This report has been prepared for Whitmore Parish Council and Baldwins Gate Action Group by Mr Graham Wheildon, I.Eng., AMICE.

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Whitmore Parish Council and Baldwins Gate Action Group Page 1 About the author This report has been prepared for Whitmore Parish Council and Baldwins Gate Action Group by Mr Graham Wheildon, I.Eng., AMICE. In over 40 years of civil engineering Mr Wheildon has held highways development control posts at Scarborough Borough Council and Derbyshire County Council. He was seconded to work in the Development Control Birmingham office of the Highways Agency. In the course of his career Mr Wheildon has supervised many new developments and highway improvements. During his time at Scarborough he also dealt with drainage adoptions and land drainage. Cllr Wheildon is a member of Whitmore Parish Council and is the Parish Council s Community Speedwatch Coordinator.

Whitmore Parish Council and Baldwins Gate Action Group Page 2 Introduction The purpose of this report is to set out the technical case for dismissal of the appeal on highway safety and access grounds. Although the application was refused on grounds of highway safety and access, the comments of Staffordshire County Council Highways (SCC) prior to the decision did not support refusal. SCC s comments and negotiations with the developer were flawed, being weak on a technical basis, and fell short in not recommending refusal of the application. Highway safety and access issues were raised by Whitmore Parish Council, Baldwins Gate Action Group and residents of Baldwins Gate throughout the application process, and the site visit by the Planning Committee contributed significantly to the decision to refuse the application. This report deals with the following: 1 The A53 in national, regional and local context 2 Appellant s proposed access to the development via Gateway Avenue 3 Access onto the A53, including sightlines for the development access 4 Traffic data, Traffic Impact Assessment and RSA1 5 Mitigation measures and proposals 6 Flood risk Construction access is dealt with separately from this report. 1 The A53 in national, regional and local context 1.1 National The A53 is a classified road with primary route (green) signs and primary destinations. It links the A500/M6 to Chester and Shrewsbury. Via the A50 and A500 it links the M1 from Derby and the East coast ports to the Mid-Wales and West coast ports. Among the 12,000 vehicles a day that pass through Baldwins Gate are a large proportion of HGVs and commercial traffic. Most of the vehicles pass through during business hours. Traffic data shows that vehicle speeds increase significantly after business hours. (See attached SCC data for the period 26 September 3 October 2013)). 1.2 Regional At the western end of Baldwin s Gate, Woodside and Sandy Lane (leading off Woodside) link the A53 to the A51. One mile to the east of Baldwins Gate, Bent Lane provides another link between the A53 and A51. The A53 and A51 cross one mile to the west of Baldwins Gate, at Blackbrook. The A51 is

Whitmore Parish Council and Baldwins Gate Action Group Page 3 another primary route and links Crewe and Nantwich to Stone and Stafford, Stone being a hub for new business and Stafford being the county seat. Both roads serve large populations. The majority of private motorists are commuters who travel along these two roads at or in excess of the speed limit. The majority of traffic on the two roads travels through Baldwins Gate. Although most drivers repeat the journey daily, there are also a large number of one-time journeys. 1.3 Local The A53 through Baldwins Gate is a village road serving two shops/post office, a filling station/shop, a pub, a farm and a church. On the south side a loop road provides access to the school and the doctor s surgery (Map 1). The A53 bisects the community of Baldwins Gate. In such cases, the presence of a classified road has an inordinate effect on the community. Accidents that close the A53 have a large impact on the local area and on commuter traffic (Figure 1). With the exception of the pub, all facilities and services in the village are located on the south side of the A53. Because of the perceived danger of the road residents of the development would be likely to use their cars to access the village s facilities and services, including the school. Figure 1 Road accident at eastern entrance to Baldwins Gate, 29 April 2014

Whitmore Parish Council and Baldwins Gate Action Group Page 4 The A53 is also a bus route. Baldwins Gate has four bus stops, two on each side of the road. Buses travel from Shrewsbury to Hanley via Newcastle on a single route, at a rate of 1 per hour in each direction, such that passengers would have to change in Newcastle if they wanted to access the main doctor s surgery in the neighbouring village of Madeley a journey of approximately 11 miles to travel 4 miles along the interconnecting roads. (Map 2) 1.3.1 Highway conditions and traffic Over the years housing development in the village along the A53 has led to road improvements to provide footways within the available curtilage, and the street lighting has changed from footpath standard to highway standard albeit rural highway standard in parts and better to meet a section 278 scheme. The lighting has been installed over a number of years and, as such, varies in standard and type. At only 6.2m wide, the A53 through Baldwins Gate is below the standard for a busy classified road. Such a road should be 7.3m wide, with widening on bends. There should be turning refuges for the many junctions, with islands marked by illuminated bollards. There should be wide verges, and footways set back to protect pedestrians from having to walk alongside the many HGVs travelling through the village (Figure 2). Footways are as little as 1.7m wide and the available width is sometimes reduced by poles, posts and overgrown hedges. All this is clearly visible on site. Figure 2 HGV passing pedestrians near the end of Gateway Avenue

