Bloor Homes Western
APPEAL REF: APP/W1850/W/20/3244410
Land North of Viaduct, Adj Orchard Business Park, Ledbury
Proof of Evidence of Nigel Millington BA (Hons) MSc MRTPI MCIHT
May 2020
PJA Project Code: 03468
PJA Seven House High Street Longbridge Birmingham B31 2UQ pja.co.uk
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APPEAL REF: APP/W1850/W/20/3244410
Version Control and Approval
Version Date Main Contributor Issued by Approved by A 06 March 2020 Nigel Millington Nigel Millington Nigel Millington B 20 March 2020 Nigel Millington Nigel Millington Nigel Millington C 15 May 2020 Nigel Millington Nigel Millington Nigel Millington D 27 May 2020 Nigel Millington Nigel Millington Nigel Millington
Bloor Homes Western Proof of Evidence of Nigel Millington
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APPEAL REF: APP/W1850/W/20/3244410
Contents
Section Page
1 Introduction ...... 1 1.1 Qualifications and Experience 1 1.2 Background Information 1 1.3 Statement of Matters 2 1.4 Format of the Proof 4
2 Evolution of the Proposals – Policy Requirements relating to Access ...... 5 2.1 Context 5 2.2 Historic Planning Policies 5 2.3 Herefordshire Core Strategy (2015) 6 2.4 Ledbury Neighbourhood Development Plan (NDP) 2018-2013 9 2.5 Summary of Policy Requirements relating to Access 10
3 Evolution of the Proposals – Transport Assessment and Travel Plan ...... 11 3.1 Context 11 3.2 Transport Assessment 11 3.3 Travel Plan 13
4 Consideration of a Second Access ...... 15 4.1 Context 15 4.2 Environmental Impact Assessment 15 4.3 Viaduct Access 16 4.4 Summary 18
5 Hereford Road (A438) / Bromyard Road (B4214) Junction ...... 19 5.1 Principal Issues 19 5.2 Discrepancies in Junction Capacity 19 5.3 Additional Growth 20 5.4 Intervisibility 21 5.5 Implications of a Second Point of Access 22
6 Knapp Lane and Cut Throat Lane ...... 23 6.1 Principal Issues 23 6.2 Knapp Lane / The Homend 23 6.3 Knapp Lane 24
Bloor Homes Western Proof of Evidence of Nigel Millington
6.4 Cut Throat Lane / A449 25 6.5 Implications of Second Point of Access 26
7 Rhea Lane ...... 27 7.1 Principal Issues 27 7.2 Policy Context 27 7.3 Alternative Routes 27
8 Provision of a Single Site Access ...... 30 8.1 Principal Issues 30 8.2 Quantum of Development 30 8.3 Ledbury Bypass 32
9 Signalised Layout of the Bromyard Road / Hereford Road Junction ...... 33 9.1 Principal Issues 33 9.2 Operating Capacity 33 9.3 Safety 34
10 Rat-Running Along Local Lanes ...... 35 10.1 Principal Issues 35 10.2 Distribution of Development Traffic 35 10.3 Knapp Lane / Cut Throat Lane 35 10.4 Traffic from the North 35 10.5 Closure of Bromyard Road 36
11 Local Residents’ Concerns ...... 37
12 Policy Assessment ...... 39 12.1 Relevant Policy Framework 39 12.2 National Planning Policy Framework 39 12.3 Herefordshire Local Plan Core Strategy 39 12.4 Highways Design Guide for New Developments 40
13 Summary and Conclusion ...... 41 13.1 Summary 41 13.2 Conclusion 42
APPEAL REF: APP/W1850/W/20/3244410
Appendices
Appendix A Plan of the Local Road Network ...... 43
Appendix B Traffic Data relating to the CA and AONB ...... 44
Appendix C Viaduct Access Options ...... 45
Appendix D Letter from BWB ...... 46
Appendix E Technical Note – Junction Intervisibility ...... 47
Appendix F Technical Note – Knapp Lane / Cut Throat Lane ...... 48
Bloor Homes Western Proof of Evidence of Nigel Millington
Introduction
1 Introduction
1.1 Qualifications and Experience
1.1.1 I am the Joint Managing Director of PJA, a consultancy specialising in the provision of transport planning, engineering and placemaking advice. I hold an Honours Degree in Geography and a Master’s Degree in Transport Planning. I am a Member of the Royal Town Planning Institute and a Member of the Chartered Institution of Highways and Transportation. I have over 22 years’ experience in the field of transport planning. The evidence which I have prepared and provide for this appeal reference APP/W1850/W/20/3244410 in this proof of evidence is true and I confirm that the opinions expressed are my true and professional opinions.
1.2 Background Information
1.2.1 As noted in the Statement of Common Ground with Herefordshire Council (HC) on Highways and Transport Matters (SoCGHT) [CD 4.2], the planning application to which this appeal relates was originally supported by technical transport and highways information prepared by another firm; BWB Consulting (BWB). Unfortunately, BWB and HC as Local Highway Authority (LHA) were unable to reach agreement on transport and highways matters and the LHA recommended refusal of the application. PJA was therefore instructed by Bloor Homes Western to review all the previous technical information, prepare revised proposals where necessary and resume negotiations with HC.
1.2.2 Following the submission of additional information and a period of additional negotiations, the LHA subsequently offered no objection to the planning application on highways grounds, as noted in the LHA’s consultation response on the application dated 10 May 2019 [CD 9.64] (p. 6, paragraph 2).
1.2.3 Despite receiving support from the LHA, planning permission was refused based on the reasons given in the Decision Notice [CD 13.1], which broadly relate to the following:
• Reason for Refusal 1 - Unsatisfactory vehicular access arrangements; • Reason for Refusal 2 - Impact on the Malvern Hills Area of Outstanding Natural Beauty (AONB) arising from additional traffic generation; and • Reason for Refusal 3 - Impact on the Ledbury Town Centre Conservation Area (CA) arising from additional traffic generation.
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Introduction
1.2.4 In addition to the reasons for refusal, ‘Informative 1’ referred to in the decision notice provides context for the planning authority’s stated reasons for refusing the application:
‘All of the above reasons for refusal are easily capable of being overcome by the applicant providing a second vehicular means of access off the Leadon Way (A417)/Hereford Road (A438) roundabout.’ [CD 13.1, p. 3, Informative 1]
1.2.5 This reference is helpful as it clarifies the LPA’s position on the proposed development, in that the provision of a second point of access would, in their mind, resolve all the concerns stated in the decision notice. It is therefore necessary as part of my evidence to identify those matters which might be resolved either in part or in whole by the provision of a second point of access, and those matters which would be common to both access scenarios and would therefore not be resolved by the addition of a second access.
1.2.6 Given the LPA’s stated preference for a second vehicular means of access, it is important to note the policy requirements in so far as access to this site is concerned. Policy LB2 of the Herefordshire Local Plan – Core Strategy 2011-2031 provides that policy context and notes the requirement for:
‘provision of satisfactory vehicular access arrangements, the details of which will be determined at the planning application stage’ [CD 1.3, Policy LB2]
1.2.7 There is therefore no explicit policy requirement for an access off the Leadon Way / Hereford Road roundabout, either as a primary or secondary access, and as noted in the Appellant’s Statement of Case [CD 5.1], the LPA’s Statement of Case [CD 5.2] and the SoCGHT [CD 4.2], the proposed vehicular access arrangements are considered to be satisfactory by all parties.
1.2.8 I have provided further information on the policy requirements relating to access and the transport assessment process in Section 2 of my proof. I have also included a plan of local road names referred to throughout my proof, in Appendix A.
1.3 Statement of Matters
1.3.1 The SoCGHT [CD 4.2] shows that there are no matters of disagreement between the LHA and the Appellant on highways and transport matters (para 2.1.4). Furthermore, that same document also confirms that there are no matters of disagreement between the LHA and the Appellant in respect of the Ledbury Town Council (LTC) objection (para 3.1.5). Whilst the LPA withdrew the Reasons for Refusal, LTC was subsequently granted Rule 6 status and has therefore submitted a Statement of Case (SoC) [CD 5.4], which must be addressed in my proof.
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Introduction
1.3.2 In relation to the LTC SoC, it is important to note the Town Council make it very clear in para 5.1.2 that their entire highways case is centred around the provision of a single point of access, noting that the access arrangements are not satisfactory because of the five reasons cited (listed in para 1.4.2 below), rather than these matters being unsatisfactory in their own right. This is further confirmed in para 5.1.11 of their SoC:
‘The Town Council will also demonstrate that the inadequacies identified above could be resolved through use of a second access to the site under the Ledbury Viaduct.’ [CD 5.4, para 5.1.11]
1.3.3 As is the case when addressing the reasons for refusal, it is therefore necessary to identify those matters within the LTC SoC which might be resolved either in part or in whole by the provision of a second point of access. It of course follows that any matters which would be common to both access scenarios and would therefore not be resolved by the addition of a second access, cannot logically form part of the Town Council’s case.
1.3.4 Whilst the LPA is not defending the reasons for refusal, it is necessary to address each of those reasons, in addition to the matters raised by LTC. The reasons for refusal, and the LTC SoC, both introduce new concerns which were not raised during the planning application process and were therefore not addressed in the supporting information submitted during the determination period.
1.3.5 Whilst a proof of evidence should not normally include new areas of evidence, it is unavoidable in this case given that the exchange of written proofs is the first opportunity to address the new areas of concern introduced in the reasons for refusal and the LTC SoC. This proof therefore contains a number of technical appendices which largely contain the new evidence, with the main body of the proof simply referring to the conclusions of that work.
1.3.6 This proof addresses the ‘Highways’ section of the LTC SoC plus Reason for Refusal 1; matters relating to vehicular access, whereas Reasons for Refusal 2 and 3 are addressed in separate proofs of evidence prepared by Mr Jackson and Mr Sutton respectively. In order to assist Mr Jackson and Mr Sutton in the preparation of their evidence, I have included in Appendix B to my proof additional traffic data relating to the Conservation Area and AONB.
1.3.7 Note that subsequent to the submission of the Town Council’s SoC, a Highways Statement of Common Ground (SoCGLTC - CD 4.5) was agreed between the Appellant and the Town Council. The SoCGLTC removes some of the matters raised in the SoC, considering them to now be agreed, therefore these matters are not addressed in this proof.
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1.4 Format of the Proof
1.4.1 In relation to the first reason for refusal, this is comprised of three separate elements as follows:
• Issues relating to the Hereford Road (A438) / Bromyard Road (B4214) junction; • Issues relating to Knapp Lane and Cut Throat Lane; and • Issues relating to Rhea Lane.
1.4.2 With regard to the LTC SoC, this raises the following outstanding concerns (which have not been agreed within the SoCGLTC):
• Provision of a single site access; • Signalised layout: operating capacity; • Signalised layout: safety; and • Increase in rat-running along local lanes.
1.4.3 The LTC SoC did raise concerns relating to emergency access and the proposed narrowing of the Hereford Road, although these matters are now agreed within the SoCGLTC.
1.4.4 My proof initially provides a review of policy requirements relating to access and the transport assessment, plus a consideration of the feasibility of providing a second point of access. I then consider Reason for Refusal 1 and the matters raised by LTC, some of which overlap with those in the reasons for refusal, followed by a review of concerns raised by local residents and then finally my assessment of the scheme against the relevant policy framework.
1.4.5 My proof therefore contains the following sections:
• Section 2 - Evolution of the Proposals – Policy Requirements relating to Access • Section 3 - Evolution of the Proposals – Transport Assessment and Travel Plan • Section 4 - Consideration of a Second Access • Section 5 - Hereford Road (A438) / Bromyard Road (B4214) Junction • Section 6 - Knapp Lane and Cut Throat Lane • Section 7 - Rhea Lane • Section 8 - Provision of a Single Site Access • Section 9 - Signalised Layout of the Bromyard Road / Hereford Road Junction • Section 10 - Rat-Running Along Local Lanes • Section 11 - Local Residents’ Concerns • Section 12 - Policy Assessment • Section 13 - Summary and Conclusions
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Evolution of the Proposals – Policy Requirements relating to Access
2 Evolution of the Proposals – Policy Requirements relating to Access
2.1 Context
2.1.1 As reported in the decision notice, the lack of a second point of access is the Council’s stated reason for refusing planning permission, noting that, in their view, all the reasons for refusal could be overcome by the provision of a second point of access off the Hereford Road / Leadon Way roundabout. Given that this issue is central to the Council’s case, it is important to examine in detail the policy requirement and evidence base in support of their position. This section of my proof therefore summarises the evolution of the policy position in relation to the access and considers the evidence available to support that position.
2.2 Historic Planning Policies
Herefordshire Unitary Development Plan (UDP) – 2007
2.2.1 The site was originally allocated for employment development in the Malvern Hills District Local Plan (MHDLP), covering the period 1986 to 2001, and was subsequently identified as employment land within the Herefordshire Unitary Development Plan (2007):
‘Release of the land is linked to major infrastructure investment, particularly in relation to roads. The land will be accessed by means of a northern extension to the Ledbury bypass, safeguarded by Policy T10. A development brief will be prepared to indicate requirements as to layout, landscaping, connections to the road system and the role of public transport. The route of the Herefordshire and Gloucestershire Canal, which passes the southern boundary of the proposal, needs to be respected, as do views through the railway viaduct (a Grade II listed building).’ [CD1.15, para 6.4.16]
2.2.2 The MHDLP originally safeguarded land for the Ledbury Bypass Extension and this was then reflected in Policy T10 of the UDP, noting that:
‘The bypass extension was seen as a means of providing a direct highway link to enable traffic from the north of the district and the existing Bromyard Road Industrial Estate to link into primary routes and the M50; removing heavy goods vehicles from the town centre, with consequent benefits for visual and environmental improvements; and facilitating the development of land proposed for employment development north of the railway viaduct. The proposal is indicated within the LTP as a possible measure which may come forward independently of the LTP process using private sector developer funding. The Local Plan employment land proposal is confirmed in this Plan and the necessary land to implement the access road continues to be safeguarded. The route of the Herefordshire and Gloucestershire Canal will need to be respected. The route passes beneath the Ledbury railway viaduct, a Grade
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Evolution of the Proposals – Policy Requirements relating to Access
II listed building, and liaison with the Environment Agency, Network Rail and landowners is required at an early stage.’ [CD 1.16, para 8.8.18]
2.2.3 It is clear that at the time the UDP was prepared, an access from the Hereford Road was envisaged in order to facilitate the planned employment development on the site and to provide a bypass function.
2.2.4 However, policy T10 of the UDP was extinguished when the Core Strategy was adopted in 2015. The land for the Ledbury Bypass Extension is therefore no longer safeguarded.
Strategic Housing Land Availability Assessment (SHLAA)
2.2.5 The SHLAA (2011) identified the site, noting that:
‘the whole of this land north of the viaduct is identified as future employment land within the UDP. To date this development has not proceeded. Its western boundary forms a bypass line. Access route under railway viaduct may be difficult to achieve with adequate protection for the viaduct and land ownership issues. Also route of Hereford & Gloucester Canal and bypass extension to Bromyard Road. Access via Bromyard Road possible, but would have to have ped/cycle link at least to south. This site could be re-designated for mainly housing with some expansion potential for existing companies to the east.’ [CD 1.34, p. 26]
2.2.6 The SHLAA introduces concerns regarding access under the viaduct and notes the potential for access from Bromyard Road, with pedestrian and cycle links to the south.
2.3 Herefordshire Core Strategy (2015)
Draft Core Strategy (2013)
2.3.1 The site is first allocated for mixed-use development under Policy LB2 of the Draft Core Strategy. With regard to access the policy requires:
‘Suitable vehicular access to the development from Bromyard Road to the north and/or the Hereford Road under the viaduct’ [CD 1.10, Policy LB2]
Core Strategy Pre-Submission Version (2014)
2.3.2 The next version of the Core Strategy refers to Hereford Road providing the primary access to the site with secondary access from Bromyard Road:
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Evolution of the Proposals – Policy Requirements relating to Access
‘primary vehicular access to the development will be from the Hereford Road under the viaduct with the option of a secondary access from the Bromyard Road to the north’ [CD 1.9, Policy LB2]
2.3.3 The Policy's explanatory text states that:
‘Vehicular, pedestrian, cycle and bus access to the housing site will primarily be under the viaduct with additional sustainable transport links to the north linking with the station. If required, the provision of a secondary vehicular access on to the Bromyard Road would also then enable the creation of a road link. A reduction in the speed limit along the Bromyard Road and improvements to the Hereford Road/Bromyard road junction are also likely to be required to improve the design, safety and efficiency of this road and junction. These and any other highway improvements will be informed by a traffic assessment.’ [CD 1.9, para 4.5.7]
Core Strategy Inspector's Report
2.3.4 The May 2014 pre-submission version of the Core Strategy was submitted for examination, with examination hearings taking place in February 2015 and the Inspector's report being released in September 2015.
