norfolk 0 1 1 5 0 1 46 0 54 1.7% Modal Share 0.0% 1.9% 1.9% 9.3% 0.0% 1.9% 85.2% 0.0% 100.0%

Basildon 2 7 9 0.3% Braintree 1 1 8 10 0.3% Brentwood 4 4 0.1% Castle Point 0 0.0% Chelmsford 13 13 0.4% Colchester 1 1 1 25 28 0.9% Epping Forest 0 0.0% Harlow 4 4 0.1% Maldon 2 2 0.1% Rochford 1 1 0.0% Southend-on-Sea 0 0.0% Tendering 1 8 1 10 0.3% Thurrock 0 0.0% Uttlesford 7 7 0.2% Essex 0 0 0 1 2 5 79 1 88 2.8% Modal Share 0.0% 0.0% 0.0% 1.1% 2.3% 5.7% 89.8% 1.1% 100.0%

Cambridge 6 1 45 52 1.6% East Cambridgeshire 22 22 0.7% Fenland 0 0.0% Huntingdonshire 7 7 0.2% Peterborough 0 0.0% South Cambridgeshire 1 1 33 35 1.1% Cambridgeshire 0 0 0 7 0 2 107 0 116 3.7% Modal Share 0.0% 0.0% 0.0% 6.0% 0.0% 1.7% 92.2% 0.0% 100.0%

Broxbourne 3 3 0.1% Dacorum 1 1 0.0% East Herts 1 1 0.0% Hertsmere 0 0.0% North Herts 1 3 4 0.1% St Albans 0 0.0% Three Rivers 0 0.0% Watford 2 2 0.1% Welwyn Hatfield 1 1 0.0% Hertfordshire 0 0 0 0 0 1 11 0 12 0.4% Modal Share 0.0% 0.0% 0.0% 0.0% 0.0% 8.3% 91.7% 0.0% 100.0%

Bedford 3 3 0.1% Central Bedfordshire 1 1 0.0% Luton 1 1 0.0% Bedfordshire 0 0 0 0 0 0 5 0 5 0.2% Modal Share 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% 0.0% 100.0%

Greater London 5 1 1 50 3 19 79 2.5% 2.5% Modal Share 6.3% 1.3% 1.3% 63.3% 0.0% 3.8% 24.1% 0.0% 100.0%

Elsewhere in the United Kingdom 6 2 1 38 1 48 1.5% 1.5% Modal Share 12.5% 4.2% 0.0% 2.1% 0.0% 0.0% 79.2% 2.1% 100.0%

No fixed Place of Work 9 3 2 12 18 355 5 404 12.8% 12.8% Modal Share 2.2% 0.7% 0.5% 3.0% 0.0% 4.5% 87.9% 1.2% 100.0%

Total 182 57 62 96 28 170 2,556 12 3,163 100.0% 100.0% Modal Share 5.8% 1.8% 2.0% 3.0% 0.9% 5.4% 80.8% 0.4% 100.0%

Combined Car Driver or Passenger 86.2%

Estimated Car Driver or Passenger to Bus Stop 53

1.7%

Estimated Car Driver or Passenger to Railway Station 83

2.6%

Estimated Total Car Driver or Passenger 90.5%

Transport Planning Associates Appendix RL-G 2009-010/POE/01 | December 2020 Sheet 1 of 1 Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-H

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-H

Highways Access Visibility Review APPEAL BY: Amber REI Holdings Ltd SITE: Former Poultry Processing Plant, Haughley Park, Haughley, Stowmarket Suffolk IP14 3JY

PINS ref: APP/W3520/W/20/3258516 Mid Suffolk District Council Planning Reference Number: DC/19/02605

Luke Barber Suffolk County Council 11th December 2020

1

CONTENTS

Page

1. Introduction 3

2. Planning Application Background 3

3. Highway Access Visibility Review 5

4. Mitigation Options 6

5. Appendices:

Appendix A SCC letter to MSDC dated 22nd January 2020 Appendix B CCE Note dated 18th November 2020 and drawing: ZB811 - PL - SK - 202