Whitmore Parish Council and Baldwins Gate Action Group Page 5 Within the area defined by the village envelope there are 11 road junctions. A short distance to the west is the junction with Woodside, which is a bus route and a route onto the A51 for residents of Baldwins Gate, Madeley Park Wood and Madeley village. None of these junctions, with the exception of Gateway Avenue, has been assessed. 1.3.2 Business and residential accesses Within the area defined by the village envelope there are accesses and/or parking on the A53 for two shops/post office and a hairdresser s; a pub; a filling station/shop forecourt; a workshop; and to railway maintenance yard. There are also several farms in the immediate vicinity. Within the village envelope there are also 38 domestic accesses onto the A53 serving 42 dwellings. At some of the older residences and where residences are situated on backlands one access serves more than one property (Figure 3). Of the 42 dwellings served by vehicle accesses onto the A53, not all have turning facilities enabling vehicles to enter and leave in forward gear. Turning facilities are not mandatory for these properties and where they do exist householders have often put them in for safety reasons. Figure 3 Shared domestic access onto the A53 in Baldwins Gate 1.3.3 Future traffic The appellant s A53 traffic data does not demonstrate the growth in volume that has taken place over recent years due to development along the A53 and the nearby A51. These two roads complement each other for distance commuting and business traffic. Large developments at

Whitmore Parish Council and Baldwins Gate Action Group Page 6 Loggerheads and Market Drayton have increased the traffic through the village and will continue to do so, as has the completion of the A50. Business growth in Stone has likewise influenced the traffic growth. Further, data projections for future traffic based on national standards cannot take account of local vagaries such as school issues, shopping trends and business development such the Müller dairy in Market Drayton, which is situated on the A53 10 miles south-west of Baldwins Gate and is serviced by many HGVs daily via Baldwins Gate. Taking into account current and planned development along the A53/A51, the local traffic will be in excess of the national road freight statistics (NRFS) used by the appellant. (NRFS are published by the DfT.) 2 Appellant s proposed access to development via Gateway Avenue 2.1 Inappropriate design criteria With the SCC s approval, the appellant has applied the design guidance in Manual for Streets 2, which replaced previous guidance, including DB32. Manual for Streets 2 made changes to the design of residential streets and introduced narrow carriageways, tight bends and poor visibility so as to improve road safety by making residents drive more slowly. However, such guidance is limited to housing estates, where, by design, speeds are lower. The Manual for Streets 2 guidance recognises that there are limitations to this, and recommends a return to the DB32 guidance in cases where speeds are higher (p. 90, para. 7.5). There is a clear difference between a junction onto a residential street and the Gateway Avenue junction with the A53 in Baldwins Gate. If there were a requirement for section 278 highway improvement works in Baldwins Gate, then the SCC engineers would use the Design Manual for Roads and Bridges and the appropriate TA and TD design guides. Through traffic on a main road does not drive as responsibly as local housing traffic. It is inappropriate to apply housing road criteria to the A53 in Baldwins Gate. 2.2 Flawed junction design While the appellant s Picady design demonstrates the junction working, it is in fact flawed. Picady is a junction design software. It uses hourly traffic flows as if the traffic flowed uniformly. Because of the uneven traffic flows and the many convoys through Baldwins Gate (see 2.2.1) it cannot produce an accurate model of the A53/Gateway Avenue junction. Because slow-moving

Whitmore Parish Council and Baldwins Gate Action Group Page 7 vehicles cause the traffic to bunch up, a vehicle turning right into Gateway Avenue will cause significant tailbacks. 2.2.1 Convoys formed by local bottlenecks The important information is the number of gaps between vehicles over the peak period, but this information is not accurate because it is not possible to model the traffic passing through several local bottlenecks on the approach to Baldwins Gate. This is typical of a model for traffic flows through a village. What happens is that vehicles catch up behind slower-moving vehicles and form queues or convoys (Figure 4). Figure 4 Vehicle convoys travelling through Baldwins Gate Westbound from Newcastle on the A53 there are a roundabout and two speed restrictions in isolation, with a junction at Three Mile Lane. Eastbound, at the junction with the A51 two streams of traffic merge and there are bends and a speed reduction coming into Baldwins Gate. The resulting convoys through the village can be 20 vehicles long in both directions. The engineering model should be analysed taking this into account. If the highway land were available the solution might be to put in a double right-turn harbourage at Tollgate Avenue/Gateway Avenue. But there is no highway land available. 2.3 Geometry of Gateway Avenue Gateway Avenue is 4.8m wide, which is narrower than the standard required for a new development (5.5m). The appellant insists that SCC has advised that even though Gateway Avenue is narrower than the standard required for new development, it is satisfactory for the access. The difference is that the wider standard permits two commercial vehicles to pass.

