Planning Application 86999/11
Dear Mr Allen,
As promised, my response to the Addendum to the Traffic
Assessment posted on the Planning Website on 29th February.
Preamble
May I first of all state my puzzlement at the following.
There are three main documents relating to the Transport
Assessment
The original Transport assessment created in November 2011
had as its primary author a Mr Ajay Patel from MVA Consultancy.
Subsequently a review of this carried out by TfGM /HFAS with
recommendations.
Finally, the Addendum to the Transport Assessment created in
February 2012.
This purports to come from a different company called
Assured Planning. However the author of this is a - Mr Ajay Patel.
There is no record of this company at Companies House nor is
there any address given on the one page website. This is peculiar.
It would appear that Mr Patel in February is reviewing the
conclusions he arrived at in November. This is fair enough in the light of
recommendations from TfGM/HFAS.
He also attempts to counteract the points made principally
by Mr Chris Lord in his objection as well as some made by myself.
It is these counteractions upon which I wish to comment.
I know it’s a bit tedious, but bear with me.
Chris and I are coming from the direction of the day to day
physical reality of the road network and traffic in the vicinity of the
junction and the wider Village and commonsense projection of what would occur
with the increased traffic from the development and proposed changes to the
highways.
This could, might and probably does clash with what a
computer in Birmingham might say,
but I am sure that the Committee members, particularly those who live in the
Village will also approach it in the same way as ourselves.
The response to
remarks made by Mr Lord and my comments. (one by one)
No 1
Mr Lord:-
The investigation does not take into
account any observations regarding the turning movements of rigid HGV’s and
buses when negotiating the Church Street/Market Street turn. These vehicles
cannot safely negotiate this junction without using lanes for on-coming traffic
Mr Patel:-
4.2 There are buses
which currently undertake the turning movement from Church Street/Market Street to Ainsworth Road and vice versa.
4.3 The accident data
for the Market
Street/Church Street/Ainsworth Road/Lever Street junction shows that there have been no
accidents involving any bus movements or HGV movements in the last 5 years.
Therefore the accident data suggest there is no significant highway safety
issue regarding turning movements of HGVs and buses.
4.4 Furthermore it is
expected that likelihood of buses (the 544 bus route has a frequency of every
60 minutes) interacting with large delivery vehicles is minimal as it is
expected that large delivery vehicles will access the store outside of peak
traffic hours when the bus service will be operational.
Me:-
Mr Lord is referring to the turning of No 524 buses and HGVs
from Market St into Church
St. This requires them to cross the centre line of the carriageway in Church
St and to do this they must wait for a gap in the
oncoming traffic. This causes following vehicles to back up in Market St.
This crossing of the centre line is essential to prevent the
rear nearside of the vehicle from mounting the kerb adjacent to the Door Shop
and depends on the judgment of the driver concerned. Thankfully these judgments
so far have avoided any pedestrian injuries or collisions with oncoming traffic
but this safety issue is inbuilt into the geography of the junction and still
exists.
Mr Lord did not and is not referring to the No 544 bus. The
frequency of the No 524 is every ten minutes in peak hours.
No 2
Mr Lord:-
a) The proposed junction from Crossley
Street is too close to the junction with Ainsworth
Road/Market Street/Church Street and Lever
Street. Vehicles queuing to access Ainsworth
Road from Market
Street cannot see traffic coming from Church
Street as the visibility is obscured by the
adjacent shop.
b) Traffic
attempting a right turn into Church Street
from Ainsworth Road
will be restricted from doing so by traffic on the adjacent roads resulting in
a build-up of traffic into the Tesco development.
Mr Patel:-
4.5 It is envisaged that
the internal access from the proposed development onto Crossley Street provides sufficient queuing space for
vehicles to egress onto Ainsworth Road.
4.6 The proposed
development access from Crossley Street to Market
Street
is similar in distance to the current TESCO access from Jessop Forge/Foundary Street to Market Street. Furthermore Foundary Street locates another serving access upstream of
the TESCO access with stationary vehicles parked opposite the access.
4.7 However from the
re-assessment of the junction in LINSIG (model 1 and 2) the results shown in
Appendix A show that Ainsworth Road arms results in maximum queue of 8 vehicles
which is a queue length of 46 metres. This queue can be accommodated along Ainsworth Road without blocking the development access via
Crossley
Street
as the distance from the give way line of Ainsworth Road to the exiting lane of Crossley Street is approximately 50 metres.
4.8 The visibility
issues discussed above would suggest that the decreased visibility presented by
the shop on the corner leads to a decrease in speed of vehicles passing by.
Therefore cars coming from Church Street to Market
Street
do so at a low speed resulting in gaps in traffic for cars to turn right into Ainsworth Road.
4.9 Furthermore the
results from the LINSIG re-assessment of the proposed junction show that there
is sufficient capacity
for vehicles at the junction turning right out of Ainsworth Road.