2.3.5 The Inspector concluded that subject to Main Modifications, the Plan was capable of being made sound. With regard to access to the site and Policy LB2, the report stated that:
‘… For Ledbury SUE/UEA, the submission plan policy LB2 tied down the primary and secondary vehicular access to two specific roads. This was too prescriptive given the early transport studies for the site. MM025 deletes the primary and secondary references and I am satisfied that this would make the policy sound in that it would be more flexible and effective. Further minor changes to the wording of the policy in terms of access suggested by the Council following responses to the main modifications would not be necessary for soundness and it would be up to the Council to impose them if they wish.’ [CD 1.5, para 100]
Main Modifications (March 2015)
2.3.6 The Inspector's recommended Main Modifications were published and again consulted upon. With regard to Policy LB2 and the explanatory text, the following changes were made regarding access (MM026):
‘primary vehicular access to the development will be from either the Hereford Road under the viaduct with the option of a secondary access or from the Bromyard Road to the north’
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Evolution of the Proposals – Policy Requirements relating to Access
[CD 1.7, p. 35]
2.3.7 The reasons listed for this change were:
• To update the plan; and • To clarify the options for access arrangements and to allow greater flexibility for employment land location.
2.3.8 An additional change was subsequently made as follows:
‘Vehicular, pedestrian, cycle and bus access to the housing site will primarily be under the viaduct will need to be provided, with additional sustainable transport links to the north linking with the station. If required, the provision of a secondary vehicular access on to the Bromyard Road would also then enable the creation of a road link.’
2.3.9 The reason listed for this change was 'for clarification regarding access to the site'.
Minor Modifications (October 2015)
2.3.10 Following the release of the Inspector's Report and consultation on the Main Modifications, the Council published a set of Minor Modifications prior to the Plan's adoption.
2.3.11 The list included Minor Modifications in response to the consultation on the Main Modifications. Within these minor modifications the explicit references to both the Hereford Road and Bromyard Road accesses are removed and replaced with the adopted policy wording, which states:
‘provision of satisfactory vehicular access arrangements, the details of which will be determined at planning application stage……and will be considered as part of the Council's determination of planning applications submitted on the site" [CD 1.8, p. 57]
2.3.12 Access arrangements for the site were clearly considered in some detail during the preparation of the plan, both by the Council and also by the Inspector. The prescriptive approach initially sought by the Council was deemed to be inappropriate by the Inspector, with the Council then opting for wording which was even more flexible than that recommended by the Inspector.
2.3.13 What is abundantly clear is that the Inspector did not consider that two points of access were required, and a flexible approach was preferred as to where access should be taken from.
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Evolution of the Proposals – Policy Requirements relating to Access
2.4 Ledbury Neighbourhood Development Plan (NDP) 2018-2013
2.4.1 The NDP was adopted in 2018, and with regard to the development site states that:
‘The Herefordshire Core Strategy sets a minimum target of 800 new dwellings for the Ledbury parish, to be provided during the Plan period (2011-2031). The bulk of this allocation (625 dwellings) will be located to the north of the town, on what is known as the Viaduct site. This site was opposed by the Town Council and the community. The site was, however, allocated in the Core Strategy by Herefordshire Council regardless and approved at examination. The site is expected to deliver most of the housing that the town requires over the Plan period and there is no desire in the town for a quantum of development significantly greater than that proposed by the Core Strategy.’ [CD 1.11, p. 22]
4.1.2 The NDP does not make any comments regarding access to the proposed site and goes on to state that:
‘Maps 7, 8 and 9 show the Viaduct Site (identified in the Herefordshire Core Strategy for 625 dwellings), The Full Pitcher Site (planning permission for 100 dwellings) and Land South of Leadon Way (planning permission for 321 dwellings). These three sites together amount to commitments of over 1,000 homes which the LNDP supports. It is considered that these sites, in conjunction with the site allocated by the LNDP and windfall sites that will come forward within the settlement boundary, more than meet the needs of the town in terms of housing provision over the plan period.’ [CD 1.11, p. 24]
2.4.2 It should be noted that the NDP supports the allocations of the three sites listed, yet with no commentary on the access to this site. Furthermore, the Examiner’s Report on the NDP makes only minor wording changes, but these do not relate to access.
2.4.3 Whilst the Ledbury Neighbourhood Plan has been prepared in conformity with the adopted Herefordshire Core Strategy policy framework for the Ledbury Viaduct site, it could quite reasonably had expressed a preference for a future vehicular access under the Viaduct. However, the NDP expresses no such preference.
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Evolution of the Proposals – Policy Requirements relating to Access
2.5 Summary of Policy Requirements relating to Access
2.5.1 Whilst access from the Hereford Road was originally a policy aspiration in order to facilitate an employment development on the site, the position has shifted significantly over more recent years.
2.5.2 The SHLAA raised concerns regarding access under the viaduct and also identified the potential for access from Bromyard Road. The Core Strategy then considered access in some detail, resolving to adopt a flexible approach, with no prescriptive requirement either for a second access or an access from Hereford Road. Finally, the Neighbourhood Plan accepted the allocation of the site and did not make any comment on the access arrangements.
2.5.3 The policy position in relation to the site access is quite clear; a prescriptive approach including access from Hereford Road was dismissed by the Core Strategy Inspector, a flexible approach was adopted by the UDP and this was carried through to the Neighbourhood Plan; and there is no policy requirement for either a second access, or for an access from Hereford Road.
Proof of Evidence of Nigel Millington 10 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Evolution of the Proposals – Transport Assessment and Travel Plan
3 Evolution of the Proposals – Transport Assessment and Travel Plan
3.1 Context
3.1.1 As noted at the beginning of my evidence, the planning application to which this appeal relates was originally supported by technical transport and highways information prepared by BWB. Unfortunately, BWB and HC were unable to reach agreement on transport and highways matters and the LHA recommended refusal of the application. PJA was therefore instructed by Bloor Homes Western to review all the previous technical information, prepare revised proposals where necessary and resume negotiations with HC. To assist the Inquiry, I have therefore summarised in the sections below the conclusions from my firm’s work in relation to the Transport Assessment and Travel Plan.
3.2 Transport Assessment
3.2.1 Vehicle access to the site will be via a new roundabout with Bromyard Road. A separate access for emergency vehicles will be provided via Bromyard Road to the south of the roundabout. Pedestrian and cycle access to the site will be provided beneath the viaduct in two locations - to the north of the Hereford Road / Leadon Way roundabout and also via Ballard Close.
3.2.2 PJA has undertaken a systematic review of routes that pedestrians and cyclists could take from the site to access local facilities, employment and education opportunities, and of the existing infrastructure along those routes. In doing so, a number of barriers to sustainable travel were identified. In response to this PJA, has designed a comprehensive package of walking and cycling infrastructure to enable future residents to travel by sustainable modes:
• Two new toucan crossings on Hereford Road; • Signalisation of the Hereford Road / Bromyard Road junction to provide a further crossing; • A 3m shared footway / cycleway on Hereford Road to replace the existing footway; • Improvements to Ledbury Footpath ZB18 to provide a shared footway / cycleway and connect to the town trail; and • Connections from within the site to the northern part of the Bromyard Road Trading Estate.
3.2.3 An assessment was then undertaken based upon nationally recognised guidance which demonstrates that existing facilities within Ledbury can be accessed on foot and by cycle. It has further been demonstrated that Ledbury railway station offers opportunities to travel to regional employment destinations including Hereford and Worcester.
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Evolution of the Proposals – Transport Assessment and Travel Plan
3.2.4 Vehicular traffic generated by the development has been calculated using surveys from a database of similar sites. The capacity of the highway network has then been assessed based upon forecast traffic conditions for a horizon year of 2031, the end of the Herefordshire Core Strategy plan period. The assessment accounts for background traffic growth and committed developments in accordance with national planning policy and Department for Transport guidance.
3.2.5 It is acknowledged, and observed on-site, that there are existing safety, capacity, and operational issues at the Hereford Road / Bromyard Road / The Homend junction adjacent to Ledbury railway station:
• Long queues occur at the junction, particularly in the evening peak hour; • Heavy goods vehicles cannot safely negotiate the junction, with other vehicles having to wait back from the give-way line to allow larger vehicles through; • There are no facilities for pedestrians to safely cross; and
• There is a history of accidents.
3.2.6 It is proposed to improve the junction to provide traffic signals. Following a review of previous assessments, it has been identified that additional traffic capacity can be provided by installing an extra lane on Hereford Road. The scheme will offer a substantial benefit in terms of highway safety and pedestrian accessibility compared to the existing situation.
3.2.7 The capacity of the junction has been tested using modelling software, and the results indicate that in both the morning and evening peak hours, the junction would operate with reserve capacity. This means that any queues which may on occasion form on the approaches to the signals during the 'red' period, would clear during the 'green' period.
3.2.8 The design of the junction has been subject to an extensive Road Safety Audit by WSP, as advisors to Herefordshire Council. The proposed layout has then been further developed to demonstrate that it can be built and would deliver the required capacity even with additional traffic from the proposed and committed developments.
3.2.9 The signal junction will be easier and safer to negotiate for pedestrians and large vehicles than the existing priority junction.
3.2.10 The capacity of other junctions within Ledbury has also been tested for a forecast year of 2031. It has been demonstrated that the development would not result in severe impacts on queues and delays on other parts of the network.
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Evolution of the Proposals – Transport Assessment and Travel Plan
3.3 Travel Plan
3.3.1 The objective of the Travel Plan is to reduce the number of single occupancy car journeys to and from the site. This will be achieved using a package of measures to encourage sustainable travel, the success of which will be regularly monitored through travel surveys.
3.3.2 The Travel Plan will be managed by a Site Travel Plan Co-ordinator (STPC), which will be funded by Bloor Homes until one-year following full occupation of the residential element of the development. Following this, monitoring of the employment element of the development will pass to individual Travel Plan Co-ordinators for each occupier.
3.3.3 The Travel Plan measures can be divided into three categories; Physical, Informative, Financial.
Physical measures
3.3.4 A package of physical measures will encourage or enable sustainable travel, including:
• The package of off-site pedestrian and cycle improvements described within the Transport Assessment; • Providing high quality pedestrian and cycle routes throughout the development; and • Requiring future occupiers of the employment element of the development to provide cycle parking and welfare facilities. Informative
3.3.5 Residents of the development will be provided with a Welcome Pack to include:
• Maps of walking and cycling routes; • Public transport information; • Information on the benefits of sustainable travel; and • Promotion of national sustainable travel events.
3.3.6 Households will also be offered a Personalised Travel Planning (PTP) service by telephone consultation which will assist residents in travelling sustainably as part of their day-to-day journeys. Sustainable travel benefits will be reinforced by an annual newsletter.
3.3.7 Each occupier of the employment element of the development will be required to provide a Travel Information Pack to their employees and provide a sustainable travel noticeboard in a prominent location.
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Evolution of the Proposals – Transport Assessment and Travel Plan
Financial
3.3.8 Future residents of the development will be offered financial incentives to travel sustainably including:
• A voucher to reclaim a free three-month bus pass which can be used by all members of the household; and • A voucher redeemable against the purchase of an adult bicycle up to the value of £100 for each household.
3.3.9 Employers will be encouraged by the STPC to offer incentives for their employees to travel sustainably, including negotiating with local public transport operators to secure ticketing discounts and offering interest-free loans for the purchase of season tickets.
3.3.10 The success of the Travel Plan will be measured through a programme of regular monitoring and reporting to HC. This will include travel questionnaire surveys to residents and employees, and annual traffic surveys of the development.
3.3.11 The initial target of the travel plan is to reduce the trip generation of the development by 10% compared to that predicted in the Transport Assessment, although this will be reviewed following the baseline surveys.
3.3.12 It should be noted that the Transport Assessment does not account for a 10% reduction in traffic flows from the site and is therefore not reliant on the success of the Travel Plan.
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Consideration of a Second Access
4 Consideration of a Second Access
4.1 Context
4.1.1 Section 2 of my proof clearly demonstrates that there is no policy basis on which the LPA could require the provision of a second point of access; from Hereford Road or any other point on the local highway network. The Transport Assessment, and the additional evidence included within other sections of this proof, demonstrates that there are no technical transport related reasons why a second access should be provided.
4.1.2 However, there is some concern amongst local residents that the provision of a second access has not been considered. Notwithstanding the lack of a requirement and need for a second access, to assist the Inquiry, I have summarised below the work carried out as part of the Environmental Impact Assessment (EIA) process in relation to the consideration of alternative access scenarios. I also present new evidence to demonstrate what the technical considerations would be of providing an access under the viaduct.
4.2 Environmental Impact Assessment
4.2.1 As part of the EIA process, a ‘Transport’ chapter was prepared by PJA for the Environmental Statement (ES) [CD 18.9]. As requested in the Council’s Scoping Opinion, four alternative access options were assessed:
• Option 1 - Single vehicle access via B4214 Bromyard Road (as proposed in the planning application); • Option 2 - Single vehicle access from the Hereford Road (A417 / A438) roundabout; • Option 3 - Two vehicle accesses from Bromyard Road and Hereford Road, with a link road between; and • Option 4 - Two vehicle accesses from Bromyard Road and Hereford Road, but with no link road between. 4.2.2 The assessment demonstrated that none of the four access options considered would result in significant adverse environmental effects. All of the options would result in significant beneficial effects to Hereford Road on severance, pedestrian delay, pedestrian amenity and fear and intimidation. As noted in para 7.10.39 of the ES:
‘None of the alternative options considered would offer a significant betterment in terms of traffic related environmental effects.’
4.2.3 I therefore consider that alternative access options have in fact been assessed, and that the alternatives considered offer no significant betterment over that proposed in the planning application.
Bloor Homes Western 15 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Consideration of a Second Access
4.3 Viaduct Access
4.3.1 Despite the lack of any policy basis for the provision of a second point of access, and despite the assessment of alternatives in the Environmental Statement concluding that no significant betterment would be derived from the other access scenarios, I have given further consideration to the practical issues associated with the possible provision of an access beneath the railway viaduct.
4.3.2 I have considered this firstly in relation to the potential design options of such an access, secondly in relation the structural considerations associated with the railway viaduct, and thirdly in relation to the view of the owner of the structure; Network Rail.
Access Options
4.3.3 PJA has developed two vehicular access options from the A348 Hereford Road / Leadon Way Roundabout, as shown in Appendix C of my proof. Option 1 is a 5.5m wide single carriageway access road with a 3m shared footway/cycleway on the east side. The carriageway passes through a single viaduct arch of approximately 8.75m in width with the footway/cycleway deviating from the carriageway and passing through an adjacent arch. It is inevitable that physical protection to the viaduct would be required due to the risk of a vehicle collision that a road beneath it would present. The access road design therefore includes the provision of a crash barrier (Road Restraint System - RRS) for a distance of 30m on each approach to the viaduct.
4.3.4 The existing corridor is heavily vegetated and as such significant clearance of the mature vegetation would be required to facilitate the access. The access road is required to cross two ordinary watercourses, one located either side of the viaduct which would require culverting to maintain flows. In order to limit the extent of culverting, a bridge structure has been proposed to facilitate the footway/cycle crossing of the watercourse.
4.3.5 To the north of the viaduct, the access road would be required cross a 1,000 year overland flow route toward the river Leadon, and as such the access road would need to remain elevated with provision in the form of pipes or culverts to maintain this flow route.
4.3.6 The introduction of a vehicular access from the south in close proximity to existing residential dwellings will trigger the need for post-development noise to be considered, which could result in the requirement of noise barriers along the eastern edge of the road.
4.3.7 The existing access from the roundabout currently serves two private accesses to residential properties. The introduction of the access road from this roundabout would require these private means of access to be maintained and formalised into junctions onto the access road. These are in close proximity to the roundabout and would likely present a road safety concern due to the change in use and increased through-traffic along the access road.
Proof of Evidence of Nigel Millington 16 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Consideration of a Second Access
4.3.8 Option 2 follows a similar alignment to Option 1 but separates the northbound and southbound carriageways allowing them to pass through separate viaduct arches. This allows the total carriageway width through each arch to be narrower, thereby increasing the horizontal clearance to each arch face.
