Parkside Inquiry · 2020. 12. 22. · Parkside Action Group (PAG) Page 7 of 26 07 Dec 2020 (PLRTM)...

Reference: PAG/BP2 Revision : 1.0 Date :07 Dec 2020

Secretary of State (SoS) for

Ministry of Housing Communities and Local Government (MHCLG)

PARKSIDE INQUIRY WRITTEN STATEMENT

TRAFFIC and TRANSPORT Mr Gareth Edwards, BSc(Hons)

PARKSIDE ACTION GROUP

PARKSIDE LINK ROAD (PLR)

Planning Inspectorate References St Helens BC : APP/H4315/V/20/3253230

Warrington BC : APP/MO655/V/20/3253232 St Helens BC (SHBC) Planning Application Reference : P/2018/2049/FUL

Warrington BC (WBC) Planning Application Reference: 2018/32514 & 2019/34719

PARKSIDE REGENERATION LLP (PHASE 1)

Planning Inspectorate Reference: APP/H4315/V20/ 3253194 St Helens BC (SHBC)Planning Application Reference: P/2018/0048/OUP

Traffic and Transport

Parkside Action Group (PAG) Page 1 of 26 07 Dec 2020

Contents

1 Executive Summary ...................................................................................................... 3

2 About the Author ........................................................................................................... 3

3 Introduction ................................................................................................................... 4

4 Transport Assessment 2020 ........................................................................................ 4

5 Transport Assessment 2019 ........................................................................................ 6

6 Evidence of Review ....................................................................................................... 9

7 Economic Appraisal & Source of Funding ................................................................... 10

8 The Local Road Network ............................................................................................. 12

9 SATURN model of the Local Road Network ................................................................ 16

10 Wigan Metropolitan Borough Council objections ...................................................... 20

11 Sustainable Transport.............................................................................................. 22

12 Future Highway Restrictions .................................................................................... 23

13 Summary & Conclusion ........................................................................................... 25

Document History

Date Version Status/Purpose Author

03-Dec-2020 1.0 D1 New document G Edwards

06-Dec-2020 1.0 D2 Missing sections included

07-Dec-2020 1.0 Corrections and comments incorporated

Definitions

AADT Annual Averaged Daily Traffic

BY Base Year

BCR Benefit to Cost Ratio

FBC Full Business Case

LCR CA Liverpool City Region Combined Authority

LMVR Local Model Validation Report

PAG Parkside Action Group

PLR Parkside Link Road

PLRTM Parkside Link Road Traffic Model

SHC St Helens Council

SIF Single Investment Fund



WBC Warrington Borough Council

WMBC Wigan Metropolitan Borough Council

Document References

Ref Filename/Description

1 Review of Supporting Transportation Information, Review Note 1: Traffic Generation,

Turner Lowe Associates, November 2020

2 Review of Supporting Transportation Information, Review Note 2: Miscellaneous

Observations, Turner Lowe Associates, November 2020

3 Public Reports Pack 19102018 Liverpool City Region Combined Authority, 19th October

2018

4 Drawing no. TS1920062/001 Environmental Weight Limit Entry Locations, Warrington

Borough Council, September 2020



1 Executive Summary

Parkside Action Group (PAG) have commissioned an expert witness, Mr John

Lowe, a partner at Turner Lowe Associates, traffic engineering consultants, to

review the transportation information that supports the planning applications for

the development of Parkside Phase 1 and the Parkside link road.

Mr Lowe has prepared two reports (refs 1 & 2), one dealing with the assumptions

made as to the traffic the development schemes will generate and another report

presenting general observations which show that the base flows are incorrect,

the model is not validated and it is not representing the actual situation. These

two reports together demonstrate that the traffic generation of the developments

has been grossly under-estimated and no decision can be taken on anything the

model is connected with.

This paper complements the reports prepared by Mr Lowe by adding further

observations on the traffic generation modelling taken from a perspective of local

area knowledge.

