PLANNING APPEAL BY CHICESTER HOMES DEVELOPMENTS LIMITED IN RESPECT OF THE NON DETERMINATION OF A PLANNING APPLICATION FOR THE ERECTION OF 55 DWELLINGS ON LAND TO THE EAST OF SOUTH PARK BRAUNTON
WRITTEN STATEMENT ON HIGHWAYS / TRANSPORT ISSUES PREPARED BY M BAKER BSc CEng MICE FCIT FILT Eur Ing ON BEHALF OF LOVE BRAUNTON
PINS Reference: APP/X1118/W/16/3161459 North Devon Council’s Planning Application Reference: 61139
Technical Report 19201/1 April 2017
CONTENTS Page
1.0 Introduction 1
1.1 Preamble 1
1.2 Background 2
1.3 Structure of this Written Statement 2
2.0 The Proposal 4
3.0 Policy Context 6
3.1 Introduction 6
3.2 NPPF 6
3.3 Local Plan 8
3.4 Emerging Joint North Devon and Torridge Local Plan 9
4.0 The Issues 13
4.1 Introduction 13
4.2 Guidance on Transport Assessment 13
4.3 Preamble 15
4.4 The Application Process 16
4.5 The Transport Assessment 25
4.6 The Appellants’ Statement of Case 29
4.7 Summary 35
5.0 Summary and Conclusions 37
Appendices
DR/MB/A Photographs
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 1
1.0 INTRODUCTION
1.1 Preamble
1.1.1 This Written Statement on Highways and Transport Issues has been prepared by Mark
Baker of Mark Baker Consulting Limited of 32 Montpelier Court, Station Road,
Montpelier, Bristol BS6 5EA. I have a Bachelor of Science Degree with Honours in
Civil Engineering from the University of Newcastle upon Tyne. I am a Member of the
Institution of Civil Engineers, a Chartered Engineer, and a European Engineer. I am a
Fellow of the Chartered Institute of Transport, and of the Chartered Institute of Logistics
and Transport.
1.1.2 I am a Director of Mark Baker Consulting Limited. I have been involved in the fields of
transportation and traffic engineering since 1978. My experience covers the range
from urban highway design to major transportation studies both in the UK and
Overseas.
1.1.3 I have advised a wide range of clients including those in both the public and private
sectors in the UK, and Overseas Government Agencies. I have recently advised with
regard to the highways and traffic implications of a variety of residential, retail,
commercial, leisure and office developments.
1.1.4 I have been appointed by Love Braunton to prepare this Written Statement on
Highways and Transport Issues on their behalf. I am familiar with the site subject of
the Appeal, the surrounding highway network, and conditions on the adjacent and
surrounding highway network.
1.1.5 The evidence which I have prepared and provide for the Appeal in this Written
Statement is true and has been prepared and is given in accordance with appropriate
guidance of my professional institutions. I confirm that the opinions expressed are my
true and professional opinions.
1.1.6 This Written Statement should be read in conjunction with the various Statements
submitted by Love Braunton. This Written Statement is intended to supplement their
overall objection. This Written Statement refers to various documents submitted during
the course of the progression of the planning application, which are included within the
Appeal documentation, and which are not unnecessarily reproduced.
1.1.7 I should add at this point that I have used the term “Love Braunton” as an independent
objector group formed of a large number of local objectors. Individual objections have
also been submitted by individual members of Love Braunton with regard to the
planning application, and in respect of this appeal.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 2
1.2 Background
1.2.1 The Appeal is in respect of the non-determination of a planning application, North
Devon Council’s (the Council’s) planning application reference 61139, which is for the
erection of 55 dwellings on greenfield land to the east of South Park, Braunton. The
planning application being submitted by Chichester Homes Developments Limited.
1.2.2 The planning application was submitted on the 29th April 2016, and the applicants
appealed on the 21st October 2016 following the deferring of consideration of the
planning application at the 12th October 2016 Planning Committee. The site had been
subject of a site visit by the Council’s Planning Committee on the 1st September 2016.
1.2.3 The appeal proposals were reported to the Council’s Planning Committee on the 14th
December 2016 in order to determine the Council’s stance had the appeal not been
submitted. The Council resolved on the 14th December 2016 that had it been able to
determine the planning application that the planning application would have been
refused with two reasons for refusal.
1.3 Structure of this Written Statement
1.3.1 The detailed objections by others on highways and transport issues have variously
highlighted a number of areas of concern on highways / transport grounds namely,
i) The site has already been rejected in the emerging Local Plan process as site
reference BRA108,
ii) The roads providing access to the site are considered to be narrow roads in
part impacted upon by the presence of parked cars, and some with sub-
standard footway widths,
iii) The traffic generation is underestimated with the traffic survey within the
submitted TA being out of peak holiday season,
iv) The inadequate nature of Lower Park Road (as shown on plate 1), Heanton
Street (as shown on plate 2), Hill View (as shown on plate 3), and Wrafton Road
(as shown on plate 4) being single width in places due to the levels of parking
along their length in part, and various roads being used as rat runs at times to
avoid congestion on the A361 through Braunton (as shown on plates 5 and 6),
and
v) Inadequate public transport.
1.3.2 This Written Statement only considers the areas within my expertise i.e.: those that are
highways / transport related. This Written Statement should be read in conjunction
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 3
with all other objections to give a complete overview of the extent of the objection
covering all relevant disciplines.
1.3.3 This Written Statement is structured as following:
i) Section 2 considers the proposal in detail to set the context for this Written
Statement,
ii) Section 3 considers the relevant national and local policy context from a
highways / transport perspective,
iii) Section 4 considers the main issues and in particular the highway safety, and
access issues, and
iv) Section 5 presents the summary and conclusions of this Written Statement.
1.3.4 Appendix DR/MB/A contains photographs illustrating various points referred to within
this Written Statement for the ease of reference of the Inspector.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 4
2.0 THE PROPOSAL
2.1 The appeal is in respect of the non-determination of a planning application for 55
homes on greenfield land to the east of South Park, Braunton. The site adjoins
residential development on South Park to the west, and Lower Park Road to the north.
Two sections of South Park run to the boundary of the site on its western side.
2.2 The sole vehicular access is from South Park which can be used by both vehicles,
pedestrians and cyclists. Plate 7 shows the section of South Park proposed for the
site access. The site also abuts a separate section of South Park to the north, but
neither vehicular or pedestrian access is proposed at this location. This is illustrated
on plate 8. The Design and Access Statement (DAS) indicated that this access option
had been discounted as the more southerly access allowed traffic to be dispersed
within South Park more evenly.
2.3 The site has an existing single track access onto Lower Park Road that will be closed
off as part of the proposal as shown on plate 9. It would be wholly unsuitable for any
access to the site due to its inadequate width at barely 4.2m wide at the gate posts
which would not allow for an adequate road width to serve such a level of development
of 55 units plus adjacent footway widths. In addition, third party land on either side of
this corridor does not allow for the achievement of adequate levels of visibility splays
onto Lower Park Road of 2.4m by 43m in either direction. There is no other frontage
available by which to provide an alternative vehicular access.
2.4 The planning application is in outline with all matters being reserved for future
determination save for the means of access by all modes. The proposal indicates that
there would be 35% affordable units although there is a dispute as to whether this
represents 19 or 20 units. The numbers are not pertinent to my considerations. The
proposal comprises a mix of three, four and five bedroomed units for the open market
element, and one, two and three bedroomed for the affordable units. Full details of the
proposal were detailed in the DAS, which is submitted in respect of the appeal.
2.5 A Transport Assessment (TA) and a Travel Plan Statement both dated April 2016 were
prepared by Peter Evans Partnership, and have been submitted in support of the
planning application. Self-evidently we were not party to any Scoping Discussions that
may have occurred with the County Council prior to the preparation of the TA. In our
opinion, any agreement with the County Council regarding the TA does not alter the
validity that any third parties may have relating to the extent or assumptions embodied
within the TA itself.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 5
2.6 There are some significant reservations regarding the submitted TA and these are
considered in further detail in section 4.5 of this Written Statement.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 6
3.0 POLICY CONTEXT
3.1 Introduction
3.1.1 The relevant planning policy context against which the Appeal should be considered is
set out at national level in the National Planning Policy Framework (NPPF), and at the
local level being the saved policies of the Local Plan, and the policies of the emerging
North Devon and Torridge Joint Local Plan (eJLP).