4.3.9 The same constraints as described for Option 1 also exist for Option 2, although the increased clearance to the arch face achieved is offset by the more onerous footprint of the access road in total. This option therefore has a greater impermeable area to drain with more onerous physical engineering in the form of the RRS, hard paving and more extensive watercourse culverting.
4.3.10 It is not my case that these physical constraints are incapable of being overcome, it is simply to note that the works required to deliver such an access road are significant, have additional related considerations, and it cannot automatically be assumed that these options are deliverable.
Structural Considerations
4.3.11 I am not a Civil or Structural Engineer and am therefore not qualified to give a view on the likely structural considerations associated with the construction and operation of a new road in such close proximity to a structure such as the railway viaduct in this case. I have therefore sought advice from Mr Andrew Wood, a Chartered Civil Engineer working for BWB Consulting in the role of Principal Engineer. Mr Wood has over 12 years’ experience in the field of bridge and highway design and his written advice is provided in Appendix D to my proof.
4.3.12 Mr Wood’s advice can be taken as read and warrants no further comment from me, other than to repeat his closing comments:
‘In summary, there are a large number of issues to be considered in developing a proposal to install a new public highway beneath an existing historic railway viaduct. This letter does not seek to confirm feasibility but it does highlight that at this stage it cannot be taken for granted – indeed it seems unlikely – that the permission of network rail would be granted.’
View of Network Rail
4.3.13 Notwithstanding the uncertainties associated with identifying an acceptable highway design for a new road beneath the viaduct, and the potential structural complexities associated with it, the view of the owner of the structure is of course a material consideration given the potential risks to health and safety.
4.3.14 Network Rail is the owner of the railway viaduct and therefore their view was sought on the likely acceptability to them of a public highway being installed beneath Ledbury Viaduct. Their response is available as CD 8.37. Note that this letter was available to the planning committee before the decision was made to refuse the application.
Bloor Homes Western 17 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Consideration of a Second Access
4.3.15 Their advice is very clear:
‘Having held conversations with NRIL’s Structures Asset Engineer we would not allow a public highway to be built beneath the structure as it would introduce undue risk to the railway.’
4.3.16 There is no ambiguity in their advice. There is no suggestion of any future assessment or qualification required which may lead them to a different conclusion. Network Rail will simply not allow a road to be built in this location.
4.4 Summary
4.4.1 My assessment of the possible provision of a second point of access beneath the viaduct can be summarised as follows:
• There is no policy requirement for the provision of a second point of access, either beneath the viaduct or elsewhere; • The EIA process did not identify any significant betterment associated with the alternative access options; • There are various highway design and structural considerations which would need to be resolved in order to identify if an access beneath the viaduct was even deliverable; and • The owner of the structure, Network Rail, would not allow the access to be bult in any event.
4.4.2 I therefore conclude that there is no evidence to suggest that the provision of a second access under the viaduct is required or deliverable.
Proof of Evidence of Nigel Millington 18 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Hereford Road (A438) / Bromyard Road (B4214) Junction
5 Hereford Road (A438) / Bromyard Road (B4214) Junction
5.1 Principal Issues
5.1.1 The principal issues relevant to this junction as cited in the first reason for refusal are as follows:
• Discrepancies in the reported capacity of the proposed junction between the proposals submitted by PJA and BWB; • The capacity of the proposed junction to accommodate additional growth to the north of Ledbury; and • The intervisibility provided between the stop lines.
5.1.2 Each of these matters is addressed in turn below.
5.2 Discrepancies in Junction Capacity
5.2.1 This aspect of the reason for refusal raises concerns over the reported capacity (referred to as ‘operating load’ in the decision notice) of the proposed signalised layout at this junction, noting that there are:
‘discrepancies in operating load between the two transport assessments provided by the developer for the same junction configuration’ (my underlining)
[CD 13.1]
5.2.2 However, this would be appear to be a simple misunderstanding on the part of the LPA. The Transport Assessment submitted by BWB included a signalised layout for this junction (as shown in Drawing No LUE-BWB-HML-XX-DR-D-114 S2 Rev P6 [CD 8.42]) which shows a single lane on the eastbound approach to the junction on Hereford Road. The Transport Assessment submitted by PJA also included a signalised layout for this junction (as shown in Drawing No 3468-A-010 Rev 5 [CD 8.45], but this clearly shows two lanes on the eastbound approach to the junction on Hereford Road.
5.2.3 The PJA signalised layout provides additional capacity through the introduction of a second lane on the eastbound approach to the junction. This therefore explains the differences in the reported capacity of the junction between the two transport assessments submitted by the developer. Rather than being a ‘discrepancy’, the PJA version simply provides improved operational performance over the previous version submitted by BWB.
5.2.4 With reference to the signal-controlled mitigation proposed by PJA, the committee report notes that:
Bloor Homes Western 19 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Hereford Road (A438) / Bromyard Road (B4214) Junction
The junction capacity analysis that has been carried out of the proposed signalised scheme has been thoroughly reviewed and will provide capacity improvements over what would happen in the future without the development at the site’ [CD 12.4, Section 4.8, ‘Traffic Impact’]
5.2.5 The committee report also notes that:
‘The operation of the proposed traffic signal scheme is considered acceptable.’ [CD 12.4, Section 4.8, ‘Traffic Impact’]
5.2.6 The same remarks are included within the SoCGHT [CD 4.2, Table 2-1, Matter No. 5, a].
5.2.7 I therefore do not consider this aspect of the reason for refusal to be valid.
5.3 Additional Growth
5.3.1 The reason for refusal raises concerns that the predicted capacity of the junction restricts any further growth to the north of Ledbury both within and beyond the current plan period.
5.3.2 The requirements for Transport Assessments to consider committed and planned development is set out in the relevant Planning Practice Guidance:
‘It is important to give appropriate consideration to the cumulative impacts arising from other committed development (ie development that is consented or allocated where there is a reasonable degree of certainty will proceed within the next 3 years). At the decision-taking stage this may require the developer to carry out an assessment of the impact of those adopted Local Plan allocations which have the potential to impact on the same sections of transport network as well as other relevant local sites benefitting from as yet unimplemented planning approval.’ [CD 1.27, ‘Travel Plans, Transport Assessments and Statements’, MHCLG, 6 March 2014, para 14]
5.3.3 The Transport Assessment submitted by PJA [CD 8.26, section 8.3] includes a summary of all committed development sites that were taken into account in the junction capacity modelling. There were no Local Plan sites considered to have the potential to impact on the same sections of the transport network, in accordance with the guidance. Note that there is no requirement in the guidance to consider any development beyond the current plan period.
5.3.4 In addition to the committed development sites, traffic growth assumptions were also applied in the Transport Assessment [CD 8.26, section 8.4] to cater for general background growth up to 2031.
Proof of Evidence of Nigel Millington 20 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Hereford Road (A438) / Bromyard Road (B4214) Junction
5.3.5 Assumptions relating to committed development and traffic growth were all agreed with the LHA, and the results of the latest junction modelling [CD 8.36, Appendix C, Tables 1 and 2] show that the junction is in fact predicted to operate with some spare capacity in 2031, even with the addition of committed development traffic and general background traffic growth.
5.3.6 I therefore do not consider this aspect of the reason for refusal to be valid. Note also that LTC have now agreed in the SoCGLTC that there is no requirement to consider growth beyond the current plan period.
5.4 Intervisibility
5.4.1 The reason for refusal raises a concern regarding the lack of intervisibility between the stop lines of the proposed signalised arrangement at this junction. Given the detailed nature of this issue, I have included as Appendix E to my proof a Technical Note which provides the necessary details.
5.4.2 The contents of that Technical Note can be summarised as follows:
• The existing junction is already congested, the layout presents a road safety issue particularly for pedestrians, and HGV movements to and from Bromyard Road cannot be safely accommodated; • The proposed design provides additional capacity to accommodate the proposed development and other planned growth, controlled pedestrian facilities are provided and HGVs can be safely accommodated; • Whilst full intervisibility is not provided, this is only a recommendation for upgrades to existing junctions. It is not a requirement of the relevant guidance; • In the unlikely event of the signals failing, the junction would revert to priority control, similar to the existing situation; • The calculated intergreen period between signal phases provides a safety margin in the event that any road users ‘jump the lights’; • A similar situation of limited intervisibility already exists in Ledbury at the Homend / Southend / Worcester Road / New Street junction. No accidents have been recorded at this junction in the last five years that relate to the lack of intervisibility; and • A similar junction improvement would be required even if a second point of access was provided, and therefore this issue would still prevail.
5.4.3 It should be noted that the proposed junction design has been subjected to a rigorous Road Safety Audit (RSA) process, which did not raise the lack of full intervisibility as a concern. The Stage 1 RSA Designer’s Response has been signed off with the LHA and includes the following comment issued by the LHA in relation to the restricted visibility northwards:
Bloor Homes Western 21 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Hereford Road (A438) / Bromyard Road (B4214) Junction
‘The bridge obscures pedestrian visibility partially to the north, but weighed against the existing situation and the introduction of a signalised facility this would demonstrate a betterment to the existing route to the station.’ [CD 8.31, Appendix A, Ref 16]
5.4.4 Consequently, I do not consider this aspect of the reason for refusal to be valid.
5.5 Implications of a Second Point of Access
5.5.1 The Council contends that all the concerns they have raised are easily capable of being overcome by providing a second point of access.
5.5.2 Given the existing capacity constraints at this junction, the unsatisfactory layout and the threat to pedestrian safety in particular, a junction improvement would be required at this location in any event, irrespective of the provision of a second point of access. Note that the ‘Ledbury Public Realm & Transportation Appraisal’ also identifies a requirement for an improvement to this junction [CD 1.19, Table 7-1, Ref 3].
5.5.3 If a second point of access under the viaduct were to be provided, additional traffic would still be generated through the Hereford Road / Bromyard Road junction, to the degree whereby an improvement scheme would still be required.
5.5.4 In addition, the provision of the second point of access would not reduce the level of additional pedestrian traffic through this junction, thereby necessitating a mitigation scheme in any case due to the lack of a controlled crossing across Bromyard Road to allow pedestrians to safely cross towards the rail station.
5.5.5 Given that a mitigation scheme would therefore be required in any event, and given the constraints at this location, it is unlikely that any other mitigation scheme which is materially different to that already proposed could in fact be provided.
Proof of Evidence of Nigel Millington 22 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Knapp Lane and Cut Throat Lane
6 Knapp Lane and Cut Throat Lane
6.1 Principal Issues
6.1.1 The principal issues relevant to this aspect of the first reason for refusal are as follows:
• The visibility available at the junction of Knapp Lane and The Homend;
• The lack of footways on Knapp Lane; and
• The forward visibility on the A449 southbound at its junction with Cut Throat Lane.
6.1.2 The Council considers that the deficiencies in design terms, as they see them, at these locations are prejudicial to highway safety. Each of these matters is addressed in turn below.
6.2 Knapp Lane / The Homend
6.2.1 Given the detailed nature of this issue, I have included as Appendix F to my proof a Technical Note which provides the necessary details.
6.2.2 The contents of that Technical Note relevant to this issue (Section 2) can be summarised as follows:
• A speed survey was undertaken to determine the recommended visibility splays; • The recommended visibility splays can be met from an ‘x’ distance of 2m; and • There have been no recorded collisions at this junction in the last five years.
6.2.3 With regard to the available visibility splay, an ‘x’ distance of 2.4m is normally used in most built- up situations, as this represents a reasonable maximum distance between the front of a car and the driver’s eye. In this case, the recommended visibility at an ‘x’ distance of 2.4m is obscured by the adjacent properties. However, Manual for Streets 2 (MfS2) notes that:
‘A minimum X distance of 2m may be considered in some slow-speed situations when flows on the minor arm are low, but using this value will mean that the front of some vehicles will protrude slightly into the running carriageway of the major arm, and many drivers will tend to cautiously nose out into traffic. The ability of drivers and cyclists to see this overhang from a reasonable distance, and to manoeuvre around it without undue difficulty, should be considered. This also applies in lightly-trafficked rural lanes.’ [CD 1.32, para 10.5.8]
6.2.4 I consider that an ‘x’ distance of 2m is reasonable in this case as both Knapp Lane and The Homend are relatively slow speed situations and the flows on Knapp Lane are low. I am also conscious that this is a situation which has existed for many years, and no accidents have been recorded at this location in the last five years.
Bloor Homes Western 23 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Knapp Lane and Cut Throat Lane
6.2.5 MfS2 provides further guidance on the implications of reduced visibility at priority junctions:
‘It has often been assumed that a failure to provide visibility at priority junctions in accordance with the values recommended in MfS1 or DMRB (as appropriate) will result in an increased risk of injury collisions. Research carried out by TMS Consultancy for MfS2 has found no evidence of this’ [CD 1.32, para 10.4.2]
6.2.6 Additional advice is also given in MfS2 when there are obstructions to visibility, such as buildings or parked cars:
‘At urban junctions where visibility is limited by buildings and parked cars, drivers of vehicles on the minor arm tend to nose out carefully until they can see oncoming traffic, and vice-versa.’ [CD 1.32, p. 80]
6.2.7 The increase in traffic on Knapp Lane as a consequence of the development is also predicted to be low. The Transport Assessment [CD 8.26, p.62, Table 10-5] shows that just 12 additional two-way trips are predicted to use Knapp Lane in the peak hours; this equates to an increase of just 5%.
6.2.8 Given the advice in MfS2, the local context, the lack of recorded accidents and the low levels of additional traffic predicted to use Knapp Lane, I conclude that the visibility at this junction is adequate.
6.3 Knapp Lane
6.3.1 The Technical Note in Appendix F to my proof also includes details (in Section 3) relevant to this issue, the contents of which can be summarised as follows:
• Following a review by the Council in 2010, traffic calming measures were installed on Knapp Lane; • Although there is no footway on Knapp Lane, there is sufficient width for a car and a pedestrian to pass; and • Pedestrians have been recorded as using Knapp Lane in the peak hours, yet no accidents have been recorded on Knapp Lane in the past five years involving a pedestrian.
6.3.2 As noted in para 6.2.7 above, just 12 additional two-way trips are predicted to use Knapp Lane in the peak hours. Given that no pedestrian accidents have been recorded on Knapp Lane and given the low levels of additional traffic predicted to use this route, I do not consider there to be an unacceptable risk to highway safety in this case.
Proof of Evidence of Nigel Millington 24 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Knapp Lane and Cut Throat Lane
6.4 Cut Throat Lane / A449
6.4.1 The Technical Note in Appendix F to my proof also includes details (in Section 4) relevant to this issue, the contents of which can be summarised as follows:
• Speed surveys have been carried out to inform the calculation of visibility splays and forward stopping sight distances; • Visibility splays can be provided from Cut Throat Lane which meet the ‘One step below desirable minimum’ standard from DMRB CD 109 Table 2.10; • Forward visibility to the Cut Throat Lane junction for vehicles travelling southbound on the A449 is below the recommended level; • However, only four accidents have been recorded at this junction in the past five years, and only one of which relates to vehicles travelling southbound on the A449; • The accident rate for this junction is typical for a junction of this type and traffic flow; and
• The increase in traffic at this junction as a result of the development is predicted to be only 15%.
6.4.2 The Council’s primary concern at this junction relates to the lack of forward visibility for vehicles travelling south on the A449. My evidence shows that the forward visibility is indeed lower than would be desirable based on DMRB, therefore I have considered what harm is arising from that existing situation. Note however that I consider the application of DMRB to be extremely robust in this situation.
6.4.3 The data shows that only one accident has occurred in the last five years which appears to be due, in part, to the lack of forward visibility, and that the total number of accidents occurring at this junction is not higher that would ordinarily be expected for a junction of this type. Having established that the existing situation is not creating a significant road safety issue, it is necessary to consider how this may change in the future ‘with development’ scenario. As noted above, the development traffic is predicted to increase junction flows by just 15%, only just beyond normal daily variation levels.
6.4.4 Given the lack of an existing road safety problem at this junction, and the modest increase in traffic flows expected as a result of the development, I do not consider that the development will give rise to an unacceptable impact on road safety in this location.
Bloor Homes Western 25 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Knapp Lane and Cut Throat Lane
6.5 Implications of Second Point of Access
6.5.1 As noted previously, the Council contends that all the concerns they have raised are easily capable of being overcome by providing a second point of access. However, the evidence in Section 5 of Appendix F to this proof shows that the Knapp Lane route is the shortest route available to the A449/Cut Throat Lane junction from both access points, and therefore the introduction of a second access would not reduce any impacts on Knapp Lane or Cut Throat Lane.