2 About the Author

I am now retired after 37 years in the defence industry, predominantly

underwater sonars, where I occupied various engineering and senior

management roles. I have a BSc(Hons) degree in Statistics and Operational

Research.

Prior to retirement my role was that of Director Anti-submarine Warfare in Thales

UK, Defence Mission Systems. My responsibilities included the business capture

and delivery of major research, design & development and production

programmes mainly in the UK but also on the export market. I developed

excellent working relationships with senior UK MoD and Royal Navy

representatives and their equivalents in Australia and France.



My career experience encompassed software & firmware engineering, system

design, system engineering management, quality management and bid & project

management. My mathematical and engineering background has been a solid

base for being able to understand and assess technical reports.

I have lived in the Lane Head area of Lowton for the past 30 years and sit on the

committee of Lane Head South Residents Group as technical officer.

3 Introduction

3.1 This paper includes a review of the applicant’s updated 2020 Transport

Assessment and compares this with the 2019 Transport Assessment. Evidence

of review of the 2019 Transport Assessment is challenged.

3.2 The suitability of the local road network to accommodate a major logistics

development is questioned as is the validity and validation of the SATURN model

developed to represent the impacted area.

3.3 The duty to cooperate with a neighbouring authority, namely Wigan Metropolitan

Borough Council (WMBC), is reviewed including the objections raised by WMBC.

3.4 Observations are also made on the credibility of the traffic modelling results, trip

generation rates used, sustainable travel assumptions and the economic

appraisal of the Parkside Link Road (PLR).

4 Transport Assessment 2020

4.1 PAG was surprised to hear at the Case Management Conference held on 1st

October 2020 that the Transport Assessment for the PLR was to be updated so

close to the planned public inquiry and 10 months after the St Helens Council

(SHC) planning committee meeting at which approval for the PLR was granted

on the basis of the 2019 Transport Assessment.



4.2 The key reasons cited for the update were recent updates to DfT modelling

parameters and changes to the highway network. The updated assessment

includes a revalidation of the 2016 Base Year (BY) model documented in an

updated Local Model Validation Report (LMVR). Changes to the highway

network have no bearing on the 2016BY model and it is questionable whether a

2016BY model should be updated to reflect DfT modelling parameters derived in

2020.

4.3 Ramboll (SHC’s transport consultants) have commented (memo Ramboll to

WBC 24/11/20) that the revalidation exercise ‘resulted in a change to some

traffic flows’. PAG have examined the LMVR 2020 results and compared them

with the LMVR 2019 results and found the Ramboll comment to be a grossly

understated description of the changes. By illustration, Table 1 below compares

the AM Peak 2016 BY ‘Do Nothing’ traffic flows at the 40 modelled reference

sites from the 2019 LMVR and the 2020 LMVR.

