OBJECTION LETTERS AGAINST THE WARREN ROAD ACCESS SHOULD BE SUBMITTED TO planapps@westberks.gov.uk BEFORE 29 JAN 16 (COPY TO: towncouncil@newbury.gov.uk, WITH THE TITLE “SANDLEFORD PARK PLANNING APPLICATION NO: 15/02300/OUTMAJ)” PLEASE DON’T FORGET: INCLUDE THE TITLE: PROPOSED DEVELOPMENT AT SANDLEFORD PARK, PLANNING APPLICATION NUMBER 15/02300/OUTMAJ YOUR NAME AND ADDRESS AND SIGN THE LETTER (THEY WILL NOT ACCEPT ANONYMOUS OBJECTION LETTERS) People have asked how the letter/email should be set out. It is suggested that the letter/email should follow a standard letter/email layout and say that you wish to object to the proposed development at Sandleford Park and have the following objections ………. (then complete as you wish) Brief History of the Warren Road Access Site selection From Bell Cornwell document on behalf of Blue Living Limited, West Berkshire LDF Core Strategy Examination, Main Matter 3, Sub Matter Strategic Allocations Hearing, Date Thu 4 Nov 10: “It is quite remarkable that the additional information submitted by the scheme promoter matched so closely the information the Council might require to justify such a decision without providing much in the way of details about an actual scheme which might provoke greater public realisation about the scale and nature of what might take place at Sandleford Park” The Warren Road Access was mentioned in the West Berkshire LDF Phase 4 Assessment Jul 10: “Since Apr 10, the Council has been engaged in masterplan discussions with the planning agent for Sandleford and key stakeholders; and different options for accesses have been discussed”. Warren Road was listed. In the same report. “Similarly an access onto Warren Road would also require obtaining additional land because the road is currently not wide enough and this could result in a detrimental environmental impact, especially with regard to trees”. However, despite objections, Warren Road was included in the Development Plan Document in Jul 12 as a sustainable transport route, NOT ALL VEHICULAR ACCESS. ESSENTIAL OBJECTION POINTS: 1. The Transport Assessment fails to model the Warren Road Access. 2. The Transport Assessment identifies an unrealistic assignment of development traffic since far more traffic would use the Warren Road access. 3. The Transport Assessment fails to consider the impact of the development on key pedestrian routes around the local schools and churches. 4. The supporting transport information fails to consider the transport environmental impacts of the development on sensitive receptors such as local schools and vulnerable road users, again, particularly associated with the local schools. 5. No work has been undertaken to consider the implications of the proposed Warren Road access on parent drop-off and pick-up at nearby schools, the accommodation of the access into the church hall car park opposite and the implications of the lay-by on the opposite side of the road. 6. It is seen as particularly important that the access route via the A339 is constructed immediately and used to allow HGV traffic access to the site. The development will last more than a decade and, for Health & Safety reasons it is suggested that, due to this option being available, HGVs should be kept away from the surrounding residential areas, particularly the schools wherever possible. In addition, this junction should incorporate the Recycling Centre and a roundabout to prevent unnecessary road journeys, thus reducing congestion at the surrounding roundabouts and allowing traffic to flow in both directions from this access. This may also encourage a reduction of traffic destined for Andover Road. According to the Environment Statement Para 17.9, a haul route will be required to be laid out through the site to enable construction traffic access to Development Parcel West 1. However, there is also a proposal for no more than 15 HGVs an hour to use the Warren Road access. A clear construction traffic route needs to be planned, taking into account the external alterations (road alterations, Park House School, Doctor’s Surgery etc) which will be required and the proximity to heavily pedestrianised areas. OTHER OBJECTION POINTS: An important tree group (as stated in Quality Design, West Berkshire SPD, Area Design Focus Andover Road, adopted 19 Jun 06) will be affected by the proposal to widen Warren Road if the same level of safety features (pavement widths etc) and sustainable transport measures are adopted in Warren Road as in Sandleford’s main east/west link road. If these pavements are constructed at 2 metres this is the minimum permitted and is not in line with the Development’s sustainable transport measures. Should the external residents not expect the same sustainable transport facilities as the Sandleford residents? Access Road conflicts with other junctions and amenities in the immediate area – the National Planning Policy Framework states that developments should be located and designed where practical to “create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones”. Additional Traffic Management system in this area will add to the potential distractions that this area holds. It would impact on the flow of traffic and have an impact on the traffic modelling produced to show predicted traffic as a result of the Sandleford Development. This junction is currently outside the scope of currently modelling that has been carried out to support this Development. A Traffic Management system would have to encompass the