Proof of Evidence of Nigel Millington 26 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Rhea Lane
7 Rhea Lane
7.1 Principal Issues
7.1.1 In the final element of the first reason for refusal, the Council expresses concern that Rhea Lane would be unsuitable for use by development traffic in the event that Bromyard Road to the south of the proposed access becomes blocked for any reason.
7.1.2 Further concern is raised that Rhea Lane may be unavailable in any case due to flooding in the vicinity of Storesbrook, although no evidence to that effect has been provided by the Council at any time during the planning application and determination process.
7.2 Policy Context
7.2.1 Planning Practice Guidance issued on ‘Travel Plans, Transport Assessments and Statements’ notes that:
“In general, assessments should be based on normal traffic flow and usage conditions’ [CD1.27, Para 015]
7.2.2 The guidance is therefore clear that the potential transport impacts of new developments should be based on a ‘normal’ day, not on the basis of a rare event which may or may not happen, and certainly not in conjunction with a separate rare event which also may or may not happen.
7.2.3 The actual probability of Bromyard Road becoming completely impassable for any length of time is of course very low. Indeed, I am not aware of any reports having been received of this being a regular event at any point in the past. The combined probability of this occurring at precisely the same time that Rhea Lane is flooded to the degree that it is also impassable is exponentially lower, to the degree that I consider the probability to be negligible.
7.2.4 Notwithstanding the policy context and the extremely low probability of Bromyard Road becoming blocked, the availability of alternative routes to the north has been considered.
7.3 Alternative Routes
7.3.1 In the event that Bromyard Road was closed to the south of the proposed access, there would be a number of alternative routes available as shown in Figure 7-1 below.
Bloor Homes Western 27 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Rhea Lane
Figure 7-1: Routes available in the event of Bromyard Road closure
7.3.2 As shown above, Bromyard Road provides access to a number of alternative routes and each of these is summarised in Table 7-1 below.
Table 7-1: Alternative Routes Route Reference Route Name Description A Rhea Lane Narrow single-track road with few places for vehicles to pass. B Unnamed Narrow single-track road with few places for vehicles to pass. C Heywood Lane Narrow single-track road with few places for vehicles to pass. D A4103 High quality single carriageway. E B4220 Good quality single carriageway. F Burtons Lane Narrow single-track road with few places for vehicles to pass. G B4218 Single track road with a number of passing places. H Knapp Lane/Cut Throat Lane Single carriageway, narrowing to one lane in places.
Proof of Evidence of Nigel Millington 28 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Rhea Lane
7.3.3 Bromyard Road therefore provides access to eight other main through-routes north of the site, with other variants of these routes available. Some of these routes are acknowledged to be of a low quality, albeit they are all passable, but there are good standard connections to the wider road network via the A4103 and B4220.
7.3.4 Whilst the provision of a second point of access would reduce the reliance on Bromyard Road, given the extremely low probability of Bromyard Road being closed, the availability of other routes, and the policy context requiring normal conditions to be assessed, I consider there to be no unacceptable impact in relation to this issue.
Bloor Homes Western 29 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Provision of a Single Site Access
8 Provision of a Single Site Access
8.1 Principal Issues
8.1.1 The principal issue cited by the Town Council in their SoC in relation to the provision of a single site access is that it is contrary to Herefordshire Council’s ‘Highways Design Guide for New Developments’ (July 2006), specifically with reference to:
• The quantum of development served from the single access point; and • Safeguarding of the northern section of the Ledbury bypass. 8.2 Quantum of Development
8.2.1 The Town Council contends that the proposal for a single site access is not satisfactory by virtue of the fact that it will serve more than 300 dwellings, contrary to Herefordshire Council’s Highways Design Guide for New Developments (July 2006).
Herefordshire Design Guide
8.2.2 The Design Guide was published to aid designers in preparing transport infrastructure in relation to new developments. Note that the Council’s own website currently carries the following text on the relevant page:
‘users are advised to consult the national guidance document ‘Manual for Streets’ which has superseded parts of our publications’. [https://www.herefordshire.gov.uk/info/200196/roads/707/highway_development]
8.2.3 Section 2 of the Design Guide provides specifications for various categories of new roads, although it provides no technical justification for the thresholds and parameters it sets. There are two potentially relevant specifications:
• ‘Major Access Roads’: these can serve between 100 – 300 dwellings, or as a single point of access up to 200 dwellings plus an emergency access. • ‘Local Distributor Roads’: no specific limits to development are set, but a minimum of two accesses to the existing highway network are required.
8.2.4 It is acknowledged that the proposed site access road does not conform to either of these categories. However, as noted within the document:
‘The Design Guide stems from guidance set out in Design Bulletin 32: Residential Roads and Footpaths: Layout Considerations (DB32) and its companion guide Places, Streets and Movement.” [CD 1.52, Section 1.1]
Proof of Evidence of Nigel Millington 30 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Provision of a Single Site Access
8.2.5 Page 2 of DB32, the second edition of which was published nearly 30 years ago in 1992, defined ‘Access Roads’ as residential roads with footways that may serve up to around 300 dwellings and provide direct access to dwellings. This appears to be the basis for the restrictions within the Herefordshire Design Guide. However, the rigid application of this and other aspects of DB32, and locally published derivatives of it, resulted in highly undesirable street layouts consisting of a series of cul-de-sacs linked by distributor roads with little or no frontage activity.
8.2.6 Manual for Streets (MfS) was published in 2007 and MfS2 in 2010, both of which supersede DB32. These documents do not place restrictions on the number of dwellings served via a single point of access, with MfS noting that:
‘The length of cul-de-sacs or the number of dwellings have been used by local authorities as criteria for limiting the size of a development served by a single access route. Authorities have often argued that the larger the site, the more likely it is that a single access could be blocked for whatever reason. The fire services adopt a less numbers-driven approach and consider each application based on a risk assessment for the site, and response time requirements.’ [CD 1.51, para 6.7.3, third bullet]
8.2.7 The weight to be attached to superseded local design guides given the more recent publication of MfS and MfS2 is a matter that is regularly debated during appeal proceedings. The Inspector’s comments from a recent appeal decision (APP/T3725/W/18/3206423) which debated just this matter, in relation to the number of dwellings to be served from a single access, provides a useful summary of the situation. In this case, the Inspector is comparing a local design guide published by Warwickshire County Council in 2001 with the more recent MfS and MfS2:
‘Since 2001 both Manual for Streets (MfS) and Manual for Streets 2 (MfS2) have been published. The former of these was published in 2007 jointly by the Welsh Assembly Government, the then Department for Communities and Local Government and the Department for Transport. The latter by the Chartered Institution of Highways & Transportation in 2010. As these documents post-date the Warwickshire Guide I consider that more weight should be given to MfS and MfS2 as these flow from latest research and represent latest best practice. Neither of these documents indicates limits on the numbers of dwellings from single point of access.’ [CD 11.31, para 28]
8.2.8 Highway authorities have mostly now moved away from the significantly out of date guidance contained in DB32 and the various local guidance documents that were produced as derivatives of it. There is a general acceptance that relatively large amounts of development can be served from a single point of access providing that safety, capacity and environmental factors are considered appropriately.
Bloor Homes Western 31 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Provision of a Single Site Access
8.2.9 With regard to the appeal site, it has been demonstrated that the single point of access will operate well within capacity, no road safety issue have been identified through the Road Safety Audit process, and two arms into the site are provided from the access roundabout to allow some traffic movements to divert away from the principal street. In terms of environmental factors, given that the application is in outline and the masterplan is only illustrative, there are of course ample opportunities at more detailed design stages to consider the nature of any dwellings fronting the principal street, in terms of the set back from the carriageway, inclusion of street trees, specification of windows etc.
Herefordshire Council's Assessment of the Proposals
8.2.10 The Council as highway authority has accepted that a single point of access is an appropriate solution to access the site, in that this arrangement would comply with the relevant policies and guidance. This matter is specifically referred to within the planning committee report:
‘The highway authority considers that the applicant has provided satisfactory justification for this within the TA and also within the Technical Note - Response to HC comments version 5 dated 16/16/2019, within which it is confirmed that, and in the view of the highway authority, successfully demonstrated that: 1. The provision of a single point of access complies with the relevant policy guidance; 2. The development could be accessed by emergency vehicles or other road users should an accident or other event block the site access; 3. Providing a single point of access does not result in an unacceptable impact on the capacity of the highway network that could not be mitigated against; and 4. In highway capacity terms the proposed access arrangements can accommodate the anticipated level of traffic associated with the proposed development.’ [CD 12.3, p. 18]
8.2.11 This agreement is further reflected within the Statement of Common Ground between the Appellant and Highway Authority [CD 4.2 Table 2-1 Page 6].
8.3 Ledbury Bypass
8.3.1 It is now agreed in the SoCGLTC that there is no longer any safeguarded route for the northern section of the Ledbury Bypass.
Proof of Evidence of Nigel Millington 32 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Signalised Layout of the Bromyard Road / Hereford Road Junction
9 Signalised Layout of the Bromyard Road / Hereford Road Junction
9.1 Principal Issues
9.1.1 The principal issues cited by the Town Council in relation to the layout of the proposed signalised layout at the Bromyard Road / Hereford junction are in relation to operating capacity and safety. I have addressed each matter in turn below.
9.2 Operating Capacity
9.2.1 The Town Council’s criticisms of the proposed signalised layout in relation to operating capacity are as follows:
• The signalised layout is required because of the increased traffic through the junction; • There were discrepancies between the results of the operation of the junction submitted by BWB and PJA; • The impact of the proposed junction in conjunction with the other proposed signalised crossings has not been assessed; • The PJA modelling is flawed; and • The capacity of the junction restricts further growth of Ledbury to the north.
Need for the signalised layout
9.2.2 As noted elsewhere in my proof, there are existing road safety problems associated with the current layout at this junction, particularly in relation to pedestrian safety given the lack of a controlled crossing and the swept paths of large vehicles overrunning the footway. There are also existing capacity issues, particularly in relation to queues and delays forming on the Bromyard Road arm of the junction.
9.2.3 These issues are acknowledged in the Ledbury Public Realm & Transportation Appraisal, which itself identifies a requirement for an improvement to this junction [CD 1.19, Table 7-1, Ref 3]. The executive summary of that document notes that:
‘Ledbury Town Council is working in partnership with Herefordshire Council and Balfour Beatty Living Places to develop public realm and transportation improvements for Ledbury.’
9.2.4 Furthermore, with reference to this specific junction, the document notes that:
‘…junction capacity issues to be balanced against active travel users’ needs.’
[CD 1.19, Table 7-1, Ref 3]
Bloor Homes Western 33 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Signalised Layout of the Bromyard Road / Hereford Road Junction
9.2.5 It is clear that the Town Council was party to the preparation of that document, and that any improvement in this location should not focus solely on capacity, requiring the needs of active travel users to be considered. The Town Council’s current objection to the provision of an improvement in this location is therefore not consistent with their previously published position.
9.2.6 It is therefore the case that an improvement to this junction is required in any event. Whilst the proposed development and associated access proposal would indeed result in increased traffic volumes through this junction, there would still be increased traffic volumes through this junction if a second access were to be provided beneath the viaduct, and the existing issues relating to capacity and pedestrian safety would still prevail.
Discrepancies between junction capacity results
9.2.7 I have already dealt with this matter in Section 5.2 of my proof.
Operation of the junction in conjunction with other proposed crossings
9.2.8 It has been agreed with the Town Council’s highway witness, Mr Bradshaw, that there is no longer a requirement to consider the operation of the two proposed stand-alone toucan crossings on Hereford Road.
Flawed Modelling
9.2.9 No explanation is provided in the LTC SoC as to the precise nature of their criticism with regard to the modelling, therefore I am not able to address this matter at the time of preparing this proof. As noted in para 5.2.4 of my proof, the modelling was thoroughly reviewed by the highway authority and their consultants, and was considered to be acceptable.
Further Growth North of Ledbury
9.2.10 The SoCGLTC notes that it is now agreed there is no need to consider any additional growth beyond the current Core Strategy plan period.
9.3 Safety
9.3.1 The Town Council’s safety concerns in relation to this junction are associated with the intervisibility between stop lines. I have already dealt with this in Section 5.4 of my proof.
Proof of Evidence of Nigel Millington 34 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Rat-Running Along Local Lanes
10 Rat-Running Along Local Lanes
10.1 Principal Issues
10.1.1 In relation to ‘rat running’, the Town Council contends that:
• The assumptions in the Transport Assessment regarding the distribution of development traffic are flawed; • There are safety concerns associated with Knapp Land and Cut Throat Lane; • The modelling underestimates the level of traffic coming from the north that will seek alternative routes; and • Increased ‘rat running’ would occur if an emergency closed Bromyard Road.
10.1.2 I have addressed each matter in the following sections of my proof.
10.2 Distribution of Development Traffic
10.2.1 It is now agreed in the SoCGLTC that the distribution of traffic is acceptable.
10.3 Knapp Lane / Cut Throat Lane
10.3.1 Safety issues relating to Knapp Lane and Cut Throat Lane have already been addressed in Section 6 of my proof.
10.4 Traffic from the North
10.4.1 It is understood that the Town Council’s concern relating to traffic arriving into Ledbury from the north is that the proposed signalised junction will create delays of such a magnitude as to force drivers to seek alternative routes. It is therefore necessary to consider whether the level of delay incurred at the Hereford Road / Bromyard Road junction, in comparison to the existing situation, would encourage vehicles travelling towards Ledbury from the north to seek alternative routes to avoid the junction.
10.4.2 The proposed signalised junction is predicted to operate with reserve capacity in both peak hours and with calculated delays of 36 to 46 seconds per vehicle [CD 8.36, Appendix C, Tables 1 and 2] on the Bromyard Road arm of the junction, depending upon the forecast pedestrian crossing demand. Given the relatively low level of delay, and given the queues at the junction are predicted to clear each cycle, I do not consider that these absolute levels of delay would be sufficient for drivers to consider an alternative route into Ledbury.
Bloor Homes Western 35 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Rat-Running Along Local Lanes
10.4.3 It should also be noted that there is already a level of queueing and delay experienced by drivers on Bromyard Road, as demonstrated by the survey data. Any additional net delays would therefore be lower than the levels set out above, adding further justification to my conclusion that drivers from the north are unlikely to seek alternative routes.
10.5 Closure of Bromyard Road
10.5.1 I have already dealt with the potential closure of Bromyard Road in Section 7.2 of my proof. The Town Council’s witness has also now agreed that the assessment should be based on normal conditions.
Proof of Evidence of Nigel Millington 36 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Local Residents’ Concerns
11 Local Residents’ Concerns
11.1.1 Representations made by local residents on the planning application have been reviewed to identify any matters of concern additional to those raised in the reasons for refusal. A large number of representations were received by the LPA, many of which do not relate to my evidence and others which are already addressed in this proof. However, I have summarised in Table 11-1 those matters raised by local residents which are not addressed in this proof, and I have then provided a brief response to each item.
Table 11-1: Matters raised by local residents Matter Raised Response The proposed toucan crossings will create additional queues Very minor localised delays will be incurred when the toucan and delays. crossings are called. However, any disbenefits associated with these minor delays are significantly outweighed by the benefits to pedestrian and cyclist safety. No additional car parking is proposed in the town centre. Additional parking in the Town Centre was not identified as a requirement in the Ledbury Public Realm & Transportation Appraisal, no request for additional parking has been received from the highway authority, and the site is within walking and cycling distance of the Town Centre. The proposed pedestrian, cycle and junction improvements The conditions and any associated triggers will be discussed with should be implemented before development commences. the LPA prior to, and during the Inquiry.
Any development that serves to increase the risk to active The proposed improvements to pedestrian and cycle infrastructure, travel journeys would contravene the Council’s Climate together with additional S016 funding related to non-car modes, Emergency Policy. will decrease, not increase, the risk to active travel.