Site

Ref

2019

LMVR

2020

LMVR

% diff Site

Ref

2019

LMVR

2020

LMVR

% diff

1 8367 8473 + 1.3 21 2770 2959 + 6.8

2 3075 3077 - 22 935 867 - 7.3

3 2575 2749 + 6.8 23 176 580 +229.5

4 8205 8197 - 24 2945 2692 - 8.6

5 9106 9019 - 25 2644 2550 - 3.6

6 8014 8013 - 26 1242 955 - 23.1

7 8818 8439 - 4.3 27 705 567 - 19.6

8 1331 1593 + 19.7 28 2711 2817 + 4.3

9 1417 838 - 40.9 29 601 646 + 7.5

10 1704 1399 - 17.9 30 8332 8455 + 1.4

11 611 469 - 23.2 31 1073 635 - 40.8

12 1008 712 - 29.4 32 568 877 + 54.4

13 865 685 - 20.8 33 538 591 + 9.9

14 757 1502 + 98.4 34 483 1023 +111.8

15 757 1168 + 54.3 35 1588 1101 - 30.7



Site

Ref

2019

LMVR

2020

LMVR

% diff Site

Ref

2019

LMVR

2020

LMVR

% diff

16 1551 1186 - 23.5 36 647 890 +37.6

17 420 413 - 1.7 37 981 830 - 15.4

18 1012 1285 + 27.0 38 806 900 + 11.7

19 2634 2115 - 19.7 39 2443 2444 -

20 1671 1295 - 22.5 40 6564 6708 + 2.2

Table 1 Comparison of AM Peak results between 2019 and 2020 LMVR

4.4 The differences between the output of the 2019 LMVR and the 2020 LMVR are

significant and cannot be described or dismissed as ‘some changes’. 16 out of

the 40 reference sites have differences of greater than 20% between the two

validation reports and the range of differences is from - 40% to over + 200%. The

only reference sites that demonstrate any stability between the two validation

reports are those associated with the strategic motorway network. There is no

stability demonstrated on the local road network. Similar differences are also

observed when the Inter Peak, PM Peak and AADT figures are compared

between the two validation reports.

4.5 PAG can have no confidence on any traffic forecasting that is built onto a model

that can change so drastically from one validation to the next.

5 Transport Assessment 2019

5.1 PAG’s lack of confidence is further compounded on examination of the 2019

Transport Assessment produced to support the planning application for the PLR.

5.2 In common with most traffic forecasting exercises the process for predicting the

traffic generated by the development of the different phases of Parkside and the

PLR starts with a baseline exercise to model the existing traffic flows. The model

is then validated against known data, e.g. traffic surveys. The traffic generated

by the development is then added to the validated model of the existing

conditions. Ramboll, on behalf of SHC, have developed the PLR Traffic Model



(PLRTM) for this purpose. The validated 2016BY traffic flows for the PLRTM are

documented in the 2019 LMVR.

5.3 However, the PLR Transport Assessment 2019 (ref: PD-RAM-03-00-REP-TR-

0014, Rev B, Feb 2019) does not use the 2016BY traffic flows documented in

the 2019 LMVR but instead uses a completely different set of data. (Refer to

Appendix 4 of Transport Assessment 2019 and the tables throughout to see the

data actually used). The differences in the traffic flows from the 2019 LMVR and

those used in the Transport Assessment 2019 are significant. Figures 1 & 2

below compare a sample of the AM Peak 2016BY traffic flows from the 2019

LMVR and Transport Assessment 2019.



Figure 1: Extract from 2019 LMVR

Figure 2: Extract from Transport Assessment 2019

5.4 The differences between the two data sets nor the rationale for using a different

data set are not explained in the Transport Assessment 2019.

5.5 PAG can have no confidence in any modelling results and conclusions drawn

when the baseline for PLRTM appears to be not sound.



6 Evidence of Review

6.1 The importance of thorough review of a model such as the PLRTM is essential

given the decisions that are informed or made on the basis of its output. This is

especially important when there is often a tendency to believe model output

without question because ‘it has been validated’. This tendency is apparent

throughout the applicant’s correspondence whenever the model results have

been challenged.

6.2 All of the documentation produced in support of the PLRTM has been authored,

checked and approved, i.e.’ signed off’. However document ‘sign-off’ is not

considered as evidence of review under modern quality management systems.

The checking and approval of the Transport Assessment 2019 did not reveal the

discrepancy highlighted above in paragraph 5.3.

6.3 SHC commissioned Mott MacDonald to undertake a review of the transport

elements associated with the PLR planning application. The Mott MacDonald

review is recorded in a technical note (ref: 415187-02, dated 04/12/19). The

review was limited to a defined set of documentation including the LMVR 2019

and the Transport Assessment 2019. The scope of the review was not extensive

and relied rather heavily on the assumption that the documentation supporting

the PLRTM would have been scrutinised during the review of the Full Business

Case (FBC) submission to the Liverpool City Region Combined Authority (LCR

CA) for the application of a Single Investment Fund grant of £23.8m. The text

below is extracted from the Mott MacDonald review.

Figure 3: Extract from Mott MacDonald review



The Mott MacDonald review also failed to identify the discrepancy highlighted

above in paragraph 5.3.