3.2 NPPF
3.2.1 Paragraph 28 recognises that there is a need to provide a vibrant rural economy, and
indicates:
“To promote a strong rural economy, local and neighbourhood plans
should:
support the sustainable growth and expansion of all types of
business and enterprise in rural areas, both through conversion
of existing buildings and well designed new buildings;
promote the development and diversification of agricultural and
other land-based rural businesses”
3.2.2 With paragraph 28 in mind, NPPF introduces a degree of realism at paragraph 29
regarding the potential use of sustainable transport modes in such rural areas by
indicating:
“the Government recognises that different policies and measures will be
required in different communities and opportunities to maximise
sustainable transport solutions will vary from urban to rural areas.”
3.2.3 Paragraph 32 of the NPPF indicates that:
“All developments that generate significant amounts of movement
should be supported by a Transport Statement or Transport
Assessment. Plans and decisions should take account of whether:
the opportunities for sustainable transport modes have been
taken up depending on the nature and location of the site, to
reduce the need for major transport infrastructure;
safe and suitable access to be site can be achieved for all
people; and
improvements can be undertaken within the transport network
that cost effectively limit the significant impacts of the
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 7
development. Development should only be prevented or refused
on transport grounds where the residual cumulative impacts of
the development are severe.”
3.2.4 This Written Statement considers whether there are opportunities for the use of
sustainable modes of transport, whether a safe and suitable access to the site can be
achieved for all modes of travel, and whether the residual cumulative impact of the
development can be classed as severe. These issues being considered further in
section 4 of this Written Statement.
3.2.5 It is our conclusion as detailed subsequently that by reference to NPPF paragraph 32
the general location is one where the settlement provides the opportunity for access to
services and facilities but that the desirable and acceptable walking distances from this
site to such services and facilities are exceeded.
3.2.6 Furthermore, that a safe and suitable access is not achieved for all modes due to
deficiencies in the adjacent highway network in particular the deficiencies in road
widths at various locations, and the considerable levels of parked vehicles leading to
an inevitable increase in conflicts.
3.2.7 These issues leading to safety concerns, and in addition with the third bullet point in
mind it is contended for the various reasons outlined in the remainder of this Written
Statement that there is a severe impact of the proposal, and in particular that the
second issue constitutes one degree of severity with the impact at the A361 / B3231
traffic signals the other degree of severity. I should add at this point that there is no
definition of “severe” within either the NPPF, or the PPG, and it is for the decision
maker to define, which in this case is the Inspector.
3.2.8 In my opinion, the severe impact is notwithstanding the quantum of impact. This is
due to the inevitable increase in conflicts particularly locally where there are restrictions
in road width that do not allow for the free passage of vehicles, and where there are
restrictions in width. Vehicles are not able to wait to avoid such conflicts due to the
restricted widths where vehicles are parked leading to the inevitable increases in
reversing to adjacent informal passing spaces primarily at private accesses. There are
no formal areas along Wrafton Road where passing places to avoid parked cars are
provided. The only passing places being either gaps in the parked vehicles, or gaps
at private driveways as illustrated by plate 4. Plates 10 and 11 show typical scenes
along Wrafton Road illustrating for this section shown on plate 10 parking on both sides
of the road which measures of the order of 7m, and vehicles having to manoeuvre
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 8
between the stream of parked cars. Plate 11 shows the section which is generally
6.5m so that parking can only occur on one side.
3.2.9 Paragraph 34 of the NPPF indicates:
“Plans and decisions should ensure developments that generate
significant movement are located where the need to travel will be
minimised and the use of sustainable transport modes can be
maximised. However this needs to take account of policies set out
elsewhere in this Framework, particularly in rural areas.”
3.3 Local Plan
3.3.1 The relevant saved policies from the North Devon Local Plan 1995 to 2011 adopted
July 2006 are TRA1A and TRA6 though the accompanying text to the Local Plan forms
an important part of the Local Plan.
3.3.2 Policy TRA1A “Promoting Sustainable Transport Choices” is also relevant, and
indicates:
“1. A DEVELOPMENT PROPOSAL THAT WILL GENERATE A
SIGNIFICANT AMOUNT OF TRAVEL OR HAVE AN IMPACT
ON THE LOCAL HIGHWAY NETWORK WILL ONLY BE
PERMITTED IF IT WILL HAVE GOOD ACCESSIBILITY TO A
CHOICE OF TRANSPORT MODES INCLUDING WALKING,
CYCLING AND PUBLIC TRANSPORT IN ACCORDANCE
WITH A TRANSPORT ASSESSMENT OR STATEMENT.
2. IN ADDITION TO THE ABOVE, A NON-RESIDENTIAL
PROPOSAL MUST INCORPORATE A TRAVEL PLAN THAT
DELIVERS SUSTAINABLE TRANSPORT MEASURES.
3. EXISTING AND POTENTIAL PEDESTRIAN AND CYCLE
ROUTES, AS SHOWN ON THE PROPOSALS MAP, WILL BE
SAFEGUARDED FROM DEVELOPMENT.
4. IN THE CASE OF FLATS AND NON RESIDENTIAL
DEVELOPMENT, SECURE CYCLE PARKING AND, WHERE
APPROPRIATE, ASSOCIATED FACILITIES MUST BE
PROVIDED IN ACCORDANCE WITH TABLE 4.”
3.3.3 In my opinion, policy TRA1A is not conformed to for the principle reason that it does
not have in the context of distances to facilities good accessibility.
3.3.4 Policy TRA6 is entitled “General Highway Considerations”, and indicates:
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 9
“A DEVELOPMENT WILL ONLY BE PERMITTED WHERE:-
A) PROVISION IS MADE FOR SAFE ACCESS ONTO AND
EGRESS FROM THE HIGHWAY FOR ALL FORMS OF
TRAVEL SERVING THE SITE;
B) THE FUNCTIONING OF THE ROAD NETWORK OR THE
SAFETY OF HIGHWAY USERS IS NOT HARMED; AND
C) THE CHARACTER AND SETTING OF THE LOCALITY IS NOT
HARMED BY ANY HIGHWAY WORKS NECESSARY TO
ACCOMMODATE THE LEVEL OF TRAFFIC GENERATED BY
THE DEVELOPMENT.”
3.3.5 In my opinion, policy TRA6 is not conformed to for the reason that the functioning /
operation of the highway network will be adversely impacted upon without off-setting
highway improvements.
3.3.6 The references in the saved Local Plan to desirable walking distances contained at
table 3, and in the text at paragraph 6.10 are considered in detail in section 4.5 of this
Written Statement.
3.4 Emerging Joint North Devon and Torridge Local Plan
3.4.1 The emerging North Devon and Torridge Local Plan (eJLP) is at an advanced stage in
its process towards adoption. The hearing into the eJLP began in late November 2016.
3.4.2 DM05 “Highways” indicates:
“All development must ensure safe and well designed vehicular access
and egress, adequate parking and layouts which consider the needs
and accessibility of all highway users including cyclists and pedestrians.
All developments shall protect and enhance existing footways,
cycleways and bridleways and facilitate improvements to existing or
provide new connections to these routes where practical to do so.”
3.4.3 The explanatory text at paragraph 12.43 indicates:
“The transport impact of any development will need to be assessed, with
any impacts minimised through sustainable development principles,
such as creating genuinely safe and attractive routes for walking, cycling
and reaching local facilities with ease. Any residual impacts should be
minimised through practical measures, such as, but not limited to,
modification of the transport infrastructure to provide additional capacity,
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 10
or offsetting any impact through other measures including bus
infrastructure improvements.”
3.4.4 The text at paragraph 12.44 indicates:
“Development proposals that would give rise to significant levels of
vehicular movement must be accompanied by a Transport Statement
for smaller developments or a Transport Assessment for more
significant developments; these should be accompanied by a Travel
Plan appropriate to the scale and impact of the proposed development.
Guidance on the indicative thresholds for transport assessments is
provided in the national guidance, currently – the national ‘Planning
Practice Guidance.’”
3.4.5 Policy ST10 sets out the overarching transport strategy for North Devon. It inter alia
promotes providing infrastructure that facilitates the delivery of strategic housing,
protects strategic routes including the A361, and recognises the transport impacts from
seasonal traffic. In addition, the Policy aims to reduce environmental impacts by
reducing the need to travel by car and ensuring that access to new developments are
safe and appropriate.