The trip assignment is disputed. The trip assignment has been agreed with the LHA, it was not a matter disputed by TPA on behalf of the Town Council, and it is now agreed in the SoCGLTC. The viability of the 675 bus service would be impacted if The proposed signalised improvement at the junction of Bromyard there are additional delays on Bromyard Road. Road with The Homend with not result in significant additional delays on Bromyard Road, and the development could result in an increase in patronage on the 675 service, therefore the impact on the viability of the service is likely to be positive. No additional parking is proposed at local schools. Additional parking at local schools was not identified as a requirement in the Ledbury Public Realm & Transportation Appraisal, no request for additional parking has been received from the highway authority, and the site is within walking and cycling distance of the local schools. Furthermore, the provision of additional parking would undermine attempts to discourage parents from using the car for school journeys. No additional parking is proposed at the rail station. Additional parking at the station was not identified as a requirement in the Ledbury Public Realm & Transportation Appraisal, no request for additional parking has been received from the highway authority, and the site is within walking and cycling distance of the local schools. However, funds could be made available from the S106 package to provide additional cycle parking at the station.
Bloor Homes Western 37 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Local Residents’ Concerns
11.1.2 I consider that the matters identified in the table above have been adequately addressed and do not give rise to any material concerns which would alter my assessment of the proposed development.
Proof of Evidence of Nigel Millington 38 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Policy Assessment
12 Policy Assessment
12.1 Relevant Policy Framework
12.1.1 The policies relevant to my proof are as stated in the decision notice and are as follows:
• National Planning Policy Framework (February 2019), Paragraphs 109 and 110; • Herefordshire Local Plan Core Strategy, adopted 16 October 2016, Policies SS1, SS4, LB2 (seventh bullet) and MT1; and • The provisions of Herefordshire Council’s ‘Highways Design Guide for New Developments’ (July 2006). 12.2 National Planning Policy Framework
12.2.1 In my professional opinion, the technical information provided in support of the planning application, and the additional evidence provided in my proof, all demonstrate that there will be no unacceptable impact on highway safety and that there will be no severe residual cumulative impacts on the road network. My assessment has shown that there are no existing road safety concerns which will be exacerbated by the proposed development, and that mitigation is provided to address localised junction capacity issues and to improve pedestrian and cycle safety. The detailed provisions of paragraph 110 of NPPF are also met by the proposals.
12.2.2 I therefore consider that the proposals are compliant with NPPF in transport terms.
12.3 Herefordshire Local Plan Core Strategy
12.3.1 In my professional opinion, the technical information provided in support of the planning application, and the additional evidence provided in my proof, all demonstrate that the development proposals are sustainable in transport terms. The site is within walking and cycling distance of both the Town Centre and the rail station, improvements are proposed to pedestrian and cycle facilities, and a comprehensive Travel Plan has been prepared. I therefore consider that the proposals are compliant with Policy SS1.
12.3.2 My evidence has demonstrated that the impacts on the transport network will be minimal, the highway network will continue to operate in a safe and efficient manner, the site is accessible and that mode choice has been facilitated. I therefore consider that the proposals are compliant with Policy SS4.
12.3.3 Much of my evidence has concentrated on the vehicular access arrangements, demonstrating that they are satisfactory, in so much as the access proposal is safe, efficient, policy compliant, deliverable and does not give rise to unacceptable impacts. I therefore consider that the proposals are compliant with Policy LB2 (seventh bullet).
Bloor Homes Western 39 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Policy Assessment
12.3.4 With regard to Policy MT1, each and every aspect of the policy requirements has been met as follows:
• Traffic impacts have been mitigated; • Non-car modes are promoted and incorporated into the design; • Active travel is encouraged through the Travel Plan; • Safe access is provided for all; • New connections have been provided to existing footways; and • The requirements of the Highways Development Design Guide and Local Transport Plan have been considered, noting however that the design guide is significantly out of date in many aspects. 12.3.5 I therefore consider that the proposals are compliant with Policy MT1.
12.4 Highways Design Guide for New Developments
12.4.1 This document was published in July 2006 and has subsequently been superseded by Manual for Streets 1 and 2, plus other publications. As noted in Section 8.2 of my proof, I therefore attach little weight to this document.
Proof of Evidence of Nigel Millington 40 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
13 Summary and Conclusion
13.1 Summary
13.1.1 This proof addresses the ‘Highways’ section of the LTC SoC plus Reason for Refusal 1; matters relating to vehicular access. The issues considered are as follows:
• Issues relating to the Hereford Road (A438) / Bromyard Road (B4214) junction; • Issues relating to Knapp Lane and Cut Throat Lane; • Issues relating to Rhea Lane;
• Provision of a Single site access; • Signalised layout: operating capacity; • Signalised layout: safety; and • Increase in rat-running along local lanes.
13.1.2 In relation to the Hereford Road / Bromyard Road junction I have demonstrated that:
• An improvement to the junction is required in any event to resolve existing capacity and pedestrian safety issues; • The capacity results presented for the proposed junction are correct; • There is sufficient capacity within the junction to accommodate both the proposed and other committed development; • The provision of full intervisibility is not a requirement and there are no significant road safety implications of not providing the full intervisibility; and • Even if a second access was to be provided, a similar junction improvement would be required in any event.
13.1.3 In relation to Knapp Lane and Cut Throat Lane I have demonstrated that:
• Adequate visibility is available at the junction of Knapp Lane with The Homend; • The lack of footways on Knapp Lane does not present an unacceptable risk to highway safety; • The lack of full forward visibility on the A449 southbound does not present an unacceptable risk to highway safety; and • The provision of a second point of access will not reduce any impacts on Knapp Lane or Cut Throat Lane.
Bloor Homes Western 41 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
13.1.4 In relation to Rhea Lane, I have demonstrated that;
• The potential transport impact of new developments should be based on a ‘normal’ day; • The probability of Bromyard Lane becoming impassable is very low, with the combined probability of this happening in conjunction with flooding on Rhea Lane being negligible; and • A range of alternative routes are available in the unlikely event of Bromyard Road becoming blocked.
13.1.5 In relation to the provision of a single site access, I have demonstrated that:
• There is no policy requirement for the provision of a second point of access, either beneath the viaduct or elsewhere; • There is no evidence to suggest that the provision of a second access under the viaduct is required or deliverable; • Little weight should be attached to the Herefordshire Design Guide; • The provision of a single site access complies with MfS and MfS2; and • The Council as highway authority has accepted that a single point of access is an appropriate solution to access the site.
13.1.6 In relation to rat-running along local lanes, and in addition to the concerns raised regarding Knapp Lane and Cut Throat Lane, I have demonstrated that drivers from the north are unlikely to seek alternative routes due to the introduction of traffic signals at the Bromyard Road / Hereford Road junction.
13.2 Conclusion
13.2.1 In conclusion, the proposed development is allocated in the Local Plan, received no objections from the local highway authority, was recommended for approval by the planning authority, the reasons for refusal have been withdrawn, the Council is now inviting the Inspector to allow the appeal, I have demonstrated that the first reason for refusal is invalid and that the matters raised by the Town Council do not have any material bearing on the assessment of the application.
13.2.2 Therefore, in my considered professional opinion, there are no highways or transport grounds on which to withhold planning permission.
Proof of Evidence of Nigel Millington 42 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix A Plan of the Local Road Network
Bloor Homes Western 43 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix B Traffic Data relating to the CA and AONB
Proof of Evidence of Nigel Millington 44 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix C Viaduct Access Options
Bloor Homes Western 45 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix D Letter from BWB
Proof of Evidence of Nigel Millington 46 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix E Technical Note – Junction Intervisibility
Bloor Homes Western 47 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix F Technical Note – Knapp Lane / Cut Throat Lane
Proof of Evidence of Nigel Millington 48 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix A Plan of the Local Road Network
Bloor Homes Western 43 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Summary and Conclusion
Appendix B Traffic Data relating to the CA and AONB
Proof of Evidence of Nigel Millington 44 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Technical Note
Project: APPEAL REF: APP/W1850/W/20/3244410
Subject: Additional traffic data relating to AONB and Conservation Area matters
Client: Bloor Homes Western Version: 2 Project No: 3468 Author: JW Date: 19/03/2020 Approved: NM
1 Introduction
1.1.1 This note provides a summary of traffic data for use in assessing the effects of the proposed development on the Area of Outstanding National Beauty (AONB) and Conservation Area (CA) in order to address Reasons for Refusal 1 and 2 in the decision notice.
1.1.2 Some of the data presented in this note is new information either gathered, or reported specifically to inform the Inquiry.
1.1.3 The development trip generation, distribution and assignment was agreed with the highway authority during the planning application and determination process and is summarised below.
2 Traffic Analysis
2.1 Trip Generation
2.1.1 The development vehicular trip generation during the peak hours was calculated using trip rates derived from suitable proxy sites within the TRICS database. This process is described in further detail within Section 5.2 of the Transport Assessment. The trip generation, which was agreed with the highway authority, is presented within Table 2-1.
LOCATION Seven House TELEPHONE 0121 475 0234 WEBSITE pja.co.uk High Street, Longbridge EMAIL [email protected] Birmingham B31 2UQ
Table 2-1: Vehicle Trip Generation
AM Peak Hour (08:00 - 09:00) PM Peak Hour (17:00 - 18:00) Land Use Parameter Arrivals Departures Two-Way Arrivals Departures Two-Way
Residential Sub-Total 625 Dwellings 75 243 318 234 123 357
Employment B1a 3,000m2 99 9 109 8 65 73
Employment B1b 1,800m2 15 2 17 1 10 10
Employment B1c 7,200m2 22 2 24 0 36 36
Employment Sub-total 12,000m2 136 13 150 9 111 119
Total (subject to rounding) 212 256 467 243 234 476
2.2 Trip Distribution
2.2.1 The development trip distribution is described within Section 5.3 of the Transport Assessment. The trip distribution is based upon Journey to Work data from the 2011 Census:
The workplace destination of respondents living in Ledbury and who travel to work by car (for the residential element of the of the development); and The place of residence of respondents who work in Ledbury and who travel to work by car (for the employment element of the development).
2.3 Trip Assignment
2.3.1 The trip assignment is detailed further within Section 5.3 of the TA and was agreed with the highway authority. Development trips were assigned to the network between the access and the origin / destination using the most appropriate routes (Table 2-2):
Table 2-2: Traffic Assignment (without Adjustments) Route Residential Trip Assignment Employment Trip Assignment 1 - Bromyard Road North 1.6% 3.6% 2 - Beggars Ash 3.5% 5.5% 3 - Worcester Road 27.1% 22.9% 4 - The Southend 10.2% 10.2% 5 - Leadon Way 38.5% 33.3% 6 - Hereford Road 19.1% 24.4% Totals (subject to rounding errors) 100.0% 100.0%
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2.3.2 In addition to the main routes, the assignment of traffic to some rural routes thought to be potential ‘rat runs’ by the highway authority was also considered within the Transport Assessment, as shown in Figure 2-1:
Figure 2-1: Rural routes considered within the Transport Assessment
2.3.3 The justification for the reassignment to each route is explained more fully within the Transport Assessment, but in summary:
10% of trips to Route 6 (A438 Hereford Road) were reassigned to Rhea Lane; 10% of trips to Route 3 (A449 Worcester Road) were reassigned to Knapp Lane; No trips were identified as being likely to use Burtons Lane; and The 3.5% and 5.5% of trips assigned to Beggar’s Ash were retained. 2.3.4 The development trip assignment with the adjustment for rural routes is presented within Table 2-3.
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2.3.5 Note that Burtons Lane was considered within the Transport Assessment. It was subsequentially identified that no development traffic would be likely to use that route, as it is a narrow single track route with few passing places, with Beggar’s Ash being a more suitable alternative route towards Wellington Heath. The route is therefore it is not represented in Table 2-3.
Table 2-3: Trip Assignment (with Rural Route Adjustments) Route Residential Trip Assignment Employment Trip Assignment Bromyard Road North 1.6% 3.6% Beggars Ash 3.5% 5.5% Knapp Lane 2.7% 2.3% Worcester Road 24.4% 20.6% The Southend 10.2% 10.2% Leadon Way 38.5% 33.3% Hereford Road 17.2% 22.0% Rhea Lane 1.9% 2.4% Totals (subject to rounding errors) 100.0% 100.0%
The agreed peak hour development trips on both the key routes and the rural routes are presented in Tables 2-4 and 2-5 for the residential and employment elements of the development respectively and in Table 2-6 for the entire site.
Table 2-4: Agreed Peak Hour Trip Assignment - Residential Trips AM Peak Hour PM Peak Hour Route Arrivals Departures Two-Way Arrivals Departures Two-Way Bromyard Road North 1 4 5 4 2 6 Beggars Ash 3 9 11 8 4 12 Knapp Lane 2 7 9 6 3 10 Worcester Road 18 59 78 57 30 87 The Southend 8 25 32 24 13 36 Leadon Way 29 94 122 90 47 137 Hereford Road 13 42 55 40 21 61 Rhea Lane 1 5 6 4 2 7 Totals 75 243 318 234 123 357 (subject to rounding)
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Table 2-5: Agreed Peak Hour Trip Assignment - Employment Trips AM Peak Hour PM Peak Hour Route Arrivals Departures Two-Way Arrivals Departures Two-Way Bromyard Road North 5 0 5 0 4 4 Beggars Ash 7 1 8 0 6 7 Knapp Lane 3 0 3 0 3 3 Worcester Road 28 3 31 2 23 25 The Southend 14 1 15 1 11 12 Leadon Way 45 4 50 3 37 40 Hereford Road 30 3 33 2 24 26 Rhea Lane 3 0 4 0 3 3 Totals 136 13 150 9 111 119 (subject to rounding)
Table 2-6: Agreed Peak Hour Trip Assignment AM Peak Hour PM Peak Hour Route Arrivals Departures Two-Way Arrivals Departures Two-Way Bromyard Road North 6 4 10 4 6 10 Beggars Ash 10 9 19 9 10 19 Knapp Lane 5 7 12 7 6 12 Worcester Road 46 62 108 59 53 112 The Southend 22 26 48 25 24 49 Leadon Way 74 98 172 93 84 177 Hereford Road 43 45 88 42 46 88 Rhea Lane 5 5 10 5 5 10 Totals 211 256 468 243 234 476 (subject to rounding)
3 Alternative Access Considerations
3.1.1 Notwithstanding the appellant’s position that an access beneath the viaduct cannot practicably be provided due to significant health and safety concerns, land ownership constraints and the expressed view of Network Rail, the following four access options were considered within the Traffic and Transport chapter of the Environmental Statement [PJA / Hunter Page Planning - 2018], as requested by Herefordshire Council through their Scoping Opinion (17th May 2017):
1 Single vehicular access via B4124 Bromyard Road (as proposed by the planning application); 2 Single vehicular access from the Hereford Road (A417 / A438) roundabout;
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3 Vehicular accesses from Bromyard Road and Hereford Road, with a link road between; and 4 Vehicular accesses from Bromyard Road and Hereford Road, with no link road between.
3.1.2 For each access option, traffic was assumed to assign to different routes on the highway network as follows:
Option 1 - All development traffic would route via the Bromyard Road access; Option 2 - All development traffic would route via the Hereford Road / Leadon Way roundabout; Option 3 - Traffic would route via the Hereford Road or Bromyard Road accesses dependent on their destination as follows: i. Trips to Bromyard Road or Beggars Ash would use the Bromyard Road access; ii. Trips towards Hereford Road or Leadon Way would use the Hereford Road access; and iii. Trips to The Homend, Worcester Road or the A417 south of Ledbury would be split between the two access points; and Option 4 - Traffic would split equally between the two access points.
3.1.3 Based on the assumptions outlined above, the proportional assignment of traffic to each route for each access option is presented in Tables 3-1 and 3-2 for the residential and employment parts of the site, and illustrated within Figures 3-1, 3-2, 3-3 and 3-4. These figures have not been disputed by the highway authority.