junctions and amenities which span the length of the 2 schools. A single set, although helping with 1 access from St George’s car-park (although there are 2 accesses from the car-park) and Warren Road, will not reduce the dangers that the other junctions and amenities bring with them. What benefit will the Warren Road Access bring? It will allow the Developer to access his land without having to wait for the connecting road linking the north to the west of Sandleford. However, according to the Environment Statement Para 17.9, a haul route will be required to be laid out through the site to enable construction traffic access to Development Parcel West 1. Therefore, Warren Road is not required for construction and it is only required to sell the properties. Why was this access road not apparent in the Strategic Development Plan if they had discussed the access options with key stakeholders. Private business should not be dictating planning decisions. There are sufficient quantity of houses on the East parcel to meet housing quotas until the bridge is built linking both sites on Sandleford. Would the cost of the proposed junction and with it a traffic management scheme be met by the Developer, or tax payer, bearing in mind the financial benefits of this access to the Developer? If permission for the Warren Road Access is granted, there will be a period of 72 months where the only access available from the Western side of Sandleford will be the Warren Road access. This will have a considerable impact on traffic on the Andover Road, in particular PRIOR to any road alterations taking place that have been recommended to cope with the additional traffic. This must be analysed properly before a decision is taken as it is likely to adversely affect traffic until the bridge linking the north and west of Sandleford is built, thus increasing the traffic flowing past the schools for traffic travelling north towards Newbury. The bridge linking the 2 sites in Sandleford is essential to reach the access points situated throughout the Development, with the Developer picking up the cost of construction. However, if both parties have access to their developments either by Warren Road or Monks Lane, there is no incentive to ensure the bridge is built. This may cause problems at a later date if either parties run in to financial problems. Without accurate traffic modelling we are assuming that if Warren Road did not exist, many residents would leave Sandleford by the A339 (hopefully with a roundabout allowing them to turn right to the Swan roundabout). The remaining traffic may indeed pass the schools if travelling from Monks Lane, however, it is easier to cross a road when the only consideration is what is travelling from left or right. If a link road south is built, whether that be to Wash Water or elsewhere, this alleviates the problem and takes the Sandleford traffic destined for the A34 away from the area of the schools. This southern link road would also support the future building of plots NEW019, NEW 108 and any other future building. If it cannot be incorporated into the existing plan, it should be incorporated into the new Local Plan to relieve the volume of traffic from the Andover Road, which is an old road not designed for modern traffic quotas. If the western section of Sandleford was to be built/houses sold when the bridge was available, this would allow time for a southern link road to be constructed. We have been told that the east/west link road will be designed to prevent rat running, but conflicting with this information is the statistic provided in the traffic modelling which has forecast a 40% traffic distribution from Sandleford through Warren Road, to alleviate the traffic on Monks Lane. A transport consultant is currently reviewing the data but has suggested 1200 vehicle movements per peak hour in total from the Sandleford Development. By linking Sandleford with the Andover Road, it will effectively link the 3 schools (Falkland Primary, Park House Secondary and the new Sandleford West Primary School). This has not been modelled for traffic impact. There are already sufficient “approved” routes in the adopted Development Plan Document which was not only approved by West Berkshire Council but by an independent inspector (Inspector’s Report dated 3 Jul 12) where he stated “Being a greenfield site and in the absence of any particular infrastructure requirements (other than the somewhat elongated access road to the south-western part of the site, which is not required at the outset) there is no reason to doubt that the development would be viable” The figures stated by JUBB who wrote the transport assessment, on behalf of Bloors, are supposedly based on the 2011 Census Travel to Work Modal Split for Falkland and St Johns Ward combined are incorrect to the benefit of the Developer, as can be verified on the National Statistics Website. There is no comment to indicate why these figures should be different from those on the Website. It should be commented that the traffic projections modelled on traffic movements of St Johns and Falkland Wards do not reflect what would actually happen in Sandleford as both wards are at the bottom of the hill and nearer to the town centre. In addition, the base data does not take into account the economic downturn during 2011 which would result in fewer journeys made. Para 5.5 Transport Assessment also states that the data contains transport destinations. This is also assumed to be incorrect