Whitmore Parish Council and Baldwins Gate Action Group Page 8 The total length of Gateway Avenue is 80m, and it is likely that passing of commercial vehicles could happen, given the general continuing growth in commercial deliveries to private residences. Without a wider road or passing places, development should not take place. The residents of Gateway Avenue should not be disadvantaged in comparison to new house occupiers living on streets designed to SCC s new development design guide. 2.4 Unsuitable layout of Gateway Avenue Although the layout of Gateway Avenue looks as if it can be extended, the road was effectively removed as a potential development access by the drafting of the village envelope, which excludes land beyond the developed area. This may have been done in recognition that the road and the access are not suitable. The nonsuitability of the road as a development access can be seen from the finished geometry of the road and the not-completed visibility splays at the junction. New developments off the A53 since the building of Gateway Avenue and the other 1960s estates have required normal junction access works and have been built to a higher standard than Gateway Avenue, as more land was available. Thus, the newer developments (Fair-Green Road and Lakeside) have at least the minimum sightline and junction geometry. 3 Access onto the A53, including sightlines, for the development access The access onto a classified road from a road serving 150 houses should be 4.5m x 90m (30mph). Guidance on the criteria is a national standard and is based on stopping distance and reaction times for drivers exiting a road into moving traffic. If speeds are in excess of 30mph, then actual speeds should be used. All surveys carried out recently in Baldwins Gate show average speeds above the speed limit (e.g. see attached SCC traffic data). This could increase the sightline requirement to 4.5m x 120m.The sightlines achievable at Gateway Avenue are approximately 2m x 50m. Given that vehicle speeds are in excess of 30mph (85%ile is 34mph), this means that the current available visibility is well below an acceptable standard. This would be made worse by additional traffic from more houses. Accidents are the result of convoy traffic and poor junction visibility. Drivers crash into the rear of a car that has just pulled out, or into a car that has just braked hard to avoid a braking car. The appellant s calculation for sightlines from a residential road onto a collector road is flawed because the A53 is a primary route, not a local distributor road. In using the formula in Manual for Streets 2, the appellant has arrived at a sightline which is based on vehicle stopping speeds and reaction times. The Manual for Streets 2 discusses the time required for an emergency stop, which

Whitmore Parish Council and Baldwins Gate Action Group Page 9 has improved in recent times. This may work within a residential envelope, but for vehicles exiting from Gateway Avenue and entering the flow of traffic on the A53, to cause an emergency stop by an oncoming vehicle would be a recipe for more accidents (rear-end shunts and collisions due to swerving). From the other accesses onto the A53 from the other side roads it is also necessary to merge into traffic, and this is best achieved by having good junction visibility. The sightlines could be improved, but this would require third-party land. The junction radii would have to be improved for vehicles turning into and out of the classified road. A minimum of 6m radii are required. This would affect the existing road geometry. For design purposes a road such as the A53 is stated in DMRB part 3 TA79/99 as a UAP4 30mph 7.3m wide + carriageway with 15% 25% HGVs. The A53 is clearly below this standard. Therefore a departure from standards would be involved and approval by the highway officer would be required. These issues should not be left to a detailed design stage, as they are not achievable. The appellant s analysis of the junction using TA42/95 is at best a distraction and at worst an attempt to blindside the issues on the A53. The traffic generated by the development would be travelling via an already substandard junction onto a classified road with major traffic issues during the working day. There are clearly road safety issues that would be made worse by a poor development access. This should be recognised and the refusal upheld. 4 Traffic data, Traffic Impact Assessment and RSA1 4.1 Traffic data The measured traffic data is not in dispute. The Community Speed Watch records vehicle numbers up to 1,200 an hour at peak times. Vehicle speeds which are recorded at 32mph (85%ile) are not disputed. (This is above the speed limit and should be the figure used for the calculation of sightlines, as per DfT standards.) However, the spread of speeds is worrying and has not been addressed. There are a large number of vehicles travelling in excess of 40mph. The SSID data in the appellant s TIA shows an 85%ile of 32 mph. SCC data indicates 34 mph with the 95%ile at 46mph. Vehicle speeds are the matter that is of most concern to the residents of Baldwins Gate. If you are trying to get your vehicle onto the road from a drive or a road junction, then speed is of concern. The consultant s data, the SCC data, the Community Speedwatch data and the Speed Indicator Device data reveal speeds in excess of the signed limit. DMRB Part 3 TA85/01 gives guidance on