Table 3-1: Residential Trip Assignment by Access Option Residential Trip Assignment Route Option 1 Option 2 Option 3 Option 4 Bromyard Road North 1.6% 1.6% 1.6% 1.6% Beggars Ash 3.5% 3.5% 3.5% 3.5% Knapp Lane 2.7% 2.7% 2.7% 2.7% Worcester Road 24.4% 24.4% 24.4% 24.4% The Southend 10.2% 0.0% 5.1% 5.1% Leadon Way 38.5% 48.7% 43.6% 43.6% Hereford Road 17.2% 19.1% 19.1% 19.1% Rhea Lane 1.9% 0.0% 0.0% 0.0% Totals 100% 100% 100% 100% (subject to rounding)
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Table 3-2: Employment Trip Assignment by Access Option Employment Trip Assignment Route Option 1 Option 2 Option 3 Option 4 Bromyard Road North 3.6% 3.6% 3.6% 3.6% Beggars Ash 5.5% 5.5% 5.5% 5.5% Knapp Lane 2.3% 2.3% 2.3% 2.3% Worcester Road 20.6% 20.6% 20.6% 20.6% The Southend 10.2% 0.0% 5.1% 5.1% Leadon Way 33.3% 43.5% 38.4% 38.4% Hereford Road 22.0% 24.4% 24.4% 24.4% Rhea Lane 2.4% 0.0% 0.0% 0.0% Totals 100% 100% 100% 100% (subject to rounding)
Figure 3-1: Traffic Assignment Option 1 (Bromyard Road Access)
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Figure 3-2: Traffic Assignment Option 2 (Hereford Road Access Only)
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Figure 3-3: Traffic Assignment Option 3 (Both Accesses with Link Road Between)
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Figure 3-4: Traffic Assignment Option 4 (Both Access - No Link Road)
3.1.4 The resultant development trips on each route in the AM and PM peak hours are summarised in Tables 3-3 and 3-4.
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Table 3-3: Two-Way Development Trips - AM Peak Hour Total Two-Way Development Trips - AM Peak Hour Route Option 1 Option 2 Option 3 Option 4 Bromyard Road North 10 10 7 10 Beggars Ash 19 19 19 19 Knapp Lane 12 12 12 12 Worcester Road 108 108 114 108 The Southend 48 0 24 24 Leadon Way 172 220 204 196 Hereford Road 88 97 89 93 Rhea Lane 9 0 0 5 Totals 468 468 468 468 (subject to rounding)
Table 3-4: Two-Way Development Trips - PM Peak Hour Total Two-Way Development Trips - PM Peak Hour Route Option 1 Option 2 Option 3 Option 4 Bromyard Road North 10 10 8 10 Beggars Ash 19 19 19 19 Knapp Lane 12 12 12 12 Worcester Road 112 112 116 112 The Southend 49 0 24 25 Leadon Way 177 226 208 202 Hereford Road 87 97 91 92 Rhea Lane 9 0 0 5 Totals 476 476 476 476 (subject to rounding)
4 AONB Matters
4.1 Traffic impact through the AONB
4.1.1 A number of rural roads lead from the site through the Malvern Hills AONB, the most notable of which is Beggars Ash, which meets Bromyard Road at a junction approximately 700m south-east of the proposed site access (Figure 4-1).
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Figure 4-1: Beggars Ash route through the AONB
4.1.2 Beggars Ash continues into the village of Wellington Heath and then onwards to Colwall. The route does eventually continue to Malvern, although there are also alternative routes to Malvern both to the north and the south of the site access.
4.1.3 Whilst the decision notice does refer to Burtons Lane, this route is outside of the AONB. It was agreed with Herefordshire Council as part of the traffic assignment that development traffic is not likely to use this route, and is therefore it is not considered any further.
4.1.4 As shown in Tables 3-1 and 3-2, the Transport Assessment identified that 3.5% and 5.5% of residential and employment trips respectively would travel through Beggars Ash.
4.1.5 Traffic surveys at the junction of Beggars Ash and Bromyard Road were undertaken on 6th February 2020. The recorded peak hour traffic flows on Beggars Ash are compared to the predicted development traffic flows in Table 4-1.
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Table 4-1: Beggars Ash Traffic Impact Period Beggars Ash Existing Development Additional Percentage Impact Two-Way Traffic Flow Two-Way Vehicles 08:00 – 09:00 95 19 20% 17:00 – 18:00 84 19 23%
4.1.6 Table 4-1 demonstrates that Beggars Ash is currently lightly trafficked, with less than two vehicles per minute on average in each peak hour. Whilst the development will give rise to a 20-23% increase in traffic levels, in absolute terms this equates to just 19 vehicles per hour in the peak periods i.e. less than one vehicle every three minutes on average.
4.2 Implications of alternative access scenarios
4.2.1 Tables 3-3 and 3-4 demonstrate that the volume of development trips likely to use Beggars Ash through the AONB would be the same under each access scenario.
5 Conservation Area Matters
5.1.1 Figures 3-1 to 3-4 identify the routes that would pass through the CA for both the proposed access and the alternative access options that have been considered.
5.1.2 Trips from the proposed Bromyard Road access would pass through the CA for trips to A449 Worcester Road (towards Malvern) and for trips to the south of Ledbury (towards the M50).
5.1.3 From the suggested Hereford Road access beneath the viaduct, trips would still pass through the CA for trips towards Malvern, but for trips towards the M50 these are more likely to use the A417 Leadon Way bypass.
5.1.4 Figures 5-1 to 5-4 present the peak hour development trips on roads within the CA for each of the four access options.
13
Figure 5-1: Development Trips in CA - Option 1 (Bromyard Road Access)
14
Figure 5-2: Development Trips in CA - Option 2 (Hereford Road Access Only)
15
Figure 5-3: Development Trips in CA – Option 3 (Both Accesses with Link Road Between)
16
Figure 5-4: Development Trips in CA: Option 4 (Both Accesses - No Link Road)
5.1.5 Under each option, the highest number of development trips would be on The Homend, before splitting between Worcester Road and The Southend. Table 5-1 summarises the number of trips on The Homend under each option.
Table 5-1: Development trips on The Homend within Conservation Area Period Peak Hour Two-Way Development Trips – The Homend
Option 1 Option 2 Option 3 Option 4 (Bromyard Road (Viaduct Access Only) (Two Accesses - (Two Accesses - Access Only) Linked) Not Linked)
AM Peak Hour 156 108 138 132
PM Peak Hour 161 112 141 136
5.1.6 This exercise demonstrates that there would be a slight difference in the levels of development traffic through the Conservation Area depending on the access option selected.
17
5.1.7 When considering the Council’s stated preferred access scenario (Option 3), there would be just 18 fewer trips within the Conservation Area in the AM peak hour and 20 fewer trips in the PM peak hour, when compared to Option 1 as proposed in the planning application.
5.1.8 At present the two-way hourly flow on The Homend in the Conservation Area is 650 vehicles in the AM peak hour and 627 vehicles in the PM peak hour. A reduction of 20 trips would represent a reduction of just three percentage points in the level of impact through the Conservation Area.
18
Summary and Conclusion
Appendix C Viaduct Access Options
Bloor Homes Western 45 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
1:500 10 20 30 NOTES A1 These drawings have been produced with reference to the CDM Regulations 2015. Please note that these are pre-construction phase drawings and should be subject to Access Road intersects existing 1000 year further design risk management as required in accordance overland flow route to River Leadon. with Regulation 9
72.000 N Viaduct 1. All dimensions in metres unless stated E
W otherwise. S 2. The purpose of this drawing is to highlight potential constraints and risks associated with providing an alternative southern vehicular access to the site through the existing Ledbury Viaduct. Access ETLRoad to link to on site road network, which would require amending site 3. The access road alignment has been based on guidance from Manual for Streets with a masterplan. 30mph speed limit and Sight Stopping Distance of 43m. Requirement to culvert existing Ordinary 4. The tie-in to the existing A438 Roundabout Watercourse, proposed Finished Road Level has been designed in accordance with DMRB (FRL) assumes 900mmØ culvert with 1.2m CD116. cover, subject to hydraulic assessment. 5. The Access Road would be required to cross 2No. Ordinary Watercourses which have been used to determine the approximate Existing Viaduct carriageway level (FRL) under the viaduct (Indicative) based on culverting these with a 900mm 60.000 Likely footbridge structure over watercourse diameter pipe with 1.2m cover. This has to minimise length of culverting dictated the FRL in order to assess possible impact of the road on the viaduct piers and A MP 136.5 foundations. Permanent and Construction impacts on 6. The provision of a Road Restraint System has been shown as an N1W1 barrier with Extent of Planning Red Line Boundary pier foundations unknown. 600mm working width, based on DFT 6.000 5.500 3.000 Guidance “Provision of Road Restraint ≈ 0.900 Extent of Planning Red Line Boundary 0.600 0.500 Systems on Local Authority Roads”. This is shown indicatively and the provision and 54.04* 8.750 specification of RRS will be subject to a risk A assessment to be agreed with Network Rail as the Viaduct Asset Owner. 7. The carriageway construction depth has Canal width reduced to 6m been based on an assumed CBR of 2.5% Proposed carriageway Likely Road Restrain System (RRS) to protect requiring 360mm of sub-base and 260mm Proposed footway/cycleway between Viaduct Piers. Viaduct Piers. Assume N1 W1 barrier with P1 Assumed construction Pier foundation Assumed construction depth of 250mm capping for a Class 2 foundation in 50.100** terminals. Subject to RRS assessment which accordance with DMRB IAN 73/06. An 1.600 depth 820mm details unknown 50.000 would require agreement with Network Rail. assumed asphalt thickness of 200mm has been assumed to provide an overall Additional excavation if pavement depth of 820mm. ground conditions are poor Mill Wood 8. If site CBR values are below 2.5%, a further Based on suggested invert level, canal Likely structural * FRL calculated based on crossing of Ordinary HP Section A-A Viaduct piers require Watercourses, see note 5. 0.5-1.0m of existing material would need to be depth to be increased or adjacent forming of canal excavated and replaced. Not to scale ground lowered through Viaduct. beneath viaduct protection during excavation ** Canal Invert level obtained from BWB drawing and compaction of fill material LUE-BWB-EWE-XX-SK-EN-0004-S2-P1 9. Provision of an acoustic fence has been shown based on advice in BWB Noise Report (LUE-BWB- ENV-XX-RP-EN-0001 P3) that the impact on traffic noise would need to be Access road likely to have impact on assessed in accordance with DMRB canal subject to confirmation of canal HD213/11. and finished road levels, potentially 10. Provision for maintaining existing overland requiring retaining structure to flow routes as shown in BWB Flood Risk support the carriageway. Assessment report (LUE-BWB- EWE-XX-RP-EN-0001 P2) will require 30 consideration and likely elevation of the Requirement to culvert existing Ordinary access road. Watercourse, proposed Finished Road Level 11. The proposed Canal alignment has been (FRL) assumes 900mmØ culvert with 1.2m taken from Barton Willmore Illustrative cover, subject to hydraulic assessment. Masterplan (25634-9701 G) and amended in alignment to pass beneath the viaduct. The 24 width, cross section and invert level of the canal has been taken from BWB drawing LUE-BWB-EWE-XX-SK-EN-0004-S2-P1 and Significant loss of mature vegetation amended to pass beneath the viaduct. and Woodland Corridor with likely 12. The overall cross section of the access impact on ecological habitats.. road and canal is indicative and subject to a detailed and co-ordinated 3D design.
al Potential Acoustic Barrier to mitigate Key tial Can noise impact of the road on Saxon Way & Yeoman Close.
Poten
11 Planning Red Line Boundary 7 Road Restraint System
Acoustic Barrier
Junction Visibility (43m)
Indicative Earthworks
5 HP Access Road High Point 40 Access road likely to have impact on canal subject to confirmation of canal Viaduct Pier and finished road levels, potentially 2 New Mills requiring retaining structure to 1000 Year overland flow route support the carriageway. 8
3.000
5.500 6
A 438 Overland Flow amended, minor annotation P02 20/03/2020 SJG added YEOMAN CLOSE REV DATE REVISION NOTE BY
Seven House ú High Street
Longbridge ú Birmingham 16 B31 2UQ ú Tel: 0121 475 0234
River Leadon Birmingham ú Bristol Exeter ú London ú Reading pja.co.uk CLIENT Issues Bloor Homes
PROJECT
Likely road safety concerns over proximity of 1
1 Land North of Viaduct Private Means of Access to the Roundabout, 3 increase risk of rear end shunts exiting the 2 Ledbury roundabout onto new site access. Playground DRAWING TITLE
Likely road safety concerns over proximity of New Southern Vehicular Access HEREFORD ROAD Private Means of Access to the Roundabout, Tie in to A438 footway improvements Mills Option 1 Copyright © Phil Jones Associates Ltd / PJA Civil Engineering increase risk of rear end shunts exiting the (See PJA Drawing 03468-A-015-P1) MS roundabout onto new site access. 7.000 Constraints Issues DRAWING ISSUE STATUS INFORMATION PJA JOB No. SUB-CODE DRAWING NO. REVISION 03468- A- SK004 - P02 Revision Letter : P - Prelim / A - Approval / T - Tender / C - Construction BIM DRAWING REFERENCE
A438 SCALE DRAWN REVIEWED DATE A1@1:500 SJG RMB 12/03/2020
Leadon 1:500 10 20 30 NOTES A1 These drawings have been produced with reference to the CDM Regulations 2015. Please note that these are pre-construction phase drawings and should be subject to further design risk management as required in accordance with Regulation 9 Access Road intersects existing 1000 year N 1. All dimensions in metres unless stated 72.000 overland flow route to River Leadon. otherwise. E
W 2. The purpose of this drawing is to highlight
potential constraints and risks associated with Viaduct S providing an alternative southern vehicular access to the site through the existing Ledbury Viaduct. Access Road to link to on site road network, which would require amending site 3. The access road alignment has been based on guidance from Manual for Streets with a masterplan. 30mph speed limit and Sight Stopping ETL Distance of 43m. 4. The one way sections of carriageway beneath the viaduct have been proposed at 4.8m wide to allow for passing of a broken down vehicle. The overall length of this one-way section is dictated by the 30m of RRS approaching the structure. Requirement to culvert existing Ordinary Watercourse, proposed Finished Road Level 5. The tie-in to the existing A438 Roundabout Existing Viaduct has been designed in accordance with DMRB (FRL) assumes 900mmØ culvert with 1.2m CD116. (Indicative) cover, subject to hydraulic assessment. 6. The Access Road would be required to 60.000 cross 2No. Ordinary Watercourses which 2.750 have been used to determine the approximate carriageway level (FRL) under the viaduct 4.800 based on culverting these with a 900mm diameter pipe with 1.2m cover. This has A MP 136.5 dictated the FRL in order to assess possible Extent of Planning Red Line Boundary 6.000 4.800 4.800 3.000 Permanent and Construction impact on pier impact of the road on the viaduct piers and
≈1.350 ≈1.500 Extent of Planning Red Line Boundary foundations. 0.600 0.600 foundations unknown. 0.500 7. The provision of a Road Restraint System 54.04* 54.04* has been shown as an N1W1 barrier with 600mm working width, based on DFT Guidance “Provision of Road Restraint 8.750 Systems on Local Authority Roads”. This is 9.100 A shown indicatively and the provision and specification of RRS will be subject to a risk Proposed carriageway Proposed footway/cycleway Additional excavation Assumed construction assessment to be agreed with Network Rail Pier foundation Assumed construction if ground conditions as the Viaduct Asset Owner. 50.100** depth of 250mm Canal width reduced to 6m details unknown 1.600 depth 820mm Likely Road Restrain System (RRS) to protect are poor 4.800 8. This option provides increased clearance to 50.000 between Viaduct Piers. 2.750 Viaduct Piers. Assume N1 W1 barrier with P1 the structure from Option 1 which would allow terminals. Subject to RRS assessment which an increasing working width of up to 1.3m would require agreement with Network Rail. (W4) , if desired. Based on proposed invert level, canal Likely structural Viaduct piers require * FRL calculated based on crossing of Ordinary Section A-A 9. The carriageway construction depth has depth to be increased or adjacent forming of canal protection during excavation Watercourses, see note 6. been based on an assumed CBR of 2.5% Not to scale ground lowered through Viaduct. beneath viaduct and compaction of fill material **Mill Canal Invert Wood level obtained from BWB drawing HP requiring 360mm of sub-base and 260mm LUE-BWB-EWE-XX-SK-EN-0004-S2-P1 3.000 capping for a Class 2 foundation in HP accordance with DMRB IAN 73/06. An assumed asphalt thickness of 200mm has been assumed to provide an overall pavement depth of 820mm. 10. If site CBR values are below 2.5%, a Access road likely to have impact on further 0.5-1.0m of existing material would canal subject to confirmation of canal need to be excavated and replaced. and finished road levels, potentially 11. Provision of an acoustic fence has been requiring retaining structure to shown based on advice in BWB Noise Report support the carriageway. (LUE-BWB- ENV-XX-RP-EN-0001 P3) that the impact on traffic noise would need to be 30 assessed in accordance with DMRB Requirement to culvert existing Ordinary HD213/11. Watercourse, proposed Finished Road Level 12. Provision for maintaining existing overland (FRL) assumes 900mmØ culvert with 1.2m flow routes as shown in BWB Flood Risk cover, subject to hydraulic assessment. Assessment report (LUE-BWB- EWE-XX-RP-EN-0001 P2) will require 24 consideration and likely elevation of the access road. 13. The proposed Canal alignment has been Significant loss of mature vegetation taken from Barton Willmore Illustrative and Woodland Corridor with likely Masterplan (25634-9701 G) and amended in impact on ecological habitats.. alignment to pass beneath the viaduct. The width, cross section and invert level of the al canal has been taken from BWB drawing LUE-BWB-EWE-XX-SK-EN-0004-S2-P1 and Potential Acoustic Barrier to mitigate amended to pass beneath the viaduct. tial Can noise impact of the road on Saxon 14. The overall cross section of the access
Way & Yeoman Close. road and canal is indicative and subject to a
Poten detailed and co-ordinated 3D design.