Me:- The reality of traffic flow up Church St right into
Market St, particularly at evening peak hours, is a constant stream at the rate
of one every couple of seconds. The
speed of this traffic is typically 20mph into and through the bend since they
have priority and have no anticipation (and usually no intention) of giving way
to traffic entering or leaving Ainsworth Rd.
The first point that Mr Lord is making is that a driver parked
at the centre line in Market St wishing to turn right into Ainsworth
Rd can only see this oncoming traffic as it enters
the junction. This driver has no clue as to when a gap may occur in this stream
of traffic and, should he try to anticipate a gap, has only seconds to commit
to and complete his manoeuvre.
The second point he is making is that a driver wishing to exit
Ainsworth Rd across Market
St and into Church St
has indeed a view of traffic approaching up Church St
and can spot an appropriate gap. However this has to coincide with a gap in the
traffic approaching the junction from Market St
for him to be able to complete this manoeuvre.
This is the cause of traffic backing up Ainsworth Rd. The
reality is that it can take up to five minutes to get out of Ainsworth
Rd at peak times and it is completely unrealistic
to suppose that with the development the queue would involve a maximum of 8
vehicles.
Comparison with the Foundry St/
Market St junction is
ridiculous.
1. There
are three and a half times as many parking spaces proposed for the development
as exist at Tesco Metro and proportionally more development generated traffic.
2. Traffic
wishing to turn right from Market St
into Foundry St have
complete visibility.
3. There
is usually room for the main flow of traffic to pass such waiting cars.
4. Vehicles
using Foundry St to access
Fletcher St and the Precinct Car Parks usually exit at the Mytham
Rd end.
All the above amply demonstrates the disconnection between the
Computer modeling figures and the known reality on the ground.
No 3
Mr Lord:-
The Traffic Impact Assessment indicates that there will be
no significant increase in traffic on the premise that the new store is for the
local community. Is it not reasonable to assume that visitors from neighbouring
districts will use this facility as they do not have a Tesco store nearby?
Users from the neighbouring districts will undoubtedly use a car as their
preferred mode of transport thereby increasing trip numbers. No account for
this has been included within this assessment.
Mr Patel:-
4.10 Travel to the
store from neighbouring district has been accounted for in the transport
assessment. This is shown by paragraphs 3.6.6, 3.6.7 and 3.6.8 in the transport
assessment.
4.11 This states
that analysis of the local authority’s Retail and Leisure Study shows that many
of the residents of Little Lever currently undertake shopping journeys by car
to retail stores outside of the area. It is expected these people will make up
a large proportion of customers at the proposed development and therefore there
will be a reduction of vehicular trips on the local highway network.
4.12 It also
states that it is expected that the proposed development will result in an
overall reduction in travel distance for food shopping purposes as it will be
in a more convenient location for the residents of Little Lever than the
foodstores they currently shop at.
4.13 It further
states that this implies that a lot of the primary trips to the site may
already be travelling along Market St and Church St anyway. This has
not been accounted for in the trip assignment calculations as they would
actually result in a decrease in trip generation numbers and they are therefore
considered to be very robust.
Me:-
Paragraphs 3.6.6, 3.6.7, & 3.6.8 actually state the
following:-
3.6.6 Additionally
from analysis of the local authority’s Retail and Leisure Study shows that many
of the residents of Little Lever currently undertake shopping journeys by car
to retail stores outside of the area. It is assumed these people will make up a
large proportion of customers at the proposed development.
3.6.7 Therefore it
is expected that the proposed development will result in an overall reduction
in travel distance for food shopping purposes as it will be in a more
convenient location for the residents of Little Lever than the foodstores they
currently shop at.
3.6.8 Consequently this also implies that a
lot of the primary trips to the site may already be travelling along Market St and Church St anyway. This has not been accounted for in
the trip assignment calculations, and they are therefore considered to be very
robust
1) - Mr Lord is referring to customers travelling into Little
Lever to visit the development from Farnworth, Radcliffe, Great Lever,
Breightmet etc etc. He is not referring to the indigenous population of Little
Lever.
These are the visitors from outside Little Lever that the
Transport Assessment does not take into account. The above paragraphs do not
mention them.
Tesco can quote from ‘The League of Gentlemen’ – “This shop is
for local people only” till they’re blue in the face but commonsense should
anticipate visitors from these other areas – in fact Tesco are probably
counting on them.
2) – As regards the indigenous population of Little Lever who
(hopefully for Tesco) will no longer travel out for the ‘big shop’, they might
indeed save a bob or two on petrol. However those who previously travelled in
the Radcliffe/Bury direction will now be heading into the Junction and those
who previously travelled along the priority Church St
/Market St route to Bolton,
Farnworth and beyond will now be trying to get into Ainsworth rd. To pretend
that somehow there will be a reduction in the potential chaos at the Junction
is facile.