as a traffic survey is the only method of obtaining this information and was only carried out for the St John Ward and not Falkland Ward. If this is indeed the case, without accurate base data there can be no confidence in the modelling or West Berkshire Council’s verification methods. There is a proposal for no more than 15 HGVs an hour to use the Warren Road access. However, given the proximity to parallel external construction (road alterations, Doctors Surgery, Park House school extension) in what is a heavily used pedestrian area, we do not believe that this should be used for construction vehicles at all. Even during school holidays this area is heavily populated as there is a holiday club catering for school children, and all the community groups associated with St George’s Church and the Roman Catholic Church located in Warren Road. This is a residential area heavily populated with children due to the close proximity of the schools and so the children do not disappear just because they are not required at school and can be seen travelling to friends, parks and local shops on scooters and by foot. Sandleford Park, Environmental Statement, para 14.185: “The impact of construction activities …. Would have a temporary minor negative effect. However, any residual negative effect would be short term and negligible”. Considering the construction is planned to continue for at least a decade, it would be difficult to see how the construction is seen as “short-term” and how, when considering the length of time prior to acting on highway mitigation measures, following the commencement of building, it would have a “negligible” effect on the surrounding area. Following construction, there will be a steady flow of HGVs to accommodate private housing and the planned business premises. Future HGV access should be planned and not left to chance, around busy schools. A report Child Pedestrian Exposure and Accidents – Further Analysis of Data from a European Comparative Study for the Dept of Transport (Road Safety Research Report No 56 Dtd Sep 05) “Most child pedestrian casualties were hit by cars. Accidents with larger vehicles had higher severity rates than average, reflecting the increased intensity of the impact when a heavy vehicle is involved.” A343 Accident Data, W Berkshire 1990-2014: 16 KSI collisions, involving 17 casualties and 94 PIA collisions, involving 122 casualties. There have been 3 reported accidents (involving 1 or more individuals) on the Andover Road directly in front of the schools since 2012 and a fatality in 2000 in the vicinity of the Kendrick Road/Andover Road junction (also close to the schools). The A343 is a Local Access Route, the A339 is a District Area Route to Key Distributions. The plan of the access routes linking Sandleford and the adaptation of the surrounding roads will encourage HGVs to take the shorter route via the A343. Department of Transport Manual for Streets “A clear distinction can be drawn between streets and roads. Roads are essentially highways whose main function is accommodating the movement of motor traffic. Streets are typically lined with buildings and public spaces, and while movement is still a key function, there are several others, of which the place function is more important” The rules for speed camera placement at the time the speed cameras on the Andover Road were installed, taken from the Safe Speed Website: o At least 4 KSI (killed and seriously injured) accidents per km in the last 3 calendar years. o At least 8 PIA (Person Injury Accident) per km in the last 3 calendar years. o Causation factors indicate that speeding was a contributory factor in some or all accidents. o At least 20% of drivers are exceeding the speed limit. Latest accident, Park House pupil in Sep 14. Why is “measures to mitigate the impact of development on the road network” scored through on the Sandleford Strategic Site Allocation Policy CS4? The reduction of the pavement width at Warren Road/Andover Road junction does not fit with the sustainable transport width of 3 metre pavements – not in line with West Berkshire Council’s sustainable transport policy. Studies have shown that pavement width is key to pedestrian safety. In the period 2006-2011 there were 85,814 injuries on roads within a 500m radius of schools; the equivalent of 1,190 incidents per month. Traffic report for SecEd magazine 3 Oct 13. It is not only the school collection times to consider, schools with senior pupils face the difficult task of balancing independence with safety, with pupils leaving the school site at lunch and break times. Dept of Transport Report dated Jun 15: Children aged 11-15 years account for 52% of child KSI and children aged 4-10 account for 39%. Pedestrians account for 69% of child KSI casualties. “In terms of a child pedestrian’s own movements, most casualties occurred when the child was crossing the road. Severity was higher than average when the boy or girl was crossing the road and was masked by a stationary vehicle (which could be parked or simply held up in a queue of traffic)” Child Pedestrian Exposure and Accidents – Further Analysis of Data from a European Comparative Study for the Department of Transport (Road Safety Research Report No 56 dated Sep 05). Report as above: “Severity was higher on major roads (mainly Class A) than on minor roads …. reflecting the underlying speed of the traffic” Speed Data for the A343 W Berks from Thames Valley Police state that 26.3% of those travelling were