11 7 Key
Planning Red Line Boundary
Road Restraint System
Acoustic Barrier
5 Junction Visibility (43m)
40 HP Access road likely to have impact on Access Road High Point canal subject to confirmation of canal and finished road levels, potentially Viaduct Pier New Mills requiring retaining structure to 2 support the carriageway. 8 1000 Year overland flow route
5.500 6 Overland Flow amended, minor annotation P02 20/03/2020 SJG added A 438 REV DATE REVISION NOTE BY Seven House ú High Street YEOMAN CLOSE Longbridge ú Birmingham B31 2UQ ú Tel: 0121 475 0234
Birmingham ú Bristol Exeter ú London ú Reading 16 pja.co.uk River Leadon CLIENT Bloor Homes Issues PROJECT Land North of Viaduct
Likely road safety concerns over proximity of 1 1 Ledbury Private Means of Access to the Roundabout, 3 increase risk of rear end shunts exiting the 2 roundabout onto new site access. DRAWING TITLE PlaygroundSouthern Vehicular Access Option 2 Copyright © Phil Jones Associates Ltd / PJA Civil Engineering Likely road safety concerns over proximity of New Private Means of Access to the Roundabout, Tie in to A438 footway improvements Constraints HEREFORD ROAD Mills DRAWING ISSUE STATUS increase risk of rear end shunts exiting the (See PJA Drawing 03468-A-015-P1) MS Issues roundabout onto new site access. 7.000 INFORMATION PJA JOB No. SUB-CODE DRAWING NO. REVISION 03468- A- SK005 - P02 Revision Letter : P - Prelim / A - Approval / T - Tender / C - Construction BIM DRAWING REFERENCE A438 SCALE DRAWN REVIEWED DATE A1@1:500 SJG RMB 12/03/2020
Summary and Conclusion
Appendix D Letter from BWB
Proof of Evidence of Nigel Millington 46 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Mike Edwards PJA Severn House High Street Longbridge Birmingham B31 2UQ
Our Ref: BMW2470/T&I_001 Contact: Andrew Wood Tel: 07392 090 970
Date: 31/03/2020
Dear Mike
STRUCTURAL CONSIDERATIONS FOR A HIGHWAY BENEATH LEDBURY VIADUCT ASSOCIATED WITH LAND NORTH OF VIADUCT, ADJ ORCHARD BUSINESS PARK, LEDBURY
I am a Chartered Civil Engineer working for BWB Consulting in the role of Principal Engineer. I have over 12 years’ experience in the field of bridge and highway design. I have been asked to provide advice in relation to structural considerations for a notional access road associated with Land North of Viaduct, Adj Orchard Business Park, Ledbury which would pass beneath a railway viaduct owned by Network Rail.
My advice at this stage is subject to a number of key limitations, most notably due to having not consulted with Network Rail’s Asset Protection team myself. Detailed consultation would be necessary in due course should the option to provide a road be progressed. The advice given herein is therefore general and is intended emphasise the various matters that would need to be considered and resolved to all parties’ satisfaction prior to any works taking place. The letter is not intended to confirm with any certainty the feasibility or otherwise of the works.
Reference has been made during preparation of this letter to two highway layout options for the southern vehicular access prepared by PJA; Option 1 (03468-A-SK004-P01) and Option 2 (03468-A-SK005-P01). In brief summary the proposals are for new highway and associated non-motorised user routes to be carried beneath two arches of the railway viaduct. The level of the highway will be slightly elevated above existing ground level due to flood risk considerations. A future canal corridor is also indicated on those drawings passing through a third viaduct arch. This canal is not in the scope of this letter although many of the issues discussed would be applicable.
When considering the provision of new highway infrastructure in the vicinity of existing structural assets there are a number of considerations that must be made, including but not limited to the following items which are briefly discussed.
Livery Place, 35 Livery Street, Birmingham, B3 2PB
Tel: 0121 233 3322
www.bwbconsulting.com
Registered office address: 5th Floor, Waterfront House, 35 Station Street, Nottingham NG2 3DQ Registered in England an d Wales Company No. 5265863
CONSULTANCY | ENVIRONMENT | INFRASTRUCTURE | BUILDINGS
Asset protection arrangements would need to be put in place including appropriate contractual agreements, most likely in the form of a Network Rail Basic Asset Protection Agreement (BAPA). This would place obligations on the proposer of the works to ensure the safety and serviceability of the Network Rail asset. Generally any permissions, consents or approvals for physical works would be via Network Rail’s local Asset Protection team whereas other parts of Network Rail would deal with matters related to legal, commercial, land, conservation and planning, etc.
Effect of temporary works including investigations, excavations and construction loading on the safety and serviceability of the existing asset. Network Rail’s Asset Protection team will need to approve any temporary works including excavations in the vicinity of the viaduct. In my experience Network Rail generally defines any land within 3m of the base of a structure foundation as the ‘support zone’, and permission is required to undertake any works that either impose a load on or penetrate that support zone. Given the geometry of the viaduct it is highly likely that the entire area between the piers would be considered the support zone.
Where Network Rail permission is required it can be assumed that the Outside Party will be expected to demonstrate to them that the works will be acceptable. This would typically be by demonstrating compliance with relevant standards and undertaking any necessary calculations and analyses. It is highlighted that the assessment of safety and load capacity of historic structures such as Ledbury Viaduct in their unaltered form is often based on empirical methods, monitoring, observation and judgement (taking into account condition factors) as much as it is on detailed calculations. It can therefore be very difficult to ‘prove’ that any future scenario would be acceptable. A risk-based approach would likely be necessary and at this stage it is not possible to confirm whether works would be acceptable to Network Rail. Although risks can be mitigated through careful planning and control, it is unlikely that any temporary works within the support zone would be considered as offering zero additional risk.
Effect of permanent works including permanent additional loading from earthworks, vehicular live loading and surface water drainage on the safety, serviceability and durability of the existing asset. The same considerations described for temporary works above would apply with the additional requirement to consider longer-term impact of vehicle loading including dynamic effects. Additionally if the ground level is raised permanently then the effect of burying previously exposed structural elements would need to be considered and approved by Network Rail.
Given the sensitivity of such a historical structure, my professional experience of Network Rail’s reasonably risk-averse approach to ensuring the safety of their assets and the potential for harm arising from a failure of the structure I consider that the likelihood of obtaining the necessary approvals and consents from Network Rail to be low.
Operational impact on the asset owner’s ability to maintain and inspect their asset. Network Rail will have an asset management regime which will include periodic inspection and maintenance. This is likely to include established wayleaves or similar to enable access over third party land as necessary. Currently access to the viaduct is relatively unhindered and the introduction of a highway would require implementation of traffic management or road closures for inspection and maintenance. The additional constraints to Network Rail’s operations are unlikely to be acceptable to them.
Page 2 of 3
Possibility of accidental loading including collision impact from errant vehicles. It is likely that this could be mitigated by an appropriately specified vehicle restraint system.
Issues related to the existing asset being brought into the public realm with increased footfall including consideration of safety, security, trespass and vandalism, all of which are potential sources of additional risk to the safety and durability of Network Rail’s asset.
Operational limitations on the highway adopting authority that the existing asset may present for future maintenance, especially any that would affect the ability of the adopting authority to adopt the highway.
Any impact on heritage and conservation value of the existing asset. The viaduct is Grade II listed; such status would not typically preclude changes although agreement would need to be reached with the relevant authorities to ensure that works do not damage the heritage and conservation value and that any opportunities for enhancement are exploited.
Matters related to land ownership, easements, wayleaves, party wall, air rights etc. Although not in the scope of this letter, it is highlighted that such matters may have significant influence on the development of any proposals for temporary and permanent works. Such matters would be subject to negotiation and it is not possible at this stage to predict whether there would be a significant impact.
Ecological considerations especially potential bat roosts or corridors for wildlife which often exist within old brick and masonry structures. This would need to be given further consideration due to the legally protected status of bats.
Matters related to the general safety of the operational railway such as lighting including vehicle lights which can affect signal sighting, and boundary treatments.
In summary, there are a large number of issues to be considered in developing a proposal to install a new public highway beneath an existing historic railway viaduct. This letter does not seek to confirm feasibility but it does highlight that at this stage it cannot be taken for granted – indeed it seems unlikely – that the permission of network rail would be granted.
Yours sincerely
Andrew Wood MEng(Hons) CEng MICE Principal Engineer, BWB Consulting
Page 3 of 3
Summary and Conclusion
Appendix E Technical Note – Junction Intervisibility
Bloor Homes Western 47 Proof of Evidence of Nigel Millington APPEAL REF: APP/W1850/W/20/3244410
Technical Note
Project: APPEAL REF: APP/W1850/W/20/3244410
Subject: Technical Appendix - Signal Junction Design Bromyard Road / Hereford Road / The Homend
Client: Bloor Homes Western Version: 1 Project No: 3468 Author: JW Date: 03/03/2020 Approved: NM 1 Introduction
1.1.1 This note has been prepared to address in detail the third bullet point of the Council’s first Reason for Refusal:
‘There would not be clear intervisibility between the stop lines of the proposed signalised arrangement at the junction of the Hereford Road (A438) and Bromyard Road (B4124), as clearly annotated on drawing number 010-PA prepared by PJA, would present a hazard to highway safety in the event of the signals failing or drivers of motor vehicles or non- motorised vehicles ‘jumping the lights’
1.1.2 This note addresses the following matters:
The safety, operational and capacity issues at the existing junction; The design features of the proposed signal junction; The references to intervisibility within the relevant standards and guidance; Assessment of the Council’s Reason for Refusal and the implications for highway safety; Consideration of relevant local examples where there are obstructions to intervisibility; and The potential implications of alternative means of access as suggested by the Council.
2 Existing Junction
2.1.1 In assessing the acceptability of the proposed junction design, it is necessary to consider the status of the existing junction. As set out within Section 3.4 of the Transport Assessment:
LOCATION Seven House TELEPHONE 0121 475 0234 WEBSITE pja.co.uk High Street, Longbridge EMAIL [email protected] Birmingham B31 2UQ
The junction is already congested, particularly in the PM peak hour when long queues form on Bromyard Road; The junction cannot safely accommodate HGV movements to/from the Bromyard Road Trading Estate. Vehicles waiting on Bromyard Road must wait approximately 20m back from the give-way line to allow HGVs to turn left towards the Trading Estate (evidenced by drawings within Appendix A of this note); There are limited facilities for pedestrians crossing Bromyard Road, with only a dropped kerb crossing and tactile paving being provided. There is poor visibility of and for those persons crossing west to east as the view is restricted by the railway bridge. Pedestrians are often forced to walk between vehicles queuing at the junction, meaning their view of oncoming traffic is restricted, as is the view of them by the oncoming traffic; Two serious collisions have occurred at the junction; and Large vehicles often overrun the footway at the corner of Hereford Road and Bromyard Road, and this is evidenced by the condition of the footway in this area. This presents a serious safety risk to pedestrians waiting to cross in this location. 3 Proposed Design
Design Summary
3.1.1 It is proposed to convert the existing junction of Bromyard Road / Hereford Road / The Homend from priority control to traffic signal control. The proposed scheme would offer the following benefits compared to the existing situation:
By holding vehicles at the proposed stop lines, heavy goods vehicles can safety manoeuvre through the junction without conflicting with other waiting vehicles and without overrunning the footway; The provision of a controlled crossing facility will allow non-motorised users to safely cross the road; A widened footway on the eastern side of the road between the junction and railway station provides additional space for pedestrians either waiting to cross or walking to and from the railway station; and Additional capacity is provided to accommodate the proposed development, other committed developments and background traffic growth.
2
4 Intervisibility Requirements
Relevant Guidance
4.1.1 The provision of intervisibility between stop lines is referred to within the Design Manual for Roads and Bridges (DMRB) document ‘CD 123 Geometric design of at-grade priority and signal- controlled junctions’ (January 2020). The guidance replaced that within DMRB TD 50/04 which has previously been referred to.
4.1.2 DMRB provides requirements and advice relating to works on the motorway and trunk road network for use when Highways England is the Highway Authority. DMRB is not a mandatory requirement for roads managed by other Local Highway Authorities, in this case Herefordshire Council, although it is often used as a guidance document in some situations.
4.1.3 DMRB uses modal verbs which are defined in ‘GG101 Introduction to the Design Manual for Roads and Bridges’ as follows:
The verb ‘must’ indicates a statutory or legislative requirement; The verb ‘shall’ indicates a requirement of the Overseeing Organisation (Highways England); The verb ‘should’ indicates advice expressed as a recommendation; and The verb ‘may’ indicates advice expressed as a permissible approach.
4.1.4 Further advice is provided within the Department for Transport’s ‘Traffic Signs Manual – Chapter 6 Traffic Control’. The manual offers advice to highway authorities when designing traffic signal junctions and crossings on roads with a speed limit of 40mph and under, particularly in urban areas. The manual was published in December 2019 and supersedes several other guidance documents, including Traffic Advisory Leaflet 1/06 which has previously been referred to.
4.1.5 The relevant aspects of each of document are summarised below.
DMRB CD 123
4.1.6 This document classifies signal controlled junctions as being either ‘existing’ or ‘new’ junctions. Existing junctions are defined as either existing signal controlled junctions, or existing priority junctions being upgraded to signal control. As such, the proposed design is classified as an ‘existing junction’ rather than a ‘new junction’ and therefore the provisions relevant to an existing junction apply in this case.
3
4.1.7 Section 7 of the guidance document relates to the junction intervisibility zone, with para. 7.3 stating that ‘An intervisibility zone shall be provided that incorporates an area that extends across the full carriageway width of each arm from a distance of 2.5 back from each stop line, as indicated in Figure 7.3.’ This is illustrated in the extract from CD123 included as Figure 1 below.
Figure 1: CD123 Extract - Junction Intervisibility Zone
4.1.8 Paragraph 7.5 of the guidance notes that “no substantial fixed obstructions shall be located in the intervisibility zone of new junctions” (our underlining) whereas paragraph 7.5.1. states that “No substantial fixed obstructions should be located within the intervisibility zones of existing junctions” (our underlining).
4.1.9 As noted in para 4.1.3 above, the word ‘shall’ indicates a requirement of the Overseeing Organisation, whereas the word ‘should’ is simply a recommendation.
4.1.10 In considering the proposed design, there is a fixed obstruction (the railway parapet) within the intervisibility zone. However, DMRB only requires that there are no obstructions within new junctions. As the proposed scheme is an existing junction, this requirement does not exist and the advice is therefore only a recommendation.
4
DfT Traffic Signs Manual (TSM) – Volume 6 Traffic Control
4.1.11 The TSM defines the intervisibility zone as an area measured 2.5m behind each stop line extending across the full carriageway width. The guidance recognises the constraints that may exist which necessitate a reduction in intervisibility, with paragraph 2.3.1 stating that:
“Adequate intervisibility helps ensure the safety of road users at junctions, and the aim should be to provide the greatest level possible for both drivers and other uses. However, in urban areas, existing building lines and other features may reduce the visibility possible below that set out above.” 4.1.12 It is clear that this guidance provides the designer and decision maker with flexibility, particularly in urban areas.
5 Safety Assessment
5.1.1 Notwithstanding the flexibility in design afforded by both relevant guidance documents, and despite the lack of a requirement to provide intervisibility, it is prudent to consider what the implications of not providing the intervisibility are, in relation to the concerns cited in the decision notice.
Signal Failure
5.1.2 In the unlikely event of the signals completely failing, the junction would revert to priority control, similar to the existing situation.