6.4 SHC submitted their FBC to the LCR CA for the application of a SIF grant in

August 2018. The Transport Assessment 2019 suite of documentation is not

listed as supporting information in the FBC application. The LCR CA

commissioned external consultants Cushman & Wakefield to undertake an

appraisal of the FBC. (The full appraisal report is included as Appendix 2 to the

LCR CA public reports pack 19/10/2018, ref: 3). The text below is extracted from

the summary of the appraisal.

Figure 4: Extract from LCR CA appraisal

The Mott MacDonald assumption in paragraph 6.3 above appears to be invalid

and, in fact, the only transport related document submitted to the LCR CA with

the FBC was the now superseded Traffic Forecasting Report (PD-RAM-03-00-

REP-TR-006) dated February 2018.

The LCR CA approved £23.8m of Single Investment Funding for the PLR in

November 2018.

6.5 It is PAG’s view that the PLRTM and the associated documentation suite have

not been subject to a sufficiently rigorous independent review.

7 Economic Appraisal & Source of Funding

7.1 The Cushman & Wakefield appraisal assessed the PLR FBC to be

‘unsatisfactory’ against two of the assessment criteria, ‘Project Costs’ and



‘Availability of match funding’. The appraisal also commented that further detail

on ‘Project Risk’ would have been expected and the ‘satisfactory’ score for this

element was only on the expectation that further detail would be provided when

available.

The ‘Project Costs’ were unsatisfactory because the detailed design had not

been undertaken and the costs were not final or tendered prices as would have

been expected at the FBC stage.

The ‘Availability of matched funding’ was deemed unsatisfactory because of

doubts raised regarding investment from the private sector. In the FBC the

delivery of the PLR included a public sector contribution from SHC of £6.17m

(the maximum available from the council) and a private sector contribution of

£9.85m to be provided by Parkside Regeneration LLP, the 50/50 joint venture

between SHC and Langtree. The appraisal concluded that whilst the financial

stability of SHC had been demonstrated, that of Langtree or the joint venture had

not.

7.2 The updated Transport Assessment of October 2020 includes an updated

Economics Report 2020 (ref: PD-RAM-03-00-REP-TR-0020, dated Oct 2020).

PAG make the following observations on this updated report.

(i) The public sector contribution from SHC has now increased to £16m.

(ii) No private sector contribution has been confirmed.

(iii) The Benefit to Cost Ratio (BCR) of the PLR (excluding Parkside phases 2 &

3) has reduced from 1.991 at the FBC stage to 1.469.

(iv) The forecast costs remain exactly the same at £39.8m despite the period of

performance being delayed by four years.

(v) PAG also note that the actual forecast cost is £42.3m but a ‘scheme

opportunity’ of £2.5m has been assumed to reduce the cost to £39.8m.

There is no detail as to how this opportunity is to be realised. At this stage

of planning PAG would expect to see a detailed Risk & Opportunity register.



7.3 Given the reduction in the BCR of the scheme, the required increase in

contribution from the public sector and the suspiciously static forecast costs,

despite the change in delivery programme, PAG do not consider it unreasonable

to suggest that the value for money of the PLR should be reassessed.

8 The Local Road Network

8.1 Parkside Phase 1 and the PLR do not have nor provide direct access to the

strategic highway network. Rather, both applications deploy traffic of various

classifications (HGV, LGV & commuting cars) onto the local highway network.

Access routes to the site pass through residential areas including some

designated as Air Quality Management Areas. Newton-le-Willows, Winwick,

Hermitage Green, Lane Head and Lowton will all be impacted by traffic

accessing the Parkside proposed development sites. Figure 5 shows the access

routes available for HGV traffic. Access via J22 of the M6 is only one of many

options.



Figure 5: Access routes for HGV traffic to and from Parkside

8.2 The photographs below demonstrate that the local road network is not suitable

for providing access to a large final mile distribution centre. All of the roads

shown below will be key access routes to the Parkside site.