3.4.6 The relevant parts of eJLP policy ST10 being:
“The Transport Strategy for northern Devon will:
(1) Provide good strategic connectivity by:
(a) ensuring the operational effectiveness of the strategic road
network (A361 and A30) and other strategic routes including the
A39, linking the area to the national road network (M5 and A30)
and to Exeter, Plymouth and Cornwall;
(b) maintaining the function of the wider strategic road network
within northern Devon”
3.4.7 This part of ST10 justifies packages of infrastructure works in order to maintain the
operational effectiveness of the highway network. There are none along the section
of the A361 from Braunton to Barnstaple proposed.
3.4.8 In addition ST10 indicates:
“(2) Meet the needs of local communities and visitors to the area by:
(a) providing transport infrastructure that facilitates the delivery of
proposed strategic extensions for housing and employment
development and facilitates economic regeneration;
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 11
(e) protecting and enhancing the function and safety of the road
network; and
(f) recognising transport impacts from the seasonal nature of traffic
in northern Devon.”
3.4.9 This part of ST10 supports the package of infrastructure improvements in order to
maintain the appropriate operation of the highway network, and supporting the concept
of infrastructure facilitating effectively housing and employment allocations. However,
no such measures are proposed locally to accommodate all other allocated sites either
within Braunton, or further afield to Ilfracombe that need to use the A361 to access a
wider range of services and facilities.
3.4.10 Furthermore:
“(3) Reduce the environmental and social impacts of transport by:
(a) reducing the need to travel by car and enabling alternative
sustainable travel options as supported by the Local Transport
Plan;
(c) requiring a Transport Assessment for major developments that
generate significant traffic movements and Travel Plans for
major developments;
(f) maximising safety on transport networks through improvements
to physical infrastructure design; and
(g) ensuring that access to new development is safe and
appropriate.”
3.4.11 This part of ST10 is consistent with the preceding sections confirming the approach of
defining a package of highways improvements, but there are none locally.
3.4.12 Policy ST23 relates to the delivery of infrastructure, and indicates:
“(1) Developments will be expected to provide, or contribute towards
the timely provision of physical, social and green infrastructure
made necessary by the specific and / or cumulative impact of
those developments having regard to the viability of
development.
(2) Where on-site infrastructure provision is either not feasible or not
desirable, then off-site provision or developer contributions will
be sought to secure delivery of the necessary infrastructure,
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 12
through methods such as planning obligations or the Community
Infrastructure Levy.
(3) Developments that increase the demand for off-site services and
infrastructure will only be allowed where sufficient capacity exists
or where the extra capacity can be provided, if necessary
through developer-funded contributions.”
3.4.13 This emerging policy confirms the approach followed by the County Council elsewhere
in their consideration of other applications by providing for off-setting highway
improvements that in this case need not be disproportionate for this development alone
to provide in total. No level of contribution to offset the impact on the A361 either at
the A361 / B3231 traffic signals or elsewhere has been sought by the County Council.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 13
4.0 THE ISSUES
4.1 Introduction
4.1.1 This section considers the traffic safety and access issues with particular reference to
the policy context both national and local considered in section 3.
4.1.2 The main issues at dispute for this appeal in my opinion are those within the context
of NPPF paragraph 32, and are summarised as:
i) The impact of the additional movements generated by the appeal proposal,
ii) The impact of those additional movements on the local highway network,
iii) Whether safe and suitable access to the site can be achieved for all users,
iv) Whether there is a severe impact, and
iv) Whether the proposal amounts to sustainable development.
4.2 Guidance on Transport Assessment
4.2.1 Guidance on the content of TSs, and TAs was contained within the Department for
Transport (DfT), and the Department for Communities and Local Government’s
(DCLG) publication “Guidance on Transport Assessment” (GTA) albeit this has
recently been revoked, and it is now for each highway authority to determine the
content, and the need for either a TS or TA based on their own thresholds. The County
Council however still follows the GTA.
4.2.2 The introduction at paragraph 1.4 of the GTA indicates that the GTA:
“is intended to assist stakeholders in determining whether an
assessment may be required and, if so, what the level and scope of that
assessment should be. It provides guidance on the content and
preparation of TAs and TSs.”
4.2.3 The guidance is clear at paragraph 4.50 of the GTA that:
“The assessment years should consider person trips from all committed
developments that would impact significantly on the transport network,
particularly where they substantially overlap, such as at the same
junctions and / or on roads as the proposed development. The
committed developments will typically include development sites that
have extant planning permission as well as development plan
allocations in an adopted or approved plan. Developments that have
been completed but not fully occupied should be included in these
assessments. The inclusion or exclusion of committed developments
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 14
in the assessments should be agreed with the relevant authorities at the
pre-application stage.”
4.2.4 In March 2014, the DCLG issued a suite of planning practice guidance notes (PPG) to
supplement the NPPF. Of relevance is that the PPG provides specific guidance on
“Travel Plans, Transport Assessments and Statements in Decision Making.” This
reiterates the approach of the revoked GTA.
4.2.5 Of particular note is the section of PPG that defines the periods of surveys for
subsequent assessment which is considered subsequently. PPG 42-013-20140306
dated 6th March 2014 indicates:
“Local planning authorities must make a judgment as to whether a
development proposal would generate significant amounts of
movement on a case by case basis (i.e. significance may be a lower
threshold where road capacity is already stretched or a higher threshold
for a development in an area of high public transport accessibility).
In determining whether a Transport Assessment or Statement will be
needed for a proposed development local planning authorities should
take into account the following considerations:
the Transport Assessment and Statement policies (if any) of the
Local Plan;
the scale of the proposed development and its potential for
additional trip generation (smaller applications with limited impacts
may not need a Transport Assessment or Statement);
existing intensity of transport use and the availability of public
transport;
proximity to nearby environmental designations or sensitive areas;
impact on other priorities/strategies (such as promoting walking and
cycling);
the cumulative impacts of multiple developments within a particular
area; and
whether there are particular types of impacts around which to focus
the Transport Assessment or Statement (e.g. assessing traffic
generated at peak times).”
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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4.2.6 PPG-42-015-20140306 also dated 6th March 2014 includes the information that should
be included in TAs, and TSs. The indication is:
“In general, assessments should be based on normal traffic flow and
usage conditions (e.g. non-school holiday periods, typical weather
conditions) but it may be necessary to consider the implications for any
regular peak traffic and usage periods (such as rush hours). Projections
should use local traffic forecasts such as TEMPRO drawing where
necessary on National Road Traffic Forecasts for traffic data.”
4.2.7 This section of the PPG is clear that non-school holiday periods should be assessed
when traffic conditions are more likely to be typical. The PPG also indicates that other
peak periods may be appropriate in addition, and not instead of typical conditions.
PPG 54-007-20141010 dated 10th October 2014 identifying data collection indicating:
“Transport data should be included that reflects the typical (neutral) flow
conditions on the network (for example, non-school holiday periods,
typical weather conditions etc.) in the area of the Plan, and should be
valid for intended purposes. It should also take account of holiday
periods in tourist areas, where peaks could occur in periods that might
normally be considered non-neutral. The recommended periods for
data collection are spring and autumn, which include the neutral months
of April, May, June, September and October.”
4.2.8 This section of PPG indicates that as well as typical or neutral conditions that a TA
should also (i.e. in addition) consider holiday periods. The consideration of holiday
periods being in addition to typical conditions rather than instead of it. The TA prepared
by Peter Evans Partnership as considered in section 4.5 has only considered the
holiday flows, and has therefore failed to fully assess the impact of the development
proposals.
4.3 Preamble
4.3.1 As detailed previously, the reference in the NPPF paragraph 32 is to planning
applications and it follows Appeals and the reference is to essentially refuse them only
“where the residual cumulative impact of developments are severe.”
4.3.2 There is however in guidance no clear definition of “severe” but there is often
considered to be a linkage to the second bullet point of paragraph 32 that requires
“safe and suitable access to the site can be achieved for all people.”
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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4.3.3 Access is holistically defined as being both the site access junction, and also all roads
that provide access from the wider highway network including in my opinion in this
case logically the A361 / B3231 traffic signals in the heart of Braunton. Plate 5 shows
a scene taken during the mid morning of conditions at the A361 / B3231 traffic signals.
Plate 6 shows the juxtaposition of the traffic signals to Heanton Street, and to the A361
pelican crossing. The two junctions represent a complex arrangement which is the
scene of frequents queues and delays in school term time, and congestion sometimes
severe in the school holiday periods.