Whitmore Parish Council and Baldwins Gate Action Group Page 10 improving roads such as the A53. This should have been referred to by SCC in its original planning response. 4.2 Traffic Impact Assessment (TIA) The TIA, as expected, contains the minimum data for an access onto the A53. However, there are numerous other active junctions in the near vicinity of Gateway Avenue which impact on the safety of the proposal. Drivers experience the issues of exiting from these roads on a daily basis. Gateway estate has 33 dwellings; Sandyfields 28; Appleton Drive 47; Fair-Green Road 46; Meadowfields estate and Tollgate Avenue 44; Lakeside 48. Meadow Way and Tollgate Avenue form a loop road that serves as a circular route to access the school (including for school buses) and the doctor s surgery. The additional turning manoeuvres at peak times should have been accounted for in the TIA, but they were not. It would be valuable data if the whole village, or at least the two junctions close to Gateway Avenue (Tollgate Avenue and Meadow Way), were also modelled. 4.3 RSA1 Stage 1 Safety Audits have a limited scope and only look at the proposals. The most appropriate survey would have been a Safety Assessment. This could have looked at existing pedestrian, vehicle and road issues at the Gateway Avenue junction and along the A53: the impact of passing vehicles on pedestrians on the existing footways on the A53; the difficulties in crossing the road; the impact of speeding vehicles and the sheer number of vehicles travelling along a road with bends; the existing Gateway Avenue junction and its shortcomings; the speed reductions and lighting necessary to ensure the A53 is a safer road; the fact that the number of road traffic accidents in the last 12 months indicates an increase in average speeds. 5 Mitigation measures and proposals 5.1 Mini roundabout The appellant, in consultation with SCC, adopted a do nothing approach at the Gateway Avenue/A53 junction. In reaction to the local response to this, the appellant then suggested installing a roundabout, which was supported by SCC. It was demonstrated that this would not be workable both within the existing

Whitmore Parish Council and Baldwins Gate Action Group Page 11 highway and on account of adjacent private accesses. The third proposal was then to leave the junction as existing but provide a Puffin crossing. 5.2 Puffin crossing with call loop A second controlled crossing in Baldwins Gate would be useful, but national guidance requires them to be situated away from junctions and accesses. SCC has stipulated that the proposed Puffin crossing should have a call loop serving traffic on Gateway Avenue. There are few examples of such a controlled crossing, and they fall outside the design guidelines. The purpose of a controlled crossing is to enable pedestrians to cross the road, not to act as junction signalling. If the crossing were to go to all red without a pedestrian, then this would look like a fault and encourage drive-throughs. The Puffin signal is different to a Pelican, and if there is a Pelican nearby on the same road this can cause confusion for both drivers and pedestrians. The footway on the north side of the A53 at the site of the proposed crossing is only 1.7m wide. This is below the recommended 2.0m and does not allow pedestrians with pushchairs to safely pass pedestrians waiting to cross the road. Traffic signal posts would worsen the situation. There are private accesses in the area of the proposed Puffin crossing. For this reason and because of the limited footway width, pedestrian guard rails could not be installed (Figure 5). Householders would not be able stop on the road (Highway Code, section 215). If a driver needed to stop, open a Figure 5 Traffic accident at the site of proposed Puffin crossing, 30 May 2014

Whitmore Parish Council and Baldwins Gate Action Group Page 12 gate or wait for traffic to pass before reversing in, then they would be breaking the law and could be prosecuted. There are examples of such controlled crossings being installed, only to be abandoned and not put into use, as they failed to work, due to legal objections from householders. A pedestrian crossing cannot be used as a speed or junction control device, or for traffic calming. It cannot be used to mitigate inadequate sight lines. 6 Flood risk The highway authority has required an adoptable road layout that is drained to a suitable outfall. The existing roads are served by a county council highway drainage system that is connected to a pumping station in Meadow Way. This pumping station might require upgrading, as there are records of flooding in Meadow Way in recent years. If the A53 were to be flooded, this would be a serious event. 7 Conclusion The proper response from SCC would have been to recommend refusal of the access via Gateway Avenue without improvements to the geometry. The DMRB gives advice on mini roundabouts and improvements to existing roads. Attachments Map 1 Baldwins Gate Map 2 Route from Baldwins Gate to Madeley SCC Speed Statistics Summary and Length Summary, 26 September 3 October 2013 Documents referred to The Manual for Streets 2 (2010) Design Manual for Roads and Bridges

Whitmore Parish Council and Baldwins Gate Action Group Page 13 Map 1 Baldwins Gate, facilities and services (Google mapping and imagery)

Whitmore Parish Council and Baldwins Gate Action Group Page 14 Map 2 Bus and car routes from Baldwins Gate to main doctor s surgery in Madeley (OS mapping from GetMapping.com)

Whitmore Parish Council and Baldwins Gate Action Group Page 15

Whitmore Parish Council and Baldwins Gate Action Group Page 16