A579 Winwick Lane showing the kerbside

cottage properties at its junction with the

A572 Newton Road. The A579 links the

A580 with Junction 22 of the M6 and is

heavily congested at peak periods. A

TfGM survey in Sept 2018 recorded

93,654 vehicles a week on this stretch of

the A579. The area is heavily polluted.

Wigan council monitor NO2 levels at this

site with the average recorded level in

2019 being 57.9 ug/m3, one and a half

times the legal limit.

A572 Newton Road. A key route along with

the A579 for northbound traffic to access

the A580 and southbound traffic to access

J22 of the M6, J9 of the M62 and the

Parkside area. Heavily congested with

standing traffic at peak times. The A572 is

in use 24 hours a day with HGV traffic.



A573 Golborne Road passes through Hermitage Green linking Winwick with

A573 Parkside Road. Very tight bends and unsuitable for HGVs but no weight

limit or warnings. Photograph above shows two HGVs meeting head on causing

gridlock.

Photographs above show the narrow bridge over railway on A573 Parkside

Road. Difficult for two cars to pass, impossible for HGVs. A573 Parkside Road

will be a key access route to Parkside phases 2 and 3 for traffic from the north.

No mitigation plans are proposed within the PLR planning application.



Low bridge beneath railway line on

A573 Golborne Dale Road. Golborne

Dale Road provides a key access link

between the A580 and the Parkside

area. It connects to the A580 at

Golborne roundabout and the PLRTM

predicts a significant increase in traffic

on this route.

9 SATURN model of the Local Road Network

9.1 Ramboll, on behalf of SHC, have developed a SATURN model, the PLR Traffic

Model (PLRTM), to assess traffic flows on the network and the impact of the PLR

and associated future developments. The validation of the PLRTM is

documented in the LMVR 2019 and updated in the LMVR 2020. The modelled

area (extracted from the LMVR 2020) is shown in Figure 5 below. In addition to

the ‘A’ roads highlighted in paragraph 7 above the PLRTM also includes a

number of minor roads; Sandy Brow Lane and Main lane connected to the A579

are examples and indicated in Figure 6. (Note: Sandy Brow Lane is incorrectly

referred to as ‘Heath Lane’ in all versions of all Ramboll reports).



Figure 6: Area covered by the PLRTM

9.2 The two minor roads are also shown as connections in the SATURN network

model, see Figure 7 below (extracted from the LMVR 2020).

Figure 7: Nodes and connections in the PLRTM

A579

Main Lane

Sandy Brow Lane

Sandy Brow Lane

Main Lane



9.3 Shown below are recent (2020) photographs of the two minor roads.

Below is Sandy Brow Lane. Tight bends, narrow sections, unsuitable for HGVs

but no weight limit in place.

Below is Main Lane. It is a farm track, unsuitable for motor vehicles and

permanently closed except for access to farm properties.



9.4 The two minor roads are clearly unsuitable for much of today’s existing traffic

and definitely not suitable for the additional HGV & LGV traffic that will be

generated by the PLR and the associated Parkside developments. However both

of these minor roads show up in examples of route choice validation in the LMVR

(all versions) to demonstrate the PLRTM is assigning sensible and logical routes

through the modelled area. Figure 8 below (extracted from the LMVR 2020)

shows Main Lane and Sandy Brow Lane as valid, viable and logical routes for

traffic moving eastbound across the modelled area.



Figure 8: Route choice validation, eastbound

9.5 The 2016 BY traffic flow diagrams shown in the LMVR 2020 indicate that ~ 500

vehicles per day use Main Lane. The 2034 ‘Do Something’ traffic flow diagrams

in the Traffic Forecasting Report 2020 indicate that more than 1000 vehicles will

be using Main Lane.

9.6 PAG can have no confidence in a SATURN based traffic model that assigns

traffic to such illogical routes and can consequently have no confidence in any

traffic forecasting from the PLRTM.