4.3.4 There is nothing in NPPF, or the companion PPG that can be taken as implying that
“severe” represents as seemingly accepted by the County Council, and by the
appellants a particular quantum of impact either in absolute or percentage terms.
Previous guidance and the GTA advocated a 5% impact as being material, and 10%
in less congested areas, but those percentages that defined “material” impact have
now been revoked.
4.3.5 For reasons that will be outlined in this Written Statement it is my opinion
notwithstanding the quantum of impact that there is a severe impact in the following
regards:
i) The cumulative impact at the A361 / B3231 traffic signals and adjacent A361 /
Heanton Street junction,
ii) The cumulative impact along Wrafton Road due to the additional vehicles
generated by the proposal conflicting with other vehicles on the section of
Wrafton Road that is effectively single lane working due to the presence of
parked cars, and
iii) The impact on the section of Lower Park Road between Barn Field Close, and
South Park that is also a shared surface.
4.4 The Application Process
4.4.1 The planning application was submitted on the 29th April 2016, and the applicants
appealed on the 21st October 2016 following the deferring of consideration of the
planning application at the 12th October 2016 Committee. The site had been subject
of a site visit by Planning Committee on the 1st September 2016.
4.4.2 The application was reported to the Council’s planning committee on the 14th
December 2016 in order to determine the Council’s stance had the appeal not been
submitted. The Council resolved on the 14th December 2016 that had it been able to
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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determine the planning application that the planning application would have been
refused with two reasons for refusal.
The Parish Council’s Consultation Response
4.4.3 Braunton Parish Council’s consultation response dated 9th June 2016 recommended
that the planning application be refused on fourteen strands, and the objection of the
Parish Council as relevant from a highways / transport perspective is summarised as
being:
i) Accessibility
The Parish Council indicated:
“It is considered to be an unsustainable location for residential
development due to its lack of safe accessibility for pedestrian
connections to sustainable transport modes and local services”,
ii) Highway Infrastructure
The Parish indicated:
“The existing road network infrastructure leading to the
development via Moor Lea and Barn Field Close is inadequate
resulting in unsafe conditions”, and
iii) eJLP Considerations
The Parish Council indicated:
“In June 2014 the North Devon and Torridge Local Plan,
Sustainability Appraisal – Technical D: Assessment of Housing
Site Options for North Devon and Torridge, rejected this site
(BRA/108) for future housing development on the grounds that it
was unsustainable in terms of:-
- Increase in traffic through the village centre with
consequent impact on air quality; and
- Limited capacity along Lower Park Road and its junction
to accommodate the development.”
4.4.4 Following the submission of amended plans, the Parish Council submitted a further
consultation response on the 26th August 2016 which indicated:
“Braunton Parish Council wish to recommend refusal, the amended
plans received do not change the Council’s earlier views and therefore
its previous reasons for refusal still stand. In addition to this, as it is a
Greenfield site, taking into account further sustainable information
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Technical Report 19201/1 April 2017
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provided the Council strongly feels that the development should be
aiming for a much higher level of sustainability.”
Braunton Access Group Consultation Response
4.4.5 The Braunton Access Group were also consulted, and indicated on the 24th May 2016
that they had concerns on the following grounds:
“There are no Public Transport links covering the area at the present
time resulting in a dependence on motor vehicles. As Mill Lane public
footpaths runs along the eastern boundary could consideration be given
to up-grading this to an all year round surface foot path to allow easy
access for pedestrians & wheelchair users.
Any road without a pavement is on concave road means pushing at an
angle or going down the middle of the road, this is a safety issue for
wheelchair users and their carers.
The access along lower park road (sic) is of grave concern, buggies and
wheelchairs often go along – there is no pavement for quite some
distance, when there is, the dropped kerbs are not in the right place so
most of users (sic) just stick to the road.
Would it be possible to allocated some 106 money to upgrading the
pavements in Lower Park Road and Mill Lane?”
County Council’s Consultation Response
4.4.6 The County Council’s consultation response dated 28th June 2016 did not raise an
highways objection subject to:
“1) The sum of £55,000 for improvements and maintenance of the
existing Public Right of Way No. 18 (Mill Lane) to the east of the
application site, in order to improve the sustainability of
pedestrian users of the application site;
2) The sum of £250 per dwelling to be utilised for Public Transport
vouchers, and
3) The sum of £50 per dwelling to be utilised towards bicycle
provision.”
4.4.7 There were a total of eight conditions recommended by the County Council to be
incorporated onto any planning approval to cover:
i) Infrastructure to be completed in accordance with details to be submitted, and
approved,
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Technical Report 19201/1 April 2017
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ii) Infrastructure to be constructed in accordance with a detailed programme to be
submitted, and approved,
iii) No part of the development to be occupied until the first 20m of the access has
been constructed up to base course,
iv) The development to be occupied in an agreed phasing with a schedule of
infrastructure to be provided,
v) The maintenance of the access and turning heads etc to be kept free of
obstruction,
vi) Within twelve months of the first occupation the completion of all infrastructure,
vii) Disposal of surface water within each dwelling curtilage, and
viii) Parking.
September Committee Report
4.4.8 In the Council’s Committee Report of the 1st September 2016 the issue of the SHLAA
process was considered in some detail, and I repeat various points to highlight the
transport / highways issues. The report indicated the Planning Policy’s consultation
response which identified:
“The site has been included within the SHLAA (SHA/BRA/108) for 42
dwellings on a net developable area of approximately 1.4 hectares at
30 dph. For information, when the SHLAA Panel first considered this
site in 2010 they were satisfied with the overall assessment and agreed
with the recommendation that ‘development of this site would be a
logical extension to the east side of Braunton.’ Whilst the SHLAA
recommendation has guided the overall level of housing development
across this site there is no policy objection to a higher number of
housing units being delivered if the principle of development was
considered acceptable on this site and any increase in numbers would
not have an adverse impact on surrounding residential properties and
landscape character as well as helping to deliver the spatial vision and
strategy for Braunton and Wrafton as set out within Policy BRA of the
emerging Plan.
Although the site was considered developable in principle, it was not
taken forward as an allocation within the emerging Local Plan.
Technical Document D of the Sustainability Appraisal (SA) assessed a
number of alternative housing options, where a number of these were
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Technical Report 19201/1 April 2017
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rejected as less sustainable options for future housing development.
The document including those sites that did not deliver key
infrastructure and strategic objectives and the main reasons for which
they were rejected. It identified issues relating to broad areas rather
than precise sites and it recognised that defining the extent of a site in
greater detail could help to mitigate some of the identified impacts but
not the fundamental concerns in terms of sustainability and
deliverability. One of these rejected sites was land at South Park where
it was concluded:
Land to the east of South Park was rejected because of sustainability
issues in terms of:
Increase in traffic through the village centre with consequent impact
on air quality;
Limited capacity along Lower Park Road and its junctions to
accommodate development where the highway is narrow with
limited opportunities to increase capacity;
No existing transport links with the village or pedestrian footpaths
along Lower Park Road; and
Key Network Feature along Mill Lane forming site eastern boundary.
In regard to the above conclusions within the SA, of particular concern
in policy terms is the limited highway capacity of the approach roads /
junctions to South Park and air quality management concerns within the
village centre (Policies TRA1A, TRA6, ST10, DM02, DM05). I would
consider that the application should be accompanied by an air quality
assessment in order to assess what the impacts may be from this
development on the air quality management area and how any impacts
will be mitigated. The contents of this report should be assessed in
consultation with Andy Cole from Environmental Health. However, the
Highway Authority should advise as to whether the local highway
network can accommodate the additional traffic movements without
having an adverse detrimental impact on the highway issues
concerned.”
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Technical Report 19201/1 April 2017
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SHLAA Proforma Assessment
4.4.9 In terms of the history, the SHLAA site assessment form was based on a site visit on
the 25th January 2010. The SHLAA assessment indicated the planning history with
relevant applications being C108329 in 2013, and C106361 in 2012. The assessment
indicated that: “Site is currently outside of the defined development boundary but well
related to Braunton.” The assessment also indicated that with regards to public
transport that: “Braunton is well served, but the site is approximately a kilometre from
the nearest route through the village centre.” With regard to access to services and
facilities the assessment indicated: “A kilometre from the village centre. Good
accessibility to higher order centres.”
4.4.10 However in terms of highway access, the response was:
“Yes from South Park, although junctions on Lower Park Road need to
be assessed.