No 4
Mr Lord:-
As a result of a potential increase in traffic along Market
Street/Church Street road users may try to
use Redcar Road/Aintree Road/Mytham Rad to avoid congestion. The roundabout at Redcar
Road is substandard despite alterations
carried out recently.
Visibility to the
right when exiting Redcar Road
is severely restricted and does not comply with current visibility requirements
despite recent improvements. Serious accidents have already occurred at this
junction and any increase in traffic is likely to increase the possibility of
future accidents.
It should also be
noted that Redcar Road
and Mytham Road
contain primary schools and therefore carry vulnerable users during peak times.
Aintree Road has in
the past been subject to possible traffic calming measures and it is my opinion
that these should be considered again as part of a Section 106 Agreement to
prevent the use of these roads as a rat run.
Mr Patel:-
4.22 A
SATURN model assessment is currently being undertaken. The SATURN model will
assess the impact of the one way Lever Street and envisaged rat running upon the wider
extent of the local highway network which includes the roundabout at Redcar Road, Aintree Road and Mytham Road route.
Me:-
I assume that this exercise will be completed, the results
posted on the Planning Website and sufficient time given for public comment
before this Application goes before the Committee. The concerns of the
residents of the above mentioned roads, whether or not they are generally in
favour of or against this development, should not be underestimated.
No 5
Mr Lord:-
Furthermore in recent years Market
Street, High Street and Church
Street have undergone a major resurfacing
scheme carried out by the Council. During the preparation of this scheme the
junction at Market Street,
Church Street
and Ainsworth Road
underwent a detailed review. At the time I understand that the only option
which was viable was to place signals on this junction. This option was not
taken any further due to the cost implications.
Mr Patel:-
The junction has been
re-assessed with as stated in paragraphs 3.30 and 3.42.
Me:- The only thing we are all agreed on. Traffic lights are
out of the question.
No 6
Mr Lord:-
The preferred option would have been a roundabout but the
lack of available space without a Compulsory Purchase Order ruled this option
out. At no time was a give way junction considered with markings on Market
Street and Church
Street as this would not have been deemed
safe.
Mr Patel:-
4.23 A
roundabout option was for the junction was discussed with BCC. This was
assessed by TfGM and considered not to be feasible due to the safety and
capacity implications.
Me:-
Mr Patel is obviously referring to the ‘Double Mini
Roundabout’ option which had been examined in preparation of the original
Transport Assessment and then discounted.
Mr Lord is not referring to this. He is referring to the
purchase and demolition of the former Berrys Electrical Shop complex, the
Baileys Newsagents complex and the Millington’s/
LA Diner complex to open out the junction for a proper roundabout into which
the site access could be brought. This, together with the difficulty of moving
the British Gas control unit would at a rough estimate cost the thick end of
£3million.
I do know that approaches have been made to the owners of some
of these properties.
No 7
Mr Lord:-
A staged safety audit should be carried out by the Council
and not the developer if this scheme is to be given further consideration.
Mr Patel:-
4.24 It was always the
intention that an independent staged safety audit should be carried out to
assess the safety implication of the proposed junction.
Me:-
Perhaps this would be better worded – “ It has always been and
still is the intention …….etc.”
The response to
remarks made by Myself and my comments.
The majority of the remarks I made in my original objection
to the Transport Assessment are covered by and co-incidental with Mr Lord’s
remarks and the seven points made above.
1)My comments subsequent to the One Way proposal for Lever
St suggested that the 100 vehicles per hour that currently enter Lever St from
the Junction would have to take one of two (or possibly three) alternative routes.
Mr Patel suggests that these have been re-distributed but it
is not clear to me how many have been allocated to the Ainsworth/ Victory
Rd option, the Dearden St
option (or the Fearneyside/Rydal option).
2) Mr Patel states:-
4.34 Furthermore
the SAT IP peak period for the 2013 Design Year flows has been modelled only.
This has been agreed with BCC. This period produces the highest trip generation
from the proposed development and therefore represents a worst case scenario
and the most robust assessment of the proposed access.
This is in relation to the modeling of the Crossley St/
Ainsworth junction.
This may be the worst case scenario for the access, but the
worst case scenario for the interaction of the store generated traffic and the
Junction is the evening peak period and the constant stream of traffic up
Church St and right into Market St as previously mentioned.
Conclusion:-
In spite of his best efforts, Mr Patel has obviously
misunderstood the points made by Mr Lord and so his responses fail to answer
these satisfactorily.
The entire premise of the various versions of the Transport
Assessment is that the computer modeling produces a realistic projection of the
traffic impact of this development in 2013.
The very fact that three different methodologies have been
used, using three different programmes makes one wonder how realistic the
results are.
A cynic would say that if one methodology does not produce
the desired or necessary result, then try a different one until that result is
obtained.
Even after this, the gap between those results and the
application of commonsense and logic to the knowledge and observations of local
people who live and use this junction and the surrounding roads on a day to day
basis, is so wide as to cast doubt on their validity for the purposes of this
Application.
Paul Richardson
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