10 Wigan Metropolitan Borough Council objections

10.1 The co-operation between Wigan Metropolitan Borough Council (WMBC) and

SHC has been limited. A meeting in June 2017, two and a half years before the

planning committee meeting, is the only occasion the two parties met to discuss

transport aspects of the Parkside Phase 1 and PLR planning applications.

10.2 WMBC issued three letters of objection to SHC, 1st Oct 2019, 6th Nov 2019 and

22nd

Nov 2019. The objections covered a broad range of issues and include,

Destination

Sandy Brow Lane

Main Lane



(i) Trip Rates – based on a single example provided by SHC. TRICS database

should be used.

(ii) Junction assessments – Lowton junctions already at maximum capacity.

Modelling by SHC showing minimal impact is not credible.

(iii) Traffic forecasting and routeing credibility – modelling by SHC shows a

reduction in traffic in Lowton areas. This is not credible as Lowton is a gateway

to the A580 and areas to the north and west of Greater Manchester.

(iv) Public transport access – using public transport availability to claim reduced trip

rates is not credible.

(v) Air Quality – Nitrogen dioxide levels at Lane Head already exceed legal limits.

Traffic from the scheme development will exacerbate the situation and traffic

modelling indicating no impact is not credible.

(vi) Committed developments – 1281 homes with planning permission in Golborne

and Lowton have not been included in the traffic forecasting.

(PAG Note: More than 2000 homes are planned for Lowton and Golborne.

Figures as at 31st July 2018 were 1260 with planning permission (55 complete)

and a further 1031 allocated. None of these have been included in the traffic

forecasting for Parkside Phase 1 or the PLR. The Wigan borough is a high

commute out area and it is anticipated that commuting traffic from these

residential developments would increase traffic at junctions in close proximity to

the Parkside development).

10.3 The response to WMBC’s objections from Ramboll (for the PLR) and Curtins (for

Parkside Phase 1) were dismissive; SHC defined the trip rates and the modelling

indicates no impact on Wigan. PAG have already commented on the over

reliance on a ‘validated’ model and Mr John Lowe has already commented on

the appointed consultants not confirming for themselves that the trip rates

defined by SHC were appropriate.

10.4 WMBC have confirmed to the Planning Inspectorate that their position regarding

these objections has not changed.



11 Sustainable Transport

11.1 Sustainable travel is an important aspect to be considered with the Parkside

Phase 1 application. This is especially so given the leakage rate of the

employment opportunities to be generated has been estimated at 40% (ref: FBC

submission, page 50), i.e. 40% of the employment opportunities are likely to be

filled by people from outside the St Helens borough. This leakage rate is

reasonable given the positioning of Parkside close to the boundary of Greater

Manchester (Wigan) and Warrington.

11.2 The updated Transport Assessment 2020 attempts to explain at great lengths

how the Parkside site is well-served by existing public transport arrangements.

PAG consider the benefits of the existing arrangements to be exaggerated.

11.3 Firstly, bus routes. The services, routes, operators and frequencies are listed.

However the limitations are not. For example, service 34, St Helens – Newton-le-

Willows – Leigh, stops operating from 6pm between Newton-le-Willows and

Leigh. The bus turns around at Newton-le-Willows and heads back to St Helens.

Leigh, approximately five miles from Parkside, is one of the larger towns in the

area and a potential source of candidate employees. Warehouse operatives will

be expected to work shifts and if public busses are to be used a 24/7 service is

required. The Parkside site is located at the far eastern side of the St Helens

borough bordering Greater Manchester and Warrington. Reductions in service

across authority boundaries, such as the one highlighted here, are not

uncommon during non-peak periods.

11.4 Secondly, rail services. The rail services from Newton-le-Willows are briefly

described. The fact that one can travel as far Llandudno and Newcastle is

irrelevant, local connectivity is the important factor to consider. Newton-le-

Willows station is on the Liverpool to Manchester Chat Moss line. The nearest

station to the east is Paticroft more than 10 miles away and has an hourly

service to Newton-le-Willows. Local rail connectivity in the Northwest is well

known to be very poor. Leigh, Golborne, Ashton-in-Makerfield and Culcheth are

all potential areas that could provide employees and none of them have a railway



station. Atherton, nine miles away and a ~20 minute car drive has a station.

However there is no direct link with Newton-le-Willows and the rail journey

involves going via Manchester stations requiring one or two changes with

multiple tickets and takes more than one hour. The reality for many people living

in the wider area surrounding Parkside is that Newton-le-Willows is the station

one travels to in order to catch a train not a station that one arrives at as a

destination.

11.5 Concessionary fares. Parkside being located at the far eastern side of the St

Helens borough is also where the Liverpool City Region borders Greater

Manchester. It is unfortunate that the two regions do not have a combined travel

policy. There are concessionary fares available within Greater Manchester but

they do not extend into the Liverpool City Region. This is a further incentive for

employees from the Greater Manchester area to commute in private cars rather

than use public transport.

11.6 PAG consider the benefits of the public transport links to Parkside to have been

exaggerated. Consequently, there is no justification for reducing commuting car

trip rates on the basis of public transport provision. The favoured option for

employees will be to use private cars.

12 Future Highway Restrictions

12.1 It is recognised that any traffic forecasting exercise can only take into account

existing conditions and confirmed future highway developments. However, since

the approval of the planning applications for Parkside Phase 1 and the PLR in

December 2019 further plans for potential highway changes have emerged.

12.2 Firstly, on 8th October 2020 Warrington Borough Council (WBC) announced a

public consultation on a plan to protect Culcheth, Glazebury, Winwick and Croft

from the effects of HGV traffic by introducing an environmental weight limit at 16

locations in the area (ref: 4). This will have a significant impact on HGV

movements especially in the west to east direction of the modelled area and will

put further pressure on the A49, A572, A573 and A579.



12.3 Secondly, at the planning meeting held on 17th December 2019 St Helens

councillors made clear their intention to place a weight limit preventing HGV

traffic entering the PLR from the A49 and exiting the PLR onto the A49. The

extract below is taken from the minutes of the planning meeting. It was the only

action placed during a meeting that lasted several hours.

Local councillors also confirmed their intention in the local press.

Cllr Gomez-Aspron, St Helens Star, 20th December 2019.

Cllr Bell, St Helens Star, 10th December 2019.

Whilst the plans from SHC have not yet been approved, the intent is clear.

12.4 If the above plans from WBC and SHC are approved all the HGV modelling

conducted to date, if not already questionable, will be completely invalid. The

remaining unrestricted parts of the local road network (A573, A572 & A579) will

be burdened with the HGV traffic going to and from Parkside.



13 Summary & Conclusion

13.1 Mr John Lowe in his technical papers, refs: 1 & 2, has demonstrated that,

The traffic that the proposed developments could generate has been vastly

underestimated and estimated in a manner which the Government has

previously advised is not appropriate.

The under-estimated traffic for Parkside Phase 1 has also been used to

estimate traffic for Parkside Phases 2 & 3 further compounding the under-

estimation.

The trip rates used based on the single example of Florida Farm are not

reliable.

The traffic model is not validated and is not representing the actual situation.

Traffic forecasting has been conducted knowingly omitting committed

developments in a neighbouring authority.

The Inspectors, and subsequently the Secretary of State, therefore, have no

reliable information on which to make a judgement as to the acceptability of the

proposals.

13.2 PAG have further complemented Mr Lowe’s technical papers by demonstrating

that,

The local road network is not suitable for the traffic to be generated by a major

logistics development.

The local road network has not been accurately modelled.

The validation of the Parkside Link Road Traffic model has serious flaws and

has not been subject to independent rigorous review.

The ‘value for money’ of the Parkside Link Road is questionable and reducing.

The availability and reliance on public transport has been grossly exaggerated.

A neighbouring authority has raised serious objections that have not been

adequately addressed.

Proposed future highway changes will invalidate the already questionable

modelling conducted to date.

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