DCC Highways: 1) The increased use of the junction, resulting from the
proposed development would, by reason of the limited visibility from and
of vehicles using the junction, be likely to result in additional danger to
all users of the road and interference with the free flow of traffic.
2) Lower ParkRoad from which access to South Park is gained is, by
reason of its inadequate width, junctions and lack of footway provision,
unsuitable to accommodate the increase in traffic likely to be
generated.”
4.4.11 The overall consideration at that stage was: “Development of this site is a logical
extension to the east side of Braunton.” However, this is only the consideration of the
SHLAA proforma, and a further detailed assessment followed as detailed in the
Committee Report confirmed that despite the proforma assessment that the site has
been rejected from the eJLP for amongst other reasons three sustainability issues:
i) The increase in traffic through the village centre with the consequent impact on
air quality,
ii) Limited capacity along Lower Park Road and its junctions to accommodate the
development where the highway is narrow with limited opportunities to increase
highway or network capacity, and
iii) No existing transport links with the village or pedestrian footways along Lower
Park Road.
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Technical Report 19201/1 April 2017
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October Committee Report
4.4.12 The 12th October 2016 Committee report indicated under the summary of the issues
within respect to highways issues:
“Much comment has been made on traffic related issues including: the
narrow access road; both accesses from South Park should be opened;
traffic generation has been underestimated (8 peak movements);
additional air pollution; pedestrian conflict with vehicles related to school
children and the junction outside; lack of pavement for a stretch of
Higher Park Road; noise; the impact of construction traffic; the physical
constraints of Lower Park Road / Heanton St/Wrafton Rd being single
width in places, having on road parking, congestion and use as ‘rat-run;
Lack of public transport; and, the condition/impact of drainage on Mill
Lane.
The application is accompanied by a Transport Assessment and Travel
Plan.
The TA concludes that:
The location of the site is accessible for pedestrians, cyclists and
public transport users and integrates with the surrounding
residential area. Therefore the site is in line with national and local.
Walking distances to schools and local amenities are well within the
boundaries of the acceptable walk distance to education facilities set
out by the CIHT Guidelines ‘Providing for Journeys on Foot’.
The small increase in vehicular flows on the local road network as a
result of the proposed development is minimal and would not give
rise to a material impact on existing traffic and safety conditions.
The cumulative impact of the development would not be severe and
thus should not be refused on transport grounds in line with NPPF.
The Local Highway Authority accepts these conclusions and
recommends conditions and a contribution towards improvements
towards Mill Lane.”
4.4.13 The recommendation at that stage being:
“The planning balance is a fine one and arguable given the need to take
into account a range of benefits and dis-benefits. The NPPF advises
that planning applications should be approved unless any adverse
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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impacts of doing so would significantly and demonstrably outweigh the
benefits, when assessed against this Framework or taken as a whole.
On applying that balance your officers consider that the benefits in
particular of contributing to housing land supply would be substantial in
addition to the other economic and social benefits noted. In the absence
of demonstrably adverse impacts that would significantly or
demonstrably outweigh these benefits it is concluded that the present
proposal represents sustainable development that in accordance with
the presumption in favour of sustainable development suggests that the
application should be supported and planning permission granted.”
4.4.14 The conclusions also indicated:
“The location of this site is accessible for pedestrians (albeit a section
of Higher Park Road has no pavement), cyclists and public transport
users and accords with recommended walking distances to local
amenities whilst the additional traffic generation is not considered such
as to give rise to result in a severe cumulative impact. A contribution is
to be made towards the adjoining PROW.”
4.4.15 The recommendation being of:
“In summary, the site has been identified as developable in the longer
term in the SHLAA exercise that underpins the emerging Local Plan. It
is not however considered necessary to bring the land forward at this
stage given its omission from either the adopted or the emerging
development plan and given outstanding objections raised in particular
by the Council’s Countryside and Landscape Officer on landscape and
ecology grounds. These concerns suggest that a redesigned layout is
required in order to overcome the objections which may in turn result in
a reduction in housing numbers. However, the present application has
progressed to appeal against non-determination and the opportunity to
review the layout and associated ecological mitigation and landscaping
on a ‘without prejudice’ basis has not been progressed.”
December Committee Report
4.4.16 The later 14th December 2016 Committee Report indicated an alternative summary of
the highways issue compared to the 12th October 2016 Committee Report indicating:
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
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Technical Report 19201/1 April 2017
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“Policy TRA6 deals with general highway considerations and requires
that a development will only be permitted where:
a) provision is made for safe access onto and egress from the
highway for all forms of travel serving the site;
b) the functioning of the road network or the safety of highway
users is not harmed; and
c) the character and setting of the locality is not harmed by any
highway works necessary to accommodate the level of traffic
generated by the development.
Much comment has been made on traffic related issues including: the
narrow access road; both accesses from South Park should be opened;
traffic generation (8 peak time movements) has been underestimated;
additional air pollution; pedestrian conflict with vehicles related to school
children and the junction outside; lack of pavement for a stretch of
Higher Park Road; noise; the impact of construction traffic; the physical
constraints of Lower Park Road / Heanton St/Wrafton Rd being single
width in places, having on road parking, congestion and use as ‘rat-run;
Lack of public transport; and, the condition/impact of drainage on Mill
Lane. Objectors have submitted their own traffic surveys.
The application is accompanied by a Transport Assessment and Travel
Plan.
The TA concludes that:
The location of the site is accessible for pedestrians, cyclists and
public transport users and integrates with the surrounding
residential area. Therefore the site is in line with national and local
(sic).
Walking distances to schools and local amenities are well within the
boundaries of the acceptable walk distance to education facilities set
out by the CIHT Guidelines ‘Providing for Journeys on Foot’.
The small increase in vehicular flows on the local road network as a
result of the proposed development is minimal and would not give
rise to a material impact on existing traffic and safety conditions.
The cumulative impact of the development would not be severe and
thus should not be refused on transport grounds in line with NPPF.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
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on behalf of Love Braunton
Technical Report 19201/1 April 2017
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The Local Highway Authority accepts these conclusions and
recommends conditions and a contribution towards improvements to
Mill Lane.
In response to questions raised by an objector about the LHA view, the
Highways Officer has commented ‘When considering the impact of
development upon the local highway network this Authority has to
consider any material impacts and the degree to which capacity and/or
safety is likely to be a consideration. I appreciate there are variations
in respect of traffic generation on a daily, weekly and monthly basis. I
believe the Transport Assessment has considered the impact of the
development and identified additional flows that are likely to be taking
place within ‘Wrafton Road’ amongst other roads. Both the figures put
forward by the developers consulting engineers, and yourselves, are
unlikely to lead to capacity issues and, therefore, DCC will not be
requesting detailed capacity analysis to be undertaken at the various
junction (sic). This is partly given on the basis of knowledge of the local
area and traffic conditions.
It is also reasonable to assume that a number of traffic movements will
leave ‘South Park’ and head eastwards if travelling to Barnstaple
avoiding ‘Wrafton Road’ altogether.
Without repeating the conclusions contained within the Transport
Assessment I have indicated previously I agree with such findings
based on the evidence put forward.
It is, of course, available to third parties to put forward an alternative
view, with or without professional representation, into the process.’
The DCC Highways Officer (who is unable to attend the meeting), has
been asked to comment further on questions raised about the
conclusions reached by the applicant’s highways consultant, but at the
time of compiling this report no response had been received from DCC.
On the basis that the LHA continue to raise no concern on traffic related
matters, it is concluded that the Policy will be satisfied.”
4.4.17 The Council resolved on the 14th December 2016 that they were minded to refuse the
planning application if they had jurisdiction, and there were two non-highways reasons
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Technical Report 19201/1 April 2017
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for refusal namely the non allocation of the site in the Local Plan, and in the eJLP, and
the percentage of affordable housing.
4.5 The Transport Assessment
Preamble
4.5.1 A TA dated April 2016 was prepared by Peter Evans Partnership, and submitted in
support of the planning application. In our opinion, any agreement with the County
Council regarding the TA does not alter the validity that any third parties may have
relating to the extent or assumptions embodied within the TA itself. Concerns raised
by third parties who have to live with the consequences of development are valid to be
considered, and should be afforded appropriate weight. I am confident that the
Inspector does not need to be reminded of this.
4.5.2 There are some significant reservations regarding the submitted TA and these are now
considered.
Traffic Surveys
4.5.3 The TA included the results of manual classified counts undertaken on Friday 28th and
Saturday 29th August 2015 at the South Park / Lower Park Road junction, and at the
A361 Exeter Road / B3231 Caen Street / East Street / South Street / Heanton Street
signal and priority junctions.
4.5.4 The applicant referred to all links but in fact there are two very closely related junctions
of the A361 / B3231 “The Square” comprising a four armed junction of the A361 Exeter
Road from the south, the B3231 Caen Street from the west, the A361 Chaloner’s Road
from the north, and East Street to the north east with approximately 30m to the south
of The Square is the staggered junction of the A361 Exeter Road to the south, South
Street to the west, the A361 Exeter Road to the north, and Heanton Street to the east.
4.5.5 The TA also included traffic data for the Lower Park Road / South Park junction though
being located to the east of Barn Field Close, these surveys do not reflect general flow
levels on Lower Park Road between Hill View, and Barn Field Close. Data being
collected for these junctions between 07.30 to 11.00, and 14.30 to 18.30.
4.5.6 The indication within the TA was that these periods and days were chosen as this
represented a peak event but this is no substantiation of this assertion within the TA,
and this is a significant failing of the submitted TA. Seemingly additional data was
collected in school term time but not presented in the TA as detailed below. The data
period is not representative using the advice in the companion guide to the National
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Technical Report 19201/1 April 2017
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Planning Policy Framework (NPPF), the Planning Policy Guidance (PPG). No data for
typical conditions have been provided.
4.5.7 The TA indicated a.m. peak hour and p.m. peak hour total junction flows of 1391, and
1648 vehicles per hour for the Friday for the A361 / B3231 junction. No surveys were
undertaken of queue lengths, or of average delays to vehicles using the junction. No
detailed impact assessment of the impact of the development at this location were
undertaken subsequently in the TA.
4.5.8 The TA included scant details of an automatic traffic counter for a week commencing
15th September 2015 but there is no data included in the appendices, and as such it
has not been possible to consider the data for in school term time compared to school
holidays. The TA asserts that speeds are low but there is simply no factual data to
verify this. Speeds also are only given for one direction of 27 mph. Third parties as
detailed subsequently in this Written Statement have assessed the differences, and
their survey results are significantly greater.
Walking Distances to Services and Facilities
4.5.9 The TA defined the desirable target walking distances from the saved Local Plan at
table 3 to facilities at paragraph 3.2.6, and indicated:
Facility Walking distance
Food shop 300m
Primary school 300m
Other non-residential facilities 600m
Bus stop 200m
4.5.10 The commentary to the saved Local Plan paragraph 6.20 indicated:
“The target desirable cycling distance between a development and key
facilities is 30 minutes which equates to approximately 8 kilometres
depending on the topography and conditions. Based on the interim
standards contained in the Regional Transport Strategy, desirable
walking distances are set out in Table 3 in order to assess the
accessibility of a development. For residential developments, these set
out the target distances within which facilities are considered to be
within reasonable walking distance. For non-residential developments,
the distances define the pedestrian catchment area of the
development.”
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Technical Report 19201/1 April 2017
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4.5.11 The TA at paragraph 3.3.2 in an attempt to argue that the values above were
inappropriate also detailed the CIHT “Guidelines for Providing Journeys on Foot” which
indicate:
Suggested Acceptable Walking Distances
Town Centres Community / School Elsewhere
Desirable 200m 500m 400m
Acceptable 400m 1000m 800m
Proposed Maximum 800m 2000m 1200m
4.5.12 In this regard, although the statutory maximum distance for walking to school for
children below 8 years is 3.2km before the education authority must provide transport,
that is not a desirable or even generally acceptable distance for a pedestrian to walk.
Table 3 of desirable walking distances on page 48 of the North Devon Local Plan 1995
to 2011 adopted in July 2006 (the Local Plan) as detailed at paragraph 4.5.9 are
unrealistically optimistic.
4.5.13 Table 3.2 of the CIHT’s “Guidelines for Providing for Journeys on Foot” regards walking
distance for commuting, to school and for sightseeing as a desirable 500m, an
acceptable 1,000m and a maximum 2,000m and for other purposes as a desirable
400m, acceptable 800m and a maximum of 1,200m. The Manual for Streets also
advises that walkable neighbourhoods are typically characterised by having a range of
facilities within 10 minutes’ (up to about 800m) walking distance of residential areas
which residents may access comfortably on foot and refers to now withdrawn
Government advice to the effect that walking has the greatest potential to replace short
car trips particularly those under 2km. The TA accepts at paragraph 5.2.2 that the
distances to the schools are further than target distances. The TA also accepts that
the walk to bus services are well beyond target, and that there are no late evening or
Sunday bus services.
Trip Rates Assessment
4.5.14 The trip rates derivations were shown in appendix 8 of the TA, and are summarised
as:
Arrivals Departures
A.M. Peak 7 21
P.M. Peak 19 10
4.5.15 The assessment has been undertaken using TRICS in a standard methodology.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
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Technical Report 19201/1 April 2017
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Trip Distribution
4.5.16 The vehicular distribution of the traffic generated by the development by route being:
A361 South towards Barnstaple via Wrafton Road 72%
B3231 towards Saunton Sands and Croyde 10%
A361 North towards Ilfracombe via Hill View (towards Ilfracombe only)
or the A361 traffic signals 17%
Lower Park Road East 1%
4.5.17 The distribution has been based on 2011 journey to work census data, and again there
is no great dispute with this which is industry standard. However, it is very curious to
say the least that the TA has not assessed the impact of 72% of all vehicles routing
via Wrafton Road, and despite third party concerns this issue was not assessed in the
appellants’ two Statements. We have undertaken that sole assessment, and our
conclusions are very clear.
Construction Traffic
4.5.18 The applicants accept that a Construction Management Plan is needed, and seemingly
anticipate that vehicles will use Wrafton Road where the road width remaining from
parked cars is limited, and where there would be an impact on the Southmead Primary
School, and Braunton Academy. Construction traffic cannot route via Heanton Street
as at 4.1m to 4.2m wide cars could not pass any construction vehicle on this link.
Construction vehicles cannot route along Lower Park Road from the east. On this
basis, the appeal should be dismissed as there is no scope for the safe routing of
construction vehicles of the quantum to construct such a sized development.
Additional Responses
4.5.19 Two additional reports were prepared by Peter Evans Partnership in response to the
Planning Officer’s queries dated 5th October 2016, and to the matters raised by Sue
Prosper dated 25th November 2016. Commentary on these documents is variously
contained in this Written Statement.
4.6 The Appellants’ Statement of Case
4.6.1 I have considered the appellant’s Written Statement dated October 2016 prepared for
this Appeal which has a total of eight sections, and a subsequent Addendum which
was dated February 2017. No separate highways / transport case was submitted in
respect of the appeal. Paragraph 1.12 detailed the case for the appellant which
included no reference whatsoever to the highways / transport issues, and this is rather
curious given that at that stage that the Council has not issued their putative reasons
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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for refusal, and as such the appellants should have provided evidence on all relevant
issues. That said highways issues are included as paragraphs 7.7.3 to 7.7.8 of the
original Statement.
Accessibility
4.6.2 The appellant’s proposition 6 at paragraph 7.6.1 of their Statement of Case is that “this
proposal will be for a sustainable development.” The text at paragraph 7.6.1 indicates:
“The sustainability credentials of the appeal proposals are not in
dispute. The appeal site is well located in relation to existing shops,
services and facilities, including schools and open space and is
therefore a suitable and sustainable location for housing. This is
confirmed by the Council’s SHLAA assessment of the appeal sites (sic)
which concludes that “development of this site is a logical extension to
the east side of Braunton” and the officer report attached as Appendix
3.”
4.6.3 It is generally accepted that Braunton has a range of services and facilities appropriate
to its status. There is some dispute, by others, regarding the capacity of the local
schools to accommodate the levels of school children generated by the development.
However, as detailed elsewhere in this Written Statement there are reservations about
the quality of the footway linkages, and the overall distances to some of the services
and facilities. For example, the nearest bus stops are over two and a half times the
distances usually considered as desirable. Once reached there are no late evening or
Sunday services that will also affect their propensity for use. The first service on the
21A route through Braunton is at 07.30 with the last at 20.58. There is no contribution
to improve the services, and these times would be unattractive to those that may have
employment in Barnstaple other than in the town centre itself.
4.6.4 The access and movement issues are considered in further detail in paragraphs 7.7.3
to 7.7.8, and it is prudent to consider each paragraph with our summary retort following.
Traffic Surveys
4.6.5 Paragraph 7.7.3 indicates:
“An assessment of the traffic movements and roads in and around the
site has been undertaken, along with pedestrian routes between the site
and village’s facilities. This is set out within the Transport Statement.”
4.6.6 The TA set out details of a traffic survey undertaken on a Bank Holiday weekday but
despite the passage of time between the surveys, and the date of submission of the
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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TA there was no check survey undertaken by the appellants / applicants of traffic
conditions for a typical weekday in school term time. There is reference to automatic
traffic counts being undertaken but there are no details of the results. The surveys
summarily are not in accord with the advice in the PPG which advocates both seasonal
peaks, and typical conditions being assessed for such locations.
4.6.7 Despite repeated requests by the objectors for the supply of the data, it has not been
forthcoming, and this has led to the objectors undertaking their own surveys which are
at the some variance to those contained within the TA. In some case, there are I
should add significant variations to the data collected on behalf of the applicants now
the appellants. The Love Braunton objectors are the only group that have undertaken
any form of check traffic survey data, and the appellants have not sought to dispute
any of the data collected by third parties.
4.6.8 Notwithstanding this the applicants’ data for Heanton Street appears erroneous with
an indication of 6 vehicles per hour in the morning peak, and 4 vehicles per hour in the
evening peak. These values have to be seen in the context of the limited photographs
of this Written Statement which cast considerable doubt on these values. If these
values are correct this development using the applicants’ distribution will lead to a
doubling of traffic flows on this link.
4.6.9 As detailed in the letter from D Relph to the Council on the 3rd October 2016, traffic
flows on Wrafton Road in school term time of 206 vehicles per hour southbound, and
101 vehicles per hour northbound between 08.00 and 09.00 on the 13th June 2016
within school term time. “The Studies of Delays to Traffic on Single Lane Carriageways
with Passing Places” undertaken by TRRL indicates:
“Results from TRRL studies indicate that simply in terms of their capacity
for carrying moving traffic single lane carriageways, correctly designed,
are unlikely to incur significant increases in delay compared with traffic
in free-flow conditions, at flow levels of up to 300 vph (total two way).”
Wrafton Road operates as single track but has no formal passing places, and flows
are above this threshold currently. The addition of the development traffic will increase
delays, and conflict potential.
4.6.10 Paragraph 7.7.4 indicates:
“The site is within a 15 minutes walking distance of the village centre
and the bus stops on the A361. It is also within a 10 minute walk to and
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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from the nearest primary and secondary schools located on Wrafton
Road.”
4.6.11 Using the guidance referred to within the MfS the village centre, school, and local bus
services are all outside the MfS “walkable neighbourhood” definition. All of the facilities
are also well outside of the target distances of the adopted Local Plan. The majority
of the services and facilities are above the desirable and acceptable distances, and
some are above the maximum walk distances contained within the CIHT “Guidelines
for Providing Journeys on Foot”.
4.6.12 Paragraph 7.7.5 indicates:
“Vehicular access to the site will be provided from a continuation of
South Park eastwards. Pedestrians will also be able to use a footpath
link to Mill Lane to the south.”
4.6.13 Plates 12 and 13 show the general condition of Mill Lane showing its unsuitability for
use other than in a recreational role. Whilst Plate 14 shows Chicken Lane that provides
a link between Curve Acre and Wrafton Road providing a shorter walk to Southmead
Primary School, and to Braunton Academy though Chicken Lane itself suffers from no
overlooking, and as such poor levels of natural surveillance, and it has no street lighting
where not overlooked that will affect its propensity for use, and potentially impact upon
the safety of users.
4.6.14 South Park provides access to the site via Barn Field Close, and Moor Lea to the west,
or via South Park to the east. Plate 7 shows the proposed access point, and indicates
the context of the remainder of the estate that the proposal would be seen as an
extension to. Plate 15 shows a view along Moor Lea showing the existing traffic
calming to constrain vehicle speeds through the development. Even without the
additional traffic burden of the proposed development, there appears to be a historic
concern about vehicles through the estate that has led to the introduction of traffic
calming.
4.6.15 The use of Barn Field Close, and Moor Lea resulting in an increase in vehicle
movements through a residential development. The use of Barn Field Close results in
an intensification in the use of the Lower Park Road / Barn Field Close junction where
traffic associated with the care home frequently parks on the north side of Lower Park
Road forcing Lower Park Road into single lane working as shown on plate 16. The
use of South Park to the east would increase traffic along Lower Park Road between
South Park and Barn Field Close where the road is shared surface generally of the
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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order of 4.6m to 5.0m wide with no footway provision as shown on plate 17. A road
width using MfS figure 7.1 of 4.6m allows two cars to pass with 5.0m allowing a
commercial vehicle to pass a car. Assuming the width for the various pedestrian types
from figure 6.8 any pedestrians on this section of Lower Park Road would result in
vehicles being unable to pass one another. There are no safe places for pedestrians
to step aside apart from at private driveways.
4.6.16 Paragraph 7.2.14 of MfS indicates:
“Subject to making suitable provision for disabled people, shared
surface streets are likely to work well:
In short lengths, or where they form cul-de-sacs;
Where the volume of motor traffic is below 100 vehicles per hour
(vph) (peak); and
Where parking is controlled or it takes place in designated areas.”
4.6.17 Lower Park Road is not a cul-de-sac, and carries some levels of through traffic.
Additionally, there is over this section no control of parking. The research into shared
surfaces on page 83 of MfS indicates:
“A study of public transport in London Borough Pedestrian Priority Areas
(PPAs) undertaken by TRL for the Bus Priority Team at Transport for
London concluded that there is a self-limiting factor on pedestrians
sharing space with motorists, of around 100 vph. Above this,
pedestrians treat the general path taken by motor vehicles as a ‘road’ to
be crossed rather than a space to occupy. The speed of vehicles also
had a strong influence on how pedestrians used the shared area.
Although this research project concentrated on PPAs, it is reasonable
to assume that these factors are relevant to other shared space
schemes.”
4.6.18 The general width is shown on plate 1 near South Park looking to the west, and plate
19 looking eastwards. Plate 19 is on the approach to Barn Field Close showing that
there is no verge for pedestrians to step onto. The relatively straight nature of Lower
Park Road does not constrain vehicular speeds. Parked cars are a hazard along
Lower Park Road as shown on plate 20 affecting Barn Field Close, and on plate 21 on
first entry from Wrafton Road.
4.6.19 Reference is drawn to Mill Lane, which is not on any great logical pedestrian desire
line. Notwithstanding its present surfacing, and lack of lighting coupled with very
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 34
limited overlooking, the use of the lane would not be logical to use to reach the nearest
primary or secondary school, or to access the services and facilities in the centre of
the village, or to access bus services.
4.6.20 Paragraph 7.7.6 indicates:
“The development will generate around 28 additional vehicles on South
Park in the morning and evening peak hours. On a Saturday lunchtime
peak an additional 20 vehicles would travel along South Park. An
additional vehicles every 2-3 minutes at peak times would not be
noticeable.”
4.6.21 It is noted that the applicants now the appellants have used industry standard software
in terms of the TRICS database, and I have no great reason to dispute their selection
criteria in that assessment. In addition they have used journey to work census data to
define likely distribution of trips, and modal share. There is nothing unusual about this.
The additional vehicles have however to be seen in the context of background traffic
flows. Given the character of the roads, and the shared surface nature this is disputed.
4.6.22 Paragraph 7.7.7 indicates:
“Based on the likely routes taken an additional 8 cars are likely to travel
through the centre of Braunton in the morning and evening peak hours.
This is compared to the 1600 vehicles recorded travelling through the
town centre in peak hours during the busy summer holidays. The
increase is less than 1% and is within typical daily variations, so no
difference in traffic would be observed.”
4.6.23 The distribution in the TA indicates that 72% of all residents would route towards and
from Barnstaple via Wrafton Road. 1% is predicted within the TA to use Lower Park
Road to the east routing along country lanes to reach destinations whilst 27% of all
residents use other routes including Croyde and Ilfracombe. For travel towards Croyde
and Saunton Sands, the only logical route is via the A361 / B3231 traffic signals which
is predicted by the appellants to be 10% of all residents. The remaining 17% is bound
to or from Ilfracombe to the north. Hill View avoids the use of the A361 / B3231 traffic
signals to travel towards Ilfracombe but it is narrow in width with parked vehicles along
most of its length reducing it to single lane working as shown on plate 3. There is also
a 6ft 6in width restriction at its northern end where it is also one way northbound and
as such traffic from Ilfracombe towards the site has no option but to route through the
traffic signals. From Lower Park Road, the traffic signals are reached via Heanton
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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Street that is 4.1m wide with a footway for its most part of 1.1m wide as shown on plate
22. As indicated on figure 7.1 of MfS this road width is only adequate for two cars to
pass, and plate 22 clearly indicates that cars cannot pass commercial vehicles.
Heanton Street is not a part or does not constitute an arm of the signal controlled
junction but forms a priority junction approximately 30m to its south at a complex
arrangement. Traffic leaving Heanton Street at peak hours has to rely on either the
adjacent pelican crossing being used, and no vehicles blocking the junction, or vehicles
on the A361 being courteous. Either operation causes an issue. Firstly if vehicles pull
out when the pelican is used, it consequentially increases the queue length on the
A361 northbound arm, and secondly if a vehicle is let out by a courteous driver this
can result in less vehicles being able to turn right from Croyde or travel along the A361
from the north.
4.6.24 Paragraph 7.7.8 indicates:
“The County Highways Authority has no objections to the appeal
proposals subject to conditions and contributions being secured
towards improvements to the adjoining public right of way and travel
plan measures.”
4.6.25 There is in section 8 “Concluding Remarks” no specific reference to highways and
transport issues save for that many be construed by the fifth bullet point viz:
“the very limited harm that would arise from the appeal proposals does
not significantly and demonstrably, nor in any way, outweigh the very
clear and substantial benefits it would deliver”
4.6.26 The appellants’ Statement of Case omits any detailed reference to Wrafton Road. The
indication is one additional vehicle every three minutes but this does not acknowledge
that Wrafton Road operates for most of the day as single track. The quantum of
increase will lead to inevitable additional conflicts.
4.6.27 Wrafton Road is not an A road nor a B road, it is a residential road with frontage access,
and two schools along its length. In addition, it has a public house, a social club, and
a retail unit.
4.6.28 It is generally 6.5m to 7.0m wide though where the lesser width it has on one side
parking restricting it to single lane working as shown on plate 23, and where the greater
width has parking on both sides resulting in it also being single track too. The section
of most concern being from south of Heanton Street through to Barton Lane.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 36
4.6.29 Beyond Barton Lane the existence of Southmead Primary School to the east, and
Braunton Academy to the west results in significant demand to cross. The Braunton
Academy car park also being located on the eastern side.
4.6.30 Traffic calming reduces the width of Wrafton Road in three locations to 3.6m, 3.7m and
4.1m from north to south respectively as shown on plates 24, 25 and 26. Plate 27
shows a view along Wrafton Road. However, the issue of the width of Wrafton Road
is not just related to that section between Heanton Street, and Braunton Academy as
plate 28 shows a view along Wrafton Road near the Knowl Water bridge with parked
vehicles, and plate 29 a view further south in the vicinity of The Williams Arms showing
residential properties abutting the road.
4.7 Summary
4.7.1 The main issues at dispute for this appeal in my opinion are those within the context
of NPPF paragraph 32, and are summarised as:
i) The impact of the additional movements generated by the appeal proposal
which are not disputed in quantum though are disputed in terms of impact,
ii) The impact of those additional movements on the local highway network and in
particular on Wrafton Road, and through the A361 / B3231 traffic signals where
along Wrafton Road the additional 72% of all vehicles generated by this site will
be bound to increase conflict potential on the sections constrained by parked
cars on one side, or on both sides, and where the development will impact at
the A361 / B3231 traffic signals due to the juxtaposition of junctions, and traffic
intensity meaning that traffic only exits Heanton Street when other vehicles are
courteous,
iii) Whether safe and suitable access to the site can be achieved for all users,
iv) Whether there is a severe impact, and in this context, it is contended that there
is at both the A361 / B3231 traffic signals, and along Wrafton Road, and
iv) Whether the proposal amounts to sustainable development.
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
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5.0 SUMMARY AND CONCLUSIONS
5.1 Paragraph 32 of the NPPF indicates that:
“All developments that generate significant amounts of movement
should be supported by a Transport Statement or Transport
Assessment. Plans and decisions should take account of whether:
the opportunities for sustainable transport modes have been
taken up depending on the nature and location of the site, to
reduce the need for major transport infrastructure;
safe and suitable access to be site can be achieved for all
people; and
Improvements can be undertaken within the transport network
that cost effectively limit the significant impacts of the
development. Development should only be prevented or refused
on transport grounds where the residual cumulative impacts of
the development are severe.”
5.2 The Written Statement has considered whether there are opportunities for the use of
sustainable modes of transport, whether a safe and suitable access to the site can be
achieved for all modes of travel, and whether the residual cumulative impact of the
development cannot be classed as severe.
5.3 It is our conclusion that:
i) The location is one where the opportunity for sustainable modes of access are
limited,
ii) That a safe and suitable access is not achieved for all modes due to
deficiencies in road widths that are not proposed to be improved as part of this
planning application,
iii) Safe and suitable access using the adjacent network cannot be achieved due
to the deficiencies in road width leading to an inevitable increase in conflicts
leading to safety concerns,
iv) In addition with the third bullet point in mind it is contended for the
various reasons outlined in this Written Statement that there is a severe impact
of the proposal, and
v) That there is a severe impact in the following regards:
a) The cumulative impact at the A361 / B3231 traffic signals and adjacent
A361 / Heanton Street junction,
Planning Appeal by Chichester Homes Developments Limited in respect of the non determination of a planning application
for the erection of 55 dwellings on land to the east of South Park Braunton
Written Statement on Highways / Transport Issues Prepared by M Baker BSc CEng MICE FCIT FILT Eur Ing
on behalf of Love Braunton
Technical Report 19201/1 April 2017
Page 38
b) The cumulative impact along Wrafton Road due to the additional
vehicles generated by the proposal conflicting with other vehicles on the
section of Wrafton Road that is effectively single lane working due to the
presence of parked cars, and
c) The impact on the section of Lower Park Road between Barn Field
Close, and South Park that is also a shared surface.
5.4 The severe impact is notwithstanding the quantum of impact. This is due to the
inevitable increase in conflict particularly locally where there are restrictions in road
width that do not allow for the free passage of vehicles, and where the restrictions
mean vehicles approaching the constrained sections of highway locally may not be
aware of the potential oncoming conflicts. Vehicles are not able to wait to avoid such
conflicts due to the restricted widths leading to inevitable increasing in reversing to
adjacent passing spaces primarily at private accesses.
5.5 It is respectfully requested that the Inspector dismisses the Appeal.
Appendix DR/MB/A
PHOTOGRAPHS
Plate 1 Lower Park Road
Plate 2 Heanton Street
Plate 3 Hill View
Plate 4 Passing places along Wrafton Lane at private accesses
Plate 5 Mid morning conditions at the A361 traffic signals
Plate 6 A361 at the A361 / B3231 showing the junction, Heanton Street and the pelican
crossing
Plate 7 South Park Proposed Access
Plate 8 South Park Abutting the Site to the north
Plate 9 Existing Access onto Lower Park Road
Plate 10 Typical scene along Wrafton Lane
Plate 11 Wrafton Road
Plate 12 Mill Lane from the north at Lower Park Road
Plate 13 Mill Lane from the south
Plate 14 Chicken Lane
Plate 15 Traffic calming along Moor Lea
Plate 16 Parked vehicles on Lower Park Road west of Barn Field Close
Plate 17 Lower Park Road shared surface
Plate 18 Lower Park Road west of South Park looking east
Plate 19 Lower Park Road west of South Park looking west
Plate 20 Lower Park Road west of Barn Field Close looking east
Plate 21 Lower Park Road
Plate 22 Heanton Street
Plate 23 Wrafton Road
Plate 24 Wrafton Road near Braunton Academy looking north
Plate 25 Wrafton Road near Braunton Academy looking south
Plate 26 Wrafton Road outside Southmead Primary School
Plate 27 Wrafton Road south of Barton Lane looking north
Plate 28 Wrafton Road
Plate 29 Wrafton Road by The Williams Arms