above the speed limit (2008). Report as above: There is a higher child pedestrian accident casualty rate in Britain as compared with France or the Netherlands. In particular, children spend more time near, and undertake more road crossings in, more major roads, wider roads, roads with higher flows of traffic and roads of higher speed. (Description of Andover Road) The National Travel Survey records that the most common mode of transport for travelling to and from school is walking. Licensed to Skill, Great Britain 2005-2009 IAM study. Car Driver Reaction: Failed to look properly – 35% of all accidents. Pedestrian failed to look properly is the highest contributory factor reported in Pedestrian accidents. This highlights the potential danger to children. The removal of Warren Road for parking and the additional competition from the new Sandleford school located on the other side of the access road, if the access road is approved, will impact on available parking in the area. Camber of the road – there is a pronounced difference in height between the road level and pavement level. Any pronounced camber in the road would affect vehicle direction under heavy breaking in adverse weather conditions, with limited protection for pedestrians. This is especially relevant to the proposed junction alteration at Warren Road where the pavements widths are being reduced, therefore reducing the safety buffer. Dept of Transport, Manual for Streets, pg 6 states that “it is all too easy to forget that streets are not just there to get people from A to B. In reality, streets have many other functions. They form vital components of residential areas and greatly affect the overall quality of life for local people” and “For too long the focus has been on the movement function of residential streets. The result has often been places that are dominated by motor vehicles to the extent that they fail to make a positive contribution to the quality of life”. “The Manual for Streets demonstrates the benefits that flow from good design and assigns a higher priority to pedestrians and cyclists”. It is difficult to comment and provide full objections on the Warren Road Access as the planning application information is incomplete for this junction. Town Council Design Statement – “The setting around the schools and churches form an essential part of the character of this Area. Any new development should respect this role and ensure that these settings are conserved and where possible, enhanced” Falkland Memorial is being considered for listing as a historical landmark and it is important to preserve it in its current context, and not to provide a widened junction that detracts from it. When the double roundabouts at the junction of Andover Road/Monks Lane were constructed it was designed to discourage HGV traffic from using local roads and thus, keep them away from the school area. This is in danger of being completely undermined by the proposed road improvements. “The appearance of key gateways to the town will be improved providing an enhanced identity for the town” West Berkshire Core Strategy (2006-2026). The West Berkshire Core Strategy (2006-2026) states “The transport infrastructure will have been improved and there will be reduced congestion and better access to public transport throughout the District”. The external allocation of primary school places whilst awaiting the opening of the Sandleford Primary Schools. The Primary School North will be the first school to be completed after the first 200 homes have been built. Children are likely to be allocated external school places until the Sandleford Schools are available. Falkland Primary School has pupil waiting lists and so it would seem logical to temporarily suspend the building of houses on the Western site until the Sandleford North School is available. Due to school allocations being calculated on catchment areas and distance measured using the West Berkshire Admissions Geographical Information System, taking a straight line between the home address and the school, it will not be possible to restrict pupils of both new schools to Sandleford residents only and so this will increase traffic flow in both directions. Website: info.westberks.gov.uk/CHttpHandler.ashx?id=38220&p=0 Bus, current return fare £3.70. User would have to stay in town for at least 4 hours to make this a cheaper option than taking a car and parking. Why does an infrequent bus service need a dedicated road and why can’t alternative access routes be used? Bus routes that have been mentioned: Bus 103 and Bus 2, no service on weekends. Bus 103: last bus 1805 hrs, Bus 2: last bus 18.42 hrs. Is this route financially viable for a private bus company and would it need subsidising by West Berkshire Council, particularly to ensure an immediate bus service to the first residents before a travel pattern emerged that was difficult to change once established. “Travel habit (behavioural automaticity) weakened immediately after the move. …. In those who changed mode, habit strength for the old mode did not disappear abruptly but rather decayed over the post-move period, whereas habit strength for the new mode grew concurrently” Old Habits Die Hard, Ian Walker, Dept of Psychology, University of Bath, 15 Sep 14. This would also apply to the use of the Warren Road Access if only one access route existed to the western site. A habit would be set before the opening of the bridge and offering the alternative access roads after 72 months.