2

Introduction I, Luke Barber, Principal Engineer of Suffolk County Council, Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX hereby state as follows:- I am employed by Suffolk County Council (“SCC”) as a Principal Engineer and have been in post since July 2015 and I am currently responsible for major development projects, countywide. I work within the Transport Strategy and Suffolk Highways Development Management Team which is responsible for overseeing the delivery of transport measures and infrastructure and responding to planning applications in Suffolk. I graduated with an HND in Mechanical Engineering from Kingston University in 1996, a BSc in Technology Management in 2005 and a FD in Civil Engineering in 2008, the latter two from University College Suffolk. I have 14 years’ experience working in Transportation and Highway Design in the public sector. I am a Road Safety Audit Team Leader with 10 years’ experience of Road Safety Audit. Where the facts and matters set out in this statement are within my own knowledge they are true and where they derive from other sources they are true to the best of my knowledge and belief.

Planning Application Background Suffolk County Council (SCC) were consulted by Mid Suffolk District Council (MSDC) on the above referenced site during the planning consultation reference DC/19/02605. Throughout the consultation process SCC responded to MSDC setting out the key highway and transportation considerations related to the site. This culminated in the letter dated 22nd January 2020 (Appendix A). This letter stated subject to various conditions being applied the proposed development would not have a severe impact, and permission should not be refused on highway grounds. One of the key conditions was around access visibility from the existing access junction onto Haughley New Road (U4977) which is subject to the National (60 mph) speed limit. The draft condition proposed that:

Visibility Condition: Before the site access road junction onto the U4977 is first used visibility splays shall be provided in accordance with details that have previously been agreed by the LPA in consultation with the highway Authority. Notwithstanding the provisions of Part 2 Class A of the Town & Country Planning (General Permitted Development) Order 1995 (or any Order 3

revoking and re-enacting that Order with or without modification) no obstruction over 0.6 metres high shall be erected, constructed, planted or permitted to grow within the areas of the visibility splays. The approved visibility splay will thereafter be retained in the specified form. Reason: To ensure vehicles exiting the drive would have sufficient visibility to enter the public highway safely and vehicles on the public highway would have sufficient warning of a vehicle emerging in order to take avoiding action.

In the consideration of the original application the applicants, now appellants, originally proposed a 40 mph speed limit for Haughley New Road to ensure adequate access visibility. As a Traffic Regulation Order is required to reduce a speed limit, and this would be subject to separate statutory consultation SCC recommended that this process should be carried out prior to the determination of the planning application. As this would have delayed determination of the application the applicants proposed an alternative approach of measuring the traffic speed on Haughley New Road and measuring the existing visibility to ensure that adequate visibility could be achieved for the measured speed of traffic. This exercise was carried out by the applicants with the following results, which were included in a Transport Assessment - Addendum (TAA):

The TAA stated that the measured speeds on site, taken from a Traffic Speed Survey are as follows: 85th percentile speeds: • Eastbound approach (west of access) = 54.0 mph • Westbound approach (east of access) = 50.0 mph

The TAA stated when corrected in accordance with Design Manual for Roads and Bridges (DMRB) methodology this would give a visibility splay dimension, from a 2.4m setback of: • West of access: 180.5 m • East of access: 122.0 m It is important to note that the November 2019 amendments to Design Manual for Roads and Bridges (DMRB) CA 185 Revision 0 (Vehicle Speed Measurement) removed the ability to apply a correction factor, so the uncorrected speed data should have been used to calculate the appropriate visibility splay.

4

The measured achievable visibility splay from the site access, as stated in the TAA is as follows: • West of access: 2.4m x 188 m • East of access: 2.4m x 158 m

The TAA included a two-dimensional plan on an Ordinance Survey basemap of the visibility splays proposed superimposed on a plan of the SCC highway boundary information. On the basis of the evidence supplied at the time of the application SCC were content to rely on the draft highways condition, as the applicants would need to demonstrate adequate visibility on site was achievable prior to first use of the access by development related traffic. If the proposed development was permitted, and this visibility splay was not achievable to the satisfaction of SCC and the Local Planning Authority (LPA) the applicants have an unsafe site access junction, and be unable to discharge this planning condition, and they would therefore have an un-implementable planning permission.

Subsequently the LPA refused planning permission and the site has proceeded to Planning Appeal, as referenced above.

Highway Access Visibility Review As part of the current appeal proceedings a further highways review has been carried out by Cannon Consulting Engineers (CCE) acting on behalf of a Rule 6 party to the appeal (Mr Robert Williams). This review is more detailed being based on a topographical survey of Haughley New Road in the vicinity of the site access junction. This considered visibility in the vertical plane as well as the horizontal plane, which is important given the undulating nature of the road in this area. This plan and covering letter is included at Appendix B. This plan shows that the theoretical visibility achievable in a horizontal plane is compromised, when measured in accordance with DMRB, by the vertical curvature of the road. This significantly restricts visibility to the west of the site access to 145m, not the 180m agreed as being required. Having received the CCE note I visited the site myself on Saturday 28th November. I carried out observations on site and concluded that the dimensions set out in the CEE

5

note are a fair and accurate representation of the actual visibility achievable from the site access.

Mitigation options It would be possible to mitigate the reduced visibility in two ways, firstly the road profile could be adjusted to remove the crest, opening up the visibility to the required standard. This is technically achievable but would be a significant civil engineering challenge and likely to be a very costly exercise. Secondly, the appellant could fund a Traffic Regulation Order (TRO) consultation, as referenced in the SCC response letter. As stated previously, given the importance of highway safety and the potential for injury collisions if inadequate visibility is achieved, this process would need to be carried out prior to the determination of the application / appeal, or a negatively worded (Grampian) condition used to ensure that the site did not commence until this matter had been fully resolved.

It is important to note that this location would not on the face of it comply with SCC guidelines for new speed limits as the road would not significantly change in nature and the housing proposed would be set back a long way from the road edge, and would not be visible to the passing motorist. Therefore, traffic on Haughley New Road would not see the reason behind any new speed limit, and without extensive traffic calming, compliance would be very poor, and speeds would, in all likelihood be close to the current levels. For these reasons Suffolk Police are likely to object to any order, without extensive measures to ensure the speed limit would be ‘self-enforcing’, and as a statutory consultee with responsibility for speed enforcement in Suffolk their view would carry great weight in the determination of any speed limit TRO consultation process.

6

Your Ref: DC/19/02605/OUT Our Ref: 570\CON\3372\18 Date: 22nd January 2020

All planning enquiries should be sent to the Local Planning Authority. Email: [email protected]

The Planning Officer Mid Suffolk District Council 1st Floor, Endeavour House 8 Russell Road Ipswich Suffolk IP1 2BX

For the Attention of: Vincent Pearce

Dear Vincent

TOWN AND COUNTRY PLANNING ACT 1990 - CONSULTATION RETURN DC/18/03592

PROPOSAL: Outline planning permission (all matters reserved) except the access point for the demolition of existing industrial buildings and construction of 149 dwellings, provision of public open space including playing fields, village greens, green corridors, community orchard, landscaping and surface water attenuation and associated works LOCATION: Former Poultry Processing Plant, Haughley Park, Haughley, IP14 3JY

In response to my previous consultation response letter, dated 28th October 2019, which built upon the points made in the 25th June 2018 and 5th of September 2018 letters, the applicants have produced an updated Transport Assessment Addendum (TAA) dated 10th December 2019. This letter is based on the contents of the TAA.

Notice is hereby given that the County Council as Highways Authority recommends that subject to suitable highways mitigation measures being secured by Planning Condition or Planning Obligation, planning permission is not refused on Highways Grounds. However, should the highways mitigation measures set out in this letter not be achieved, the development as currently planned would result in a Severe Impact, contrary to Paragraph 109 of the revised National Planning Policy Framework (2019), and therefore permission should be refused.

This letter also makes reference to connectivity considerations that should also be taken into account when determining the application, noting the location of the site and its relationship to nearby settlements.

Road Safety – Access Visibility Splay

Currently Haughley New Road (U4977) is subject to a National Speed Limit (60 mph) and the supplied traffic survey data shows that 85%ile speed are around 50-54mph. However, there is local evidence that traffic speeds regularly exceed this, given the free-flowing nature of traffic on this route, and relatively straight alignment with limited junctions or visible development. This is unsurprising as this road was formerly the main A45 east / west trunk road and was designed to a high (although superseded) design standard.

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk

The applicants have proposed installing a 40mph speed limit approx. 150m west of the access to the development in the interest of highway safety as outlined in Drawing No T16026/SK04 & SK05. The intension will be for the developer to enter into unilateral undertaking with SCC to create the Traffic Regulation Order (TRO) to introduce the speed limit. However, there is no guarantee that this TRO would be successful, as it is a separate legal process outside of the control of the Local Planning Authority or the applicants. This speed limit is unlikely to accord with Suffolk Speed Limit policy and Suffolk Police have indicated their reluctance to accept a lower speed limit without speed management features, given the nature of the road. The 28th October letter set out three options for resolving this issue, namely:

1. The developer would pay SCC a sum to carry out the TRO consultation and this would need to be consulted on and positively determined prior to a decision being made on the Planning Application. 2. The developer could revise the access detail with visibility splays suitable for a National Speed Limit road (215m). We would still carry out the consultation on a reduced speed limit, but the back up plan of a splay suitable for the current speed limit of the road would need to be secured. 3. The access condition would re worded negatively, as a Grampian Condition, to cover the eventuality that the speed limit was not deliverable. In this scenario if the speed limit failed through statutory consultation the access would not be achievable and the site could not proceed until an alternative plan had been provided and gone through the necessary consultation processes. This would delay the delivery of the site and be an unsatisfactory situation for all parties. Therefore, the two alternative options are favoured.

The TAA considers the second of these three options, considering the current measured speed of traffic, the current available visibility splay achievable within land controlled by the Highway Authority, and the likely reduction in the vehicular use of the access, when comparing the extant use and the proposed use.

The TAA confirms that the measured speeds on site, taken from a Traffic Speed Survey are as follows:

85th percentile speeds: • Eastbound approach (west of access) = 54.0mph • Westbound approach (east of access) = 50.0mph

When corrected in accordance with Design Manual for Roads and Bridges (DMRB) methodology this would give a visibility splay dimension, from a 2.4m setback of:

• West of access: 180.5m • East of access: 122.0m

The measured achievable visibility splay from the site access is as follows:

• West of access: 2.4m x 188m • East of access: 2.4m x 158m

Therefore, adequate visibility is achievable on site, without the need to reduce the speed limit across the site frontage to 40 mph. However, it is common ground between the applicant and SCC that it would be desirable to do so, if the required Traffic Regulation Order could be made and any objections overcome. Therefore, the proposed unilateral undertaking to provide SCC with funding for a TRO consultation will still be required. Generally, £10K is required for the legal process, the signing could be incorporated into the S278 works for the proposed footway linking the site to Park Road, Wetherden.

As the safety of the site access for the proposed development is now not dependant on the success of the TRO this element of the previous objection is considered to be resolved.

Sustainable Access to Services

The proposed footway improvements linking the site to Park View are welcomed, however there is still no complete footway connecting Park View to the Park Road/Stowmarket Road junction in Wetherden. The pedestrian link proposed is only 800mm wide in parts are falls significantly below the widths that would be considered to be attractive for walking.

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk

In the TAA the applicants have confirmed that the proposed facility is all that can be delivered in land within the control of the Highway Authority. While a wider continuous facility into the centre of Wetherden would be a significant benefit of the scheme, the more limited feasible scheme still has some more marginal benefits in terms of connectivity to the limited range of services in Wetherden village. As the footway provision ends within the 30 mph speed limit and traffic flows on Park Road are considered modest there are no significant additional road safety risks associated with the proposed footway scheme. It does provide access to the Public Rights of Way (PRoW) network which links Wetherden with Elmswell, a more substantial village, with far more facilities, such as schools, a railway station, and shops.

The TAA also assesses the uncontrolled crossing point on New Road at the end of the proposed footway scheme, which provides a link to Wetherden. The assessment considers the width of the road crossing, the average walking speed of pedestrians and traffic flows, and comes to the conclusion that sufficient gaps in the traffic will exist to enable a safe crossing point for pedestrians.

The TAA sets out a proposal to improve the PRoW to provide a virtually traffic free route from Wetherden (and on to the site) to Elmswell. The full walking route from the centre of the development site to the school is shown on Drawing T16026/SK09. The total length of this route has been measured at approximately 3.7km.

It is important to note that this site is not allocated in the current Local Plan and is not currently proposed in the draft Local Plan, which was subject to a “Reg. 18” consultation in 2019. As such, fundamental issues of connectivity have not been explored during a Local Plan process.

It is noteworthy that the proposed Haughley Park development is only accessible from a private road, which has no footways and is not under the control of the applicants. This access road is undulating and is around 750m long between bell mouth and the centre of the site and even when a pedestrian reached Haughley New Road they would be a considerable distance from Wetherden, using the new footway route mentioned earlier in this section. The approximate distance from the centre of the site to Wetherden village is a further approximate 800m, making the total walking distance over 1.5 km. It is also worth noting that Wetherden is a small village with very few amenities, it has no shops, , schools or significant attractors. The nearest basic facilities are in Elmswell, which is a further approximately 2 km miles from Wetherden, and the safest routes to this village would involve a trip via Wetherden, as the direct routes along New Road are not attractive for walking or cycling. This would make the total distance over 3.5 km.

The (now Chartered) Institute of Highways and Transportation (IHT) sets out several walking distances in Guidelines for Providing Journeys on Foot (2000):

Therefore, the walking distances from this site to key services would be far in excess of these maximum figures. That is not to say that some potential residents would not walk at all, but it is clear that walking and cycling would not be attractive modes of travel from this site, resulting in rather ‘car dominated’ travel patterns and very few trips are likely to be carried out by sustainable modes.

While these issues fall below the ‘severe’ test as set out in paragraph 109 of the NPPF, it is clear that the site doesn’t accord with other paragraphs in Section 9 (Promoting sustainable transport) of the NPPF. Therefore, we would expect that the decision maker would take all of these matters

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk

into account in the planning balance when making an assessment of the suitability of this site for this form of development.

Planning Conditions

Should the Planning Authority be minded to grant planning approval we would recommend that the following conditions are applied:

Visibility Condition: Before the site access road junction onto the U4977 is first used visibility splays shall be provided in accordance with details that have previously been agreed by the LPA in consultation with the highway Authority. Notwithstanding the provisions of Part 2 Class A of the Town & Country Planning (General Permitted Development) Order 1995 (or any Order revoking and re-enacting that Order with or without modification) no obstruction over 0.6 metres high shall be erected, constructed, planted or permitted to grow within the areas of the visibility splays.

The approved visibility splay will thereafter be retained in the specified form.

Reason: To ensure vehicles exiting the drive would have sufficient visibility to enter the public highway safely and vehicles on the public highway would have sufficient warning of a vehicle emerging in order to take avoiding action.

Footway Condition: Before the development is first occupied the footway linking the site to key services in Wetherden (along the U4977 and Park Road) shall have been completed in accordance with details that shall have been previously approved by the LPA in consultation with the Highway Authority. The approved scheme shall be retained thereafter in its approved form.

Reason: To provide residents with safe access to key local facilities.

Drainage Condition: Before the development is commenced details shall be submitted to and approved in writing by the Local Planning Authority showing the means to prevent the discharge of surface water from the development onto the highway. The approved scheme shall be carried out in its entirety before the access is first used and shall be retained thereafter in its approved form.

Reason: To prevent hazards caused by flowing water or ice on the highway.

HGV Access Condition: All HGV traffic movements to and from the site over the duration of the construction period shall be subject to a Deliveries Management Plan which shall be submitted to the planning authority for approval a minimum of 28 days before any deliveries of materials commence. No HGV movements shall be permitted to and from the site other than in accordance with the routes defined in the Plan. The site operator shall maintain a register of complaints and record of actions taken to deal with such complaints at the site office as specified in the Plan throughout the period of occupation of the site.

Reason: To reduce and / or remove as far as is reasonably possible the effects of HGV traffic in sensitive areas.

Parking Condition: Before the development is commenced details of the areas to be provided for manoeuvring and parking of vehicles including electric vehicle charging points and secure cycle storage shall be submitted to and approved in writing by the Local Planning Authority. The approved scheme shall be carried out in its entirety before the development is brought into use and shall be retained thereafter and used for no other purpose. Reason: To ensure the provision and long term maintenance of adequate on-site space for the parking and manoeuvring of vehicles, where on-street parking and manoeuvring would be detrimental to highway safety.

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk

NOTE 15 The works within the public highway will be required to be designed and constructed in accordance with the County Council's specification. The applicant will also be required to enter into a legal agreement under the provisions of Section 278 of the Highways Act 1980 relating to the construction and subsequent adoption of the highway improvements. Amongst other things the Agreement will cover the specification of the highway works, safety audit procedures, construction and supervision and inspection of the works, bonding arrangements, indemnity of the County Council regarding noise insulation and land compensation claims, commuted sums, and changes to the existing street lighting and signing. Planning Obligations

As set out above it is proposed to reduce the speed limit of New Road to 40 mph across the frontage of the site. Due to the nature of the road it is likely that some form of traffic calming or speed management signing would be required to satisfy Suffolk Police that a reduced speed limit would have reasonable compliance, given the high speed nature of the road and the historic alignment, given it was formally part of the A45 trunk road from Ipswich to the Midlands. Only SCC can carry out the speed limit order consultation process, but the physical works could potentially be delivered by Planning Condition and S278, as part of the access and footway works.

A potential draft planning condition is below:

Speed Management Condition: Before the development is first occupied a speed management scheme on the U4977 shall have been completed in accordance with details that shall have been previously approved by the LPA in consultation with the Highway Authority. The approved scheme shall be retained thereafter in its approved form.

Reason: To provide residents with safe access onto the adopted highway network.

The minimum contribution for order making would be £10,000, but this figure would be much higher if SCC was required to carry out the speed management works.

The developer has set out a methodology for making walking routes to school (secondary and primary) from the site safe and useable by enhancing the network of Public Rights of Way (PRoW). This is as an alternative to funding the home to school travel costs for children living on the site in the future. This work can be delivered by condition or obligation. Due to the number of potential PRoW affected, and variations in surface condition it is not possible to provide a fully costed scheme at short notice. Therefore, delivering the off site improvement works by condition and S278 may be the preferred option.

A potential draft planning condition is below:

Off Site Access Condition: Before the development is first occupied a public assess improvement scheme covering the key routes from the site to Wetherden and Elmswell shall have been completed in accordance with details that shall have been previously approved by the LPA in consultation with the Highway Authority. The approved scheme shall be retained thereafter in its approved form.

Reason: To provide residents with safe access to key local services, such as Primary and Secondary schools.

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk

Conclusions

This is clearly a complex case with several conflicting factors shaping the potential for development on this site. SCC now has a far better understanding of these issues from the LPA and the developer and the positive dialogue on this site is to be welcomed. While previous SCC response letters have indicated that planning permission should be refused on highway grounds, it is now clear that the developers’ consultants have addressed the fundamental issues around the site access safety and have a variety of mitigation options. However, the site is clearly very remote from key services and the full range of NPPF paragraphs should be used to assess the sustainability of the site and the suitability for this form of development.

Yours sincerely,

Luke Barber Principal Engineer Strategic Development

Endeavour House, 8 Russell Road, Ipswich, Suffolk IP1 2BX www.suffolk.gov.uk

Luke Barber Suffolk County Council

By Email.

18th November 2020

Our Ref: RE//ZB811/Sec/LBarber 181120

Dear Luke,

Planning Application Reference: DC/19/0265 – Mixed Use Development of 134 dwellings, employment provision, community building, public open space and associated works.

Appeal Reference: APP/D3520/W/20/3258516

Former Chicken Processing Factory, Haughley Park.

Cannon Consulting Engineers are currently acting for Haughley Park Limited who are a Rule 6 party at the forthcoming appeal. We are raising concerns related to highway safety in relation to the access and use of the road in its unimproved state through the park which are impacted upon by the lease which does not allow for improvement and only confers use of the surfaced part of the road.

In relation to the site access, I have been considering the position of the Highway Authority in its response to the above planning application and in respect of issues you raised regarding the visibility splays.

I noted in particular that the stance taken by the applicant in both this application and the previous one in 2018, was to put forward a solution that involves reducing the speed limit to 40mph in the vicinity of the access by undertaking the necessary TRO and providing splays in accordance with this new speed limit.

I also noted that in the TA submitted with the application that no mention was made of the achievable splays from the site access and the corresponding vehicle speed of traffic on the approaches. However, the TA Addendum which followed your review of the application went into significant detail to examine the achievable splays from the site access, including measurement on site. It was then determined on the basis of a plan prepared on an OS base that the 40mph speed limit was desirable but not necessary for the appropriate splay to be achieved. In response you agreed with this position and it addressed the concerns of the Highway Authority.

The applicant identified that 188m was achievable and that only 180.5m was necessary using the calculation provided in MfS but having taken into account criteria set out in DMRB. This confirms that DMRB is the applicable design standard at this location and that has been accepted by the applicant.

Having been to site I was concerned by the vertical profile of the road on the approach to the site access from the north and whether or not the splay could be achieved vertically as well as horizontally as had been demonstrated in the submitted TAA.

No information appears to have been presented in the TA in 2019, nor previously in 2018 that considered this detail. However, a topographical survey was submitted as part of the application documents and was used as the basis for the site access drawings in the 2018 application. This included levels on the approach to the access.

Given the importance you placed on achieving adequate visibility for the intended redevelopment of the site and the need to prove acceptability of the 40mph speed limit reduction prior to determination, we have undertaken to check the vertical profile using the submitted topographical survey. The attached drawing has used information in the survey to create a long section following the centreline of the road and then shows the corresponding vertical visibility splays over the distances identified by the applicant at 180.5m (required) and 188m (measured achievable). We have also shown the required splay of 160m which would correspond to a 50mph speed limit.

DMRB requires that the splay is clear of obstruction between the driver eye height of 1.05m and an object height of 0.26m. The sight lines shown at 188m, 180.5m and 160m are obstructed by the vertical profile of the road and do not meet this requirement. The achievable splay is significantly reduced at 146m.

Given the original desire of the applicants to reduce the speed limit, it would appear this is necessary to make the access safe and accord with the accepted design standard. This corresponds with your previous objection and in our view this affects the conclusion reached in the final SCC response to the application.

In light of trying to reach common ground with parties at the appeal on matters we raised in our Statement of Case, I would be grateful if you could consider this information and let us have any further comments.

Yours sincerely,

Robert Evans Director

Encl. Drawing No. ZB811-PL-SK202 cc. James Bailey – JB Planning Robert Williams – Haughley Park Limited

‹ Crown copyright and database rights 2020 Ordnance Survey 100047325 KEY N

NOTES

2.4m x 188m ACHIEVABLE VISIBILITY SPLAY 2.4m x 132m VISIBILITY SPLAY

2.4m x 120m VISIBILITY SPLAY (40mph)

2.4m x 160m VISIBILITY SPLAY (50mph) PLAN VIEW

188m (ACHIEVABLE)

180.5m (REQUIRED)

160m

145m 0.26m

REV DESCRIPTION DE DR CH DATE DESIGNED BY DRAWN BY CHECKED BY - DP - SCALE @ A1 SIZE DATE D.N.S. 29/10/2020 PROJECT TITLE HAUGHLEY PARK

DRAWING TITLE 60.00 SITE ACCESS VISIBILITY SPLAY 1.05m

CLIENT

R. WILLIAMS

Exist. LEVEL 60.84 61.306 61.072 62.910 62.618 62.326 62.060 61.804 61.547 65.221 64.887 64.553 64.217 63.880 63.543 63.206 65.863 65.550

Exist. CHAIN. 0.000 70.080 5.000 69.955 180.000 185.000 189.491 105.000 110.000 115.000 120.000 125.000 130.000 135.000 140.000 145.000 150.000 155.000 160.000 165.000 170.000 175.000 100.000 66.176 90.000 66.760 95.000 66.489 75.000 67.511 80.000 67.278 85.000 67.019 60.000 68.179 65.000 67.973 70.000 67.742 40.000 68.907 45.000 68.738 50.000 68.572 55.000 68.381 25.000 69.404 30.000 69.251 35.000 69.079 10.000 69.830 15.000 69.702 20.000 69.553

SECTION THROUGH ROAD CENTER LINE VERTICAL ALIGNMENT SCALED UP BY 5

Peek House, 20 Eastcheap Cambridge House, Lanwades London, Business Park, Kentford, EC3M 1EB Newmarket, CB8 7PN Tel: 020 7717 5870 Tel: 01638 555107 [email protected] www.cannonce.co.uk

DRAWING NUMBER REV. ZB811 - PL - SK - 202 - M:\ZB811 Haughley Park Stowmarket\3 PLANS\DRAWINGS\CURRENT DRGS\ZB811 - PL - SK - 202 - VISIBILITY PLAN (CENTRE LINE) PLAN (CENTRE - 202 - VISIBILITY - PL - SK DRGS\ZB811 PLANS\DRAWINGS\CURRENT Park Stowmarket\3 Haughley M:\ZB811

NOTE THE PROPERTY OF THIS DRAWING AND DESIGN IS VESTED IN CANNON CONSULTING ENGINEERS AND MUST NOT BE COPIED OR REPRODUCED IN ANY WAY WITHOUT THEIR WRITTEN CONSENT Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

APPENDIX RL-I

Transport Planning Associates 2009-010/POE/01 December 2020 Appendix RL-I Mid Suffolk District Council Former Poultry Processing Plant, Haughley Park, Stowmarket

A Planning Appeal by AMBER REI HOLDINGS LIMITED In respect of Former Poultry Processing Plant, HAUGHLEY PARK, STOWMARKET Proof of Evidence of Rupert Lyons

Re-working of the Visibility Splay Calculation provided at Appendix B to the Appellant's Transport Assessment - Addendum (December 2019)

EASTBOUND - Desirable Minimum Approach SSD WESTBOUND - Desirable Minimum Approach SSD

2 2 SSD = vt + v / 2(d+0.1a) SSD = vt + v / 2(d+0.1a)

Where, Where, v = 85th percentile speed (metres/ second) v = 85th percentile speed (metres/ second) t = reaction time t = reaction time 2 2 d = decleration rate (metres/second ) d = decleration rate (metres/second ) a = gradient (%) a = gradient (%)

85th percentile vehicle speed 85th percentile vehicle speed v = 52.1mph v = 48.1mph 83.8kph 77.4kph 23.29m/s 21.50m/s

t = 2MfS2 t = 2MfS2

d = 2.45MfS2 d = 2.45MfS2

a = -4.7 a = 4.3

Therefore, Therefore, vt = 46.58 vt = 43.01

2 2 v = 542.46 v = 462.36

2(d+0.1a) = 3.96 2(d+0.1a) = 5.76

SSD = 183.57 SSD = 123.28 Add 2.40 Add 2.40

Total = 185.97metres Total = 125.68metres

Transport Planning Associates Appendix RL-I 2009-010/POE/01 | December 2020 Sheet 1 of 1