5.1.3 Whilst rare, these situations do occur, and drivers generally behave cautiously due to the relatively uncertain situation they are presented with. In this case, drivers crossing the Bromyard Road stop line are likely to drive forwards slowly until they had a full view of the junction. Within this area, Bromyard Road is wide enough to accommodate cars or light goods vehicles travelling in both directions. As such, although vehicles travelling from Bromyard Road may not immediately be visible from the Hereford Road stopline, their paths would not conflict.
5.1.4 If a HGV was making a left turn into Bromyard Road from Hereford Road during a period of signal failure, they are likely to encroach into the oncoming traffic lane, but they are likely to do so cautiously and this is no different to the current situation.
5
‘Jumping the Lights’
5.1.5 A key element of traffic signal design is the ‘intergreen’ period between the end of the green signal giving right of way for one phase, and the beginning of the green signal giving right of way for the next conflicting phase. The intergreen period therefore provides a safety margin which allows traffic to clear the junctions safely, even though there is reduced intervisibility. The intergreen periods have been calculated specifically for this junction design using the methodology within the Traffic Signs Manual, which specifies a time period based on the distance between conflicting vehicle paths.
6 Relevant Examples
6.1.1 As noted within the TSM, existing building lines and other features may reduce the visibility possible. This does not necessarily translate to an unsafe junction design. A useful local example of this is the Homend / Southend / Worcester Road / New Street signal controlled junction within Ledbury town centre (as shown in Figure 2).
Figure 2: A438 The Homend / A449 Junction
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6.1.2 In this example, the narrow road widths caused by the surrounding historic buildings mean that the stop lines are set back by between 15 and 20m on the northern, western, and southern arms, and by 80m on the eastern arm. As a result, the historic buildings form fixed obstructions within the intervisibility zone between all the stop lines.
6.1.3 In the last five years for which records are available (to July 2019), only one personal injury collision has occurred at this junction; when a pedestrian ran into the side of a vehicle. The cause of this collision is not related to the lack of intervisibility.
6.1.4 Given the local context, the lack of accidents at the junction described above, and given that the traffic flows at this junction are similar to those forecast at the Bromyard Road / Hereford Road junction, it is considered that the lack of full intervisibility does not represent significant risk to road safety.
7 Alternative Access Considerations
7.1.1 Given that the decision notice suggests the intervisibility issue is ‘easily capable of being overcome by the applicant providing a second vehicular means of access’, it is necessary to consider whether this is indeed the case.
7.1.2 Four access options were considered within the Environmental Statement:
1 Single vehicular access via B4124 Bromyard Road (as proposed by the planning application); 2 Single vehicular access from the Hereford Road (A417 / A438) roundabout; 3 Vehicular accesses from Bromyard Road and Hereford Road, with a link road between; and 4 Vehicular accesses from Bromyard Road and Hereford Road, with no link road between.
7.1.3 The council’s preferred access scenario, Option 3, would result in less additional development traffic at the junction than under Option 1, due to some traffic diverting onto Ledbury Bypass from the viaduct access. However, surveys carried out to inform the Transport Assessment demonstrate that significant queuing already occurs at the junction [CD xxx, Section 3.4], and there is also an acknowledged pedestrian safety concern [CD xxx, paras 3.10.3 to 3.10.5].
7.1.4 Furthermore, under all access options there would a significant uplift in pedestrians crossing Bromyard Road at the junction. The Transport Assessment [CD xxx, p.40, Figure 6-1] estimates that an additional 391 pedestrians will cross Bromyard Road at the junction between 0700 and 1900 each weekday, plus a further 43 cycle trips [CD xxx, p.40, Figure 6-2]. These numbers are common to each access scenario.
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7.1.5 Therefore, given the existing capacity and safety issues at the junction, it can reasonably be concluded that under all options a similar improvement scheme would be required to accommodate both the additional vehicular traffic and pedestrian demand.
7.1.6 Given that a similar improvement scheme would be required irrespective of the access option, the issue of intervisibility would still arise and the provision of a second point of access would therefore not resolve this matter.
8 Summary
There are significant safety, operational and capacity issues at the existing junction; The proposed junction design would offer improved capacity, allow for a safer and more efficient operation and provide a controlled pedestrian crossing facility; The relevant design guidance recognises that intervisibility is often restricted, and allows for reduced intervisibility where necessary; In the event of signal failure or vehicles ‘jumping the lights’ there would not be an unacceptable safety risk; There are relevant local examples of restricted intervisibility where there is no record of highway safety issues; and The provision of a second point of access would not resolve this matter as a similar improvement scheme would be required in any event.
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Appendix A Swept Path Analysis – Existing Junction
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1:500 10 20 30 NOTES A2 These drawings have been produced with reference to the CDM Regulations 2015. Please note that these are pre-construction phase drawings and should be subject to Bromyard Road Bromyard further design risk management as required in accordance
with Regulation 9
Bridge Bridge
12
Existing area of vehicle overrunning
Bridge Bridge
2.8 6
'Standard' Rigid Bus Overall Length 12.000m Overall Width 2.550m Overall Body Height 3.069m Min Body Ground Clearance 0.309m Track Width 2.350m Lock to lock time 4.00s 'Standard' Rigid Bus Wall to Wall Turning Radius 10.771m
13.6 6.53 Hereford Road
Max 90° Horiz 4.78 Max 10° Vert 1.37 3 1.4 6.4 1.4 1.4 2.52
Max Legal Length (UK) Articulated Vehicle (16.5m) Overall Length 16.500m Overall Width 2.550m Max Legal Length (UK) Articulated Vehicle (16.5m) Overall Body Height 3.681m Hereford Road Min Body Ground Clearance 0.411m Max Track Width 2.500m Lock to lock time 6.00s Kerb to Kerb Turning Radius 6.530m
4.223
0.762 2.692
DB32 Private Car Overall Length 4.223m Overall Width 1.715m Overall Body Height 1.392m 'Standard' Rigid Bus Min Body Ground Clearance 0.233m Max Track Width 1.629m Bus Depot Egress, Left Turn Lock to lock time 4.00s
Hereford Road, Left Turn onto B4214 Bus Depot Access, Right Turn Into Kerb to Kerb Turning Radius 5.780m
The Homend The
Bridge
ridge B
Max Legal Length (UK) Articulated Vehicle (16.5m)
ridge
B Bridge
REV DATE REVISION NOTE BY
Max Legal Length (UK) Articulated Vehicle (16.5m) Seven House ú High Street Longbridge ú Birmingham B31 2UQ ú Tel: 0121 475 0234 Hereford Road Existing area of vehicle overrunning London ú Birmingham Bristol ú Reading ú Exeter www.pja.co.uk CLIENT Bloor Homes PROJECT Land North of the Viaduct, Ledbury Max Legal Length (UK) Articulated Vehicle (16.5m)
Existing area of vehicle overrunning DRAWING TITLE Copyright © Phil Jones Associates Ltd / PJA Civil Engineering 'Standard' Rigid Bus Hereford Road-The Homend Existing Layout Vehicle Tracking DRAWING ISSUE STATUS The Homend The INFORMATION B4214 , Right Turn onto Hereford Road JOB CODE SUB-CODE DRAWING NO. REVISION 03468- A- 011- P0
B4214, Left Turn onto The Homend Homend The Revision Letter : P - Prelim / T - Tender / C - Construction Continuing Along Hereford Road - The Homend Bus Depot Egress, Right Turn A2@ 1:500 AF ME 20.09.18 SCALE DRAWN REVIEWED DATE
Summary and Conclusion
Appendix F Technical Note – Knapp Lane / Cut Throat Lane
Proof of Evidence of Nigel Millington 48 Bloor Homes Western APPEAL REF: APP/W1850/W/20/3244410
Technical Note
Project: APPEAL REF: APP/W1850/W/20/3244410
Subject: Technical Appendix - Knapp Lane / Cut Throat Lane Safety
Client: Bloor Homes Western Version: 5 Project No: 3468 Author: JW Date: 04/06/2020 Approved: NM 1 Introduction
1.1.1 This note has been prepared to address in detail the fourth bullet point of the Council’s first Reason for Refusal:
‘The proposals would result in a material increase in undesirable trips, frequently referred to as ‘rat running’ along Knapp Lane (U67005) and Cut Throat Lane (U67005) which are substandard in design terms as: a) Knapp Lane has inadequate visibility at its south western end at its junction with The Homend (A438) and does not have footways, and b) Vehicles travelling in a south westerly direction along the A449 turning into Cut Throat Lane end of Knapp Lane (a dangerous right hand turn where a number of accidents have occurred) have inadequate forward visibility.’ As a consequence highway safety, including pedestrian and cyclist safety, would be prejudiced.
1.1.2 The Council’s Reasons for Refusal also contend that this point could be easily overcome by providing a second vehicular access beneath the viaduct.
1.1.3 This note firstly demonstrates that provision of a second access point would not reduce the propensity of vehicles to use Knapp Lane / Cut Throat Lane.
1.1.4 Notwithstanding this conclusion, this note then goes further to consider highway safety issues related to the following parts of the local highway network:
Knapp Lane / The Homend priority junction; Knapp Lane itself; and Cut Throat Lane / A449 priority junction.
LOCATION Seven House TELEPHONE 0121 475 0234 WEBSITE pja.co.uk High Street, Longbridge EMAIL [email protected] Birmingham B31 2UQ
2 Second Point of Access Considerations
2.1.1 The Council contends that the development is unacceptable due to the material increase in traffic on Knapp Lane and Cut Throat Lane, but that this could be easily overcome by providing a second point of access. Consideration has therefore been given as to whether the provision of a second access might prevent a ‘material increase’ in trips on this route.
2.1.2 Knapp Lane is an available route to the A449 towards Malvern. From the proposed access, the A449 can be reached via The Homend through the town centre, or via Knapp Lane.
2.1.3 From the suggested secondary access, the A449 can be reached via either of the above routes, or via the A417 Ledbury Bypass and New Street through the town centre. These routes are highlighted in Figure 1.
2.1.4 Table 1 provides a comparison of journey times and distances for the various routes between both access points and the Cut Throat Lane junction with the A449.
2.1.5 The journey time analysis is based on Google Maps, and has been reported for weekday departures at 08:30, 12:00 and 17:30, in both directions. The journey time range provided is the minimum and maximum reported by Google Maps for these routes across all the periods.
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Figure 1: Routes to A449 from Access Points
Table 1: Route Route Route Journey Time Distance (to Cut Throat Lane / A449 Junction) Bromyard Road Proposed Access Knapp Lane 5 minutes 2.6km to A449 at Cut Throat Lane The Homend 6 – 9 minutes 3.6km Junction Suggested Secondary A417 Knapp Lane 5 minutes 2.1km Access to A449 at Cut Throat The Homend 6 – 8 minutes 3.2km Lane Junction A417 Leadon Way / A449 The 7 – 12 minutes 4.7km / 3.8km (one-way Southend system)
2.1.6 Table 1 shows that Knapp Lane presents the shortest and quickest route to the A449/Cut Throat Lane junction from both access points, therefore the provision of the secondary access point would not reduce the propensity for development traffic to use Knapp Lane. Notwithstanding this conclusion an assessment of the safety of this route has been undertaken below.
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3 Knapp Lane / The Homend
3.1 Junction Layout
3.1.1 Knapp Lane and The Homend form a simple priority junction. The Homend measures between 7.0 - 7.5m in width and features some on-street car parking either side of the junction.
3.1.2 Knapp Lane forms the minor arm of the junction and measures approximately 4.4m in width for the first 50m from the junction with The Homend. This is insufficient for two cars to pass, however vehicles are able to pass within the bellmouth of the junction with Homend Crescent, which is visible from the Knapp Lane / The Homend junction.
3.1.3 Double yellow lines are provided around the bellmouth of the junction and the give-way point on Knapp Lane is marked by a ‘Stop’ line.
3.1.4 Both The Homend and Knapp Lane are subject to a 30mph speed limit although there are advisory 20mph maximum speed signs in place on Knapp Lane.
3.1.5 Footways varying in with of between 1.5 and 2m are provided on both sides of The Homend. Footways are not provided on Knapp Lane.
3.2 Design Parameters – Visibility
3.2.1 An Automatic Traffic Count (ATC) traffic survey was undertaken on The Homend for a 7-day period from 5th February 2020. The survey recorded an 85th percentile speed of 27mph northbound and 24mph southbound. The data is provided within Appendix D of this note.
3.2.2 Based on the formulae provided within MfS2, the recommended SSDs are 36m from Knapp Lane to the north and 31m to the south. No allowance for wet weather was applied to the traffic speeds within the SSD calculations. The visibility cannot be achieved from an ‘x’ distance of 2.4m, as this is restricted by the adjacent properties. The SSDs can be achieved from an ‘x’ distance of 2.0m, as demonstrated on the drawings within Appendix E of this note. This represents a situation where the vehicle on Knapp Lane edges into the carriageway until there is a full view of oncoming traffic.
3.2.3 Personal Injury Accident (PIA) data has been obtained from Herefordshire Council, for the most recent five-year period available (06/05/2015 – 23/07/2019). The data reveals that there have been no personal injury collisions at the junction within the five year period.
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4 Knapp Lane
4.1 Highway Layout
4.1.1 Knapp Lane provides a route between A438 The Homend and A449 Worcester Road. Approximately 350m from The Homend junction, Knapp Lane becomes Cut Throat Lane.
4.1.2 Knapp Lane varies in width, predominantly between 4.0m and 5.5m although in small sections narrowing to 3.5m. Knapp Lane serves several residential streets on either side, including Knapp Close, Homend Crescent, Bank Crescent, Knapp Ridge and Upperfields. The road follows a steep uphill gradient between Knapp Lane and Cut Throat Lane.
4.1.3 In 2010, the Council undertook a review of traffic management on Knapp Lane. Following this review, traffic calming measures were installed on Knapp Lane, including:
An advisory 20mph speed limit; ‘SLOW’ road markings on approach to the junction with The Homend; Road markings to narrow an 80m section between Knapp Close and Knapp Ridge, with a give- way system in operation providing priority to northbound traffic; At the transition to Cut Throat Lane, 30mph roundels were provided; and Two further sets of 30mph roundels with dragon’s teeth road markings were provided.
4.1.4 A copy of the Council’s review and a drawing highlighting the measures that were installed is presented within Appendix F to this note.
4.2 Pedestrian Safety
4.2.1 Pedestrian traffic volumes on Knapp Lane were recorded as part of a traffic survey on Thursday 6th February 2020. A copy of the data is provided within Appendix G to this note.
4.2.2 During the AM peak hour (08:00 – 09:00), 12 pedestrians were recorded on Knapp Lane, and in the PM peak hour (17:00 – 18:00), seven pedestrians were recorded.
4.2.3 Although there is no footway on Knapp Lane, the road is of sufficient width to allow a car and a pedestrian to pass. There is street lighting provided and signage warning drivers to expect pedestrians walking in the carriageway.
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4.3 Accident Data
4.3.1 The accident data in Appendix C identifies just one collision in the last five years on Knapp Lane. The collision involved a vehicle travelling down Knapp Lane which overtook a cyclist. The vehicle then stopped to give-way to an oncoming vehicle, the cyclist behind then failed to stop and collided with the rear of the stopped vehicle ahead.
4.3.2 No other collisions were recorded, including any involving pedestrians.
5 Cut Throat Lane / A449
5.1 Junction Layout
5.1.1 Cut Throat Lane forms a simple priority junction with the A449 Worcester Road. The A449 Worcester Road measures approximately 7.5m in width and has a centre-line radius of c.70m. Around this bend, the A449 benefits from a section of c.1.0m hatching along its centreline. This results in two single lanes measuring approximately 3.25m in width. Overtaking manoeuvres are banned by the solid white line, whilst the hatched area provides a sense of visual narrowing.
5.1.2 Cut Throat Lane forms the minor arm of the junction and approaches the A449 road at an acute angle on the outside of the bend, with a c.4.0m radii on its southern kerb line. Cut Throat Lane varies in width, between c.4.5 – 5.0m.
5.1.3 Both Cut Throat Lane and the A449 are subject to the national speed limit (60mph) and street lighting is not provided.
5.2 Visibility – Stopping Sight Distance Calculation
Stopping Sight Distance Formula
5.2.1 Providing adequate visibility at a junction allows road users to judge approaching traffic and complete manoeuvres with a sufficient margin of safety. Visibility should be measured in either direction from the minor arm of a priority junction (a visibility splay) and as forward visibility on the major arm.
5.2.2 The main parameter for measurement of visibility is the Stopping Sight Distance (SSD), which is the recommended distance to enable drivers to see ahead and come to a stop from a given speed. The basic formula for calculating SSD (in metres ) is: