CPRE 2: Proof of Evidence – Traffic and safety Public Inquiry concerning the Appeal for Non-Determination of the Outline Planning Application for 440 Dwellings on Land West of Church Road, Otham Maidstone and the Appeal against Refusal of a Planning Application for 421 Dwellings on Land West of Church Road, Otham Maidstone. Maidstone Borough Council (MBC) References: 19/501600/OUT & 20/500084/NONDET and 19/506182/FULL & 20/500109/REF Planning Inspectorate References: APP/U2235/W/20/3254134 and APP/U2235/W/20/3256952 Proof of Evidence for the Public Inquiry concerning the Appeal for Non- Determination of the Outline Planning Application for 440 Dwellings on Land West of Church Road, Otham Maidstone and the Appeal against Refusal of a Planning Application for 421 Dwellings on Land West of Church Road, Otham Maidstone. Maidstone Borough Council (MBC) References: 19/501600/OUT & 20/500084/NONDET and 19/506182/FULL & 20/500109/REF Planning Inspectorate References: APP/U2235/W/20/3254134 and APP/U2235/W/20/3256952 0.1 My name is Malcolm James Kersey. Prior to my retirement from Jacobs Engineering in 2016, I had been responsible for the design and installation of traffic control systems for clients throughout the country. For some 30 years of my career, I specialised in this field for Kent County Council (KCC), the first 16 years as an employee and the remainder as a consultant after the outsourcing of Kent County Council’s Highways department to Babtie Consulting Engineers, later incorporated into Jacobs Engineering. For much of this time I led the team providing traffic control systems in Kent, and personally approved all new traffic signal designs prior to their implementation. 0.2 I have an Honours Degree, Bachelor of Engineering in Civil and Structural Engineering and a further degree, Master of Engineering in Traffic and Transportation Engineering, both from the University of Sheffield. I am a retired Member of the Institution of Civil Engineers and a Chartered Engineer. 0.3 I have lived adjacent to Spot Lane in Bearsted, in the Ecclesiastical Parish of St Nicholas, Otham with St Mary, Langley, for more than 30 years. I am a trustee of the Friends of Otham Church and Vice- chairman of The Bearsted and Thurnham Society. 1 Introduction 1.1 I will use my local knowledge and professional experience to examine the traffic and safety implications of the proposed development at the Appeal Site. I will address the effects of the traffic that would be generated by committed development and that from the Appeal Site. I will consider the impact of the proposed “mitigation measures” on the surrounding road network. 1.2 To place the Appeal Site in the context of the others for which housing development has been approved, Figure 1 is adapted from Maidstone Borough Council’s Adopted Local Plan. The Appeal Site, west of Church Road, is labelled “H1 (8)”, the policy under which development of the site may be considered. Its only connection to the rest of the developments is via Church Road, an unclassified country lane. Those other developments are grouped together with direct connections to A274 Sutton Road. Some of these developments are complete. Most are in various stages of construction. 1.3 It is pertinent to note that, in respect of the development of the Appeal Site, in Policy H1 (8), the Adopted Local Plan requires satisfactory compliance with Policy H1 and some eighteen further criteria to be met. Under the heading “Strategic highways and transportation” these include a “Package of measures to significantly relieve traffic congestion on Sutton Road and Willington Street”. 2 Traffic Predictions 2.1 The documents entitled Transport Assessment submitted in support of the Planning Applications for the Appeal Site, detail the methodology employed to predict traffic flows on the road network in the vicinity of the site in 2029. The chosen year was ten years after the date of the original application, when development on the Appeal Site was expected to be complete. Page 1 of 29 2.2 A series of traffic counts was undertaken in 2018 at fifteen key junctions, as agreed with KCC Highways. These were used to produce network diagrams showing traffic movements presented in Appendix A19 of both documents. A growth factor was reportedly applied to the traffic figures to reflect the likely traffic movements in 2029 as a consequence of general increase of traffic in the wider area. The factor used is not clearly identified in the documentation. A set of network diagrams demonstrating the effect of traffic growth is also not provided. 2.3 A list of eighteen committed developments was agreed with KCC Highways to be considered in order to identify the effect of the traffic generated by them in 2029. These are listed in paragraph 6.33 of the first Transport Assessment (TA). Each committed development was assessed in turn and the generated was assigned to the network. The results are presented as individual peak hour traffic flow diagrams in Appendix A20 of both documents. 2.4 The locations of the key developments south of the Appeal Site are shown in Figure 1. The locations of those north of the site are shown in Figure 2. 2.5 It should be noted that the names of developments shown on the diagrams that have been produced, do not correspond exactly with those listed in paragraph 6.33 of the TA. In particular, there are two pairs of diagrams for the Barty Farm housing development, one of which has supplementary notes indicating inbound and outbound flows for the commercial Woodcut Farm development. 2.6 The two sets of traffic predictions were combined, in Appendix A21 to create Committed Development Flow diagrams for each peak hour as a “Base Case”; effectively the traffic flows that will be experienced in 2029 irrespective of development at the Appeal Site. 2.7 Similar diagrams are presented in Appendix A22 showing predicted traffic to be generated from the Appeal Site, again assigned to the road network. 2.8 All the predictions shown in Appendices A21 and A22 are combined in Appendix A23 to show the flows that might be expected to be experienced in 2029 following completion of the development at the Appeal Site. Discussion 2.9 A new roundabout was constructed on Sutton Road to create a junction with Edmett Way, the spine road for the Langley Park development. It is currently the only means of access for the development, which is still under construction. A preliminary validation of the data presented in Appendix A20 shows no traffic on that road arising from Langley Park. It does show 57% of the 632 vehicles leaving Edmett Way in the AM peak, would be generated by the proposed “Eclipse Park Hotel”, a site located approximately 7km away, as shown in Figure 2. It is apparent that the data submitted has not been subjected to any form of Quality Assurance. 2.10 The remaining 43% of traffic leaving Edmett Way is shown to be generated by “Land South of Sutton Road”. The main access to that development further east on Sutton Road, is not shown. It is proposed to provide a secondary link to Langley Park at the southern end of both sites, but it seems highly unlikely that this would be used as a favoured route to join Sutton Road. 2.11 An assessment of the data presented in Appendix A20 for northbound traffic on two key links in the network yields the results shown in Table 1. 2.12 The names of the developments are as shown on the diagrams in Appendix A20. Anyone with a modicum of local knowledge would know that the information presented is seriously flawed. It appears that most of the large housing developments currently under construction in the vicinity of A274 Sutton Road are not expected to generate any traffic on Willington Street or Church Road. Page 2 of 29 2.13 The flows entering the southern end of Willington Street and heading for the new Marks and Spencer store at Eclipse Park, which opened on 12 August 2020, are shown as 304 (AM Peak) and 282 (PM Peak). There is no indication of the route taken by half of this traffic as the totals reaching the junction with Deringwood Drive are 151.5 and 141 respectively – the rest just disappears. Traffic heading to the Medical Campus, and the new Science and Technology (S&T) School and TV Studios in New Cut Road is similarly subject to apparently random "halving" at an undefined point along Willington Street. 2.14 Nonetheless, it is curious to note that according to the information submitted for its Planning Approval, the Marks and Spencer car park has a capacity of 282 spaces. It would be a remarkable retail establishment that was able to attract such high volumes of traffic during peak periods. 2.15 Equally implausible is the vast majority of additional evening peak traffic on Church Road which is supposed to be heading for either Barty Farm or Woodcut Farm – the confusion has already been highlighted. If it is the former, the flow of 51 vehicles would be exceptional as the development only consists of 100 houses and many other routes to it exist. If it is the latter, the note on the drawing shows an inbound flow to that development of only 21 vehicles. On further examination, the total PM peak flow heading eastbound on Ashford Road, east of Spot Lane associated with this development is shown to be 100 vehicles. It appears once again that no one has been charged with checking the quality of the information that has been submitted.