The Wincheap Society s comments on, and objections to, CA//17/02718

To: Canterbury City Council Planning Department [Letter dated] 30 December 2017 The Wincheap Society s comments on, and objections to, CA//17/02718. The document that accompanies this letter contains our full comments on and objections to certain documents in Application CA//17/02718, and both this letter and the document have been written for the purpose of being copied and displayed on CCC s Planning website page for s on CA//17/02718. We fully endorse the contents of the Thanington Without Parish Council s on that page. Additional to their concerns the Wincheap Society is worried about: 1. apparent discrepancies concerning routing and signage; 2. manoeuvrability of long lorries (LSTs and truck trains) not being considered; and 3. errors and assumptions made in the Hybrid Transport Assessment document. We are also disconcerted by PBA s standard presentation in the Application documents (and other documents, such as the Thanington 4th Arm Slip Road Walking, Cycling & Horse-Riding Assessment & Review Report ) they have produced. PBA lists the various central and local government policies with which the relevant development is required to comply. PBA then lists the ways in which what is being proposed complies with those requirements, and finally in summary states that the Application is compliant. Surely the decision as to compliance should be CCC s Planning Department s, and not PPL/PBA s? At most the Applicant should submit that, in its opinion, what is being presented to CCC is compliant, and CCC should say whether it is or not. The impression that PPL/PBA is marking its own homework is confirmed when other documents relevant to the Thanington Park Development and the A2/A28 4th slip road are examined. For example, the Walking/Cycling safety assessment document mentioned above contains data and surveys produced by PBA or its subcontractors that unsurprisingly support PPL/PBA s proposals. We have looked for evidence of CCC Planning (and KCC HIghways) carrying out their own critical reviews of this and other related Applications, and have found none. If you can provide us with such evidence, we would be grateful. The Wincheap Society consider it shameful that we have had to examine all these documents in fine detail, and continually challenge them in reports and responses. Why is not CCC doing so on our behalf? If it is, why are its findings not made public? Yours sincerely,. Wincheap Society 1

The Wincheap Society s comments on, and objections to: CA//17/02718 Hybrid application for mixed-use development of land bounded by Cockering Road and the A2 Dover Road. Application for outline planning permission for 4000sq. m. of B1 employment floorspace. Application for detailed planning permission for 87 dwellings, an extended westbound slip road on the A2, a new access on to Cockering Road main link road, areas of formal and informal open space, utilities infrastructure including flood attenuation works and associated groundworks. Land south of Cockering Road and west of the A2, Thanington. 1. Eight drawings dated 6 Dec 2017: A2 London Off Slip Single Deck Bus: 1/2 and 2/2 A2 London Off Slip Articulated Vehicle: 1/2 and 2/2 A2 London Off Slip Refuse Vehicle: 1/2 and 2/2 A2 London Off Slip Rigid Vehicle: 1/2 and 2/2 1.1 Routing and signage The 4 1/2 illustrations showing green and arrowed routes at the bell mouth junction for 4 types of vehicles all appear to provide for a right turn into the contra-flow by traffic from the west on the A28, e.g. Note the directional arrow pointing down into the south bound contra-flow lane, marked on the A28 immediately above the bell mouth junction. However, the road layout shown at page 40 of the Thanington 4th Arm Slip Road Walking, Cycling & Horse-Riding Assessment & Review Report (page 40, Thanington Park A2 London Bound Off Slip General arrangement Layout) and in other relevant documents, shows no road makings for such a right hand turn, but two road marking 2

arrows on the two east round lanes pointing ahead only and a preceding road sign showing similar arrows, one for a Canterbury Lane and one for the A2 (Dover bound on slip). It is unclear from these and other plans currently available whether traffic from the west will access the development site via: 1. as appears to be envisaged in these Drawings, a turn right from the A28 into the contra-flow and then a 90 degree right turn into the site, as these Drawings show; or 2. a right turn from the A28 into St Nicholas Road, with a new traffic light system, to the Cockering Road access point; or 3. a left turn into Ten Perch Road, negotiating the key hole route round the roundabout to return to the A28 via a right turn, and then a left turn into the contra-flow and a 90 degree right turn into the site, or any combination of these. Which is it to be? Regarding option 2, if this is the intended entry route for all traffic approaching from the west, will there be any incentive at all for traffic leaving the site and intending to turn right or left onto the A28 to use the new contra-flow route? The unsuitability of St Nicholas Road or Strangers Lane, both residential estate streets, for access to the site was one of the reasons that several previous planning applications were rejected. The proposed contra-flow system on the A2 off slip is supposed to provide an access point that avoids the problem of undesirable use of these residential streets (and of Cockering Road). If inward access from the A28 via St Nicholas Road is to be mandatory for traffic from the west, then outward access via the same route for both west and east bound traffic will become available. Can one assume that the inward and outward flows of residential and bus traffic currently using St Nicholas Road will not be interfered with? Or are the current inhabitants of Thanington south of the A28 to be yet further inconvenienced? Thus, use of the contra-flow with become unnecessary, and probably safer and easier, for all traffic except west bound traffic on the A28 leaving Canterbury or exiting the A2 via the 4th slip road. Regarding option 3, whether this is the intended inward route for all traffic, including from the west, OR only for non-residential traffic, then a great deal of signage will be required to make this routing plain to drivers of such vehicles. It is difficult to negotiate the current A2/A28 junction layout, particularly for drivers approaching it for the first time. All the agencies involved in this planning process should also bear in mind that drivers will go where their SatNavs tell them they can go, regardless of signage. Many lorry drivers persist in using SatNavs intended only for the private car market, and not for large commercial vehicles. Hence jams on country roads and collisions with bridges being so often reported. 3

1.2 Very long vehicles and road trains using the proposed new layout: not considered The 8 illustrations show green and arrowed routes at the 90 degree turn into the Thanington Park site and the 45 degree left tun at bell mouth junction for 4 types of vehicles, with maximum legal overall lengths, as follows: 1. Single deck bus: 11.98 metres 2. Articulated vehicle: 16.5 metres, kerb to kern turning radius 6.8 metres. 3. Refuse vehicle: 11.347 metres. 4. FTA Design HG Rigid Vehicle (1998) : 10 metres, kerb to kerb turning radius 11 metres. The maximum lengths chosen in these illustrations for articulated and rigid vehicles are puzzling, The current legal maximums in the UK are: One truck: 12 metres; Truck + trailer: 16.5 metres; Road trains: 18.75 metres. Longer semi-trailers (LSTs) now being trialled: 18.55 metres (60 ft). Road trains and LSTs are now with us, on roads in the Wincheap / Thanington area. Why are they not illustrated in PPL s Application CA//17/02718? UK Road train UK LST: note the long tail extension behind the rear wheels: this is over 2 metres (7 ft) longer than on most current UK lorries. A road train recently seen parking on alongside GO Outdoors Canterbury in Maynard Road, just off Cow Lane, filled the space between the entrance to and the exit from Go Outdoors car park, i.e. nine end-to-end car parking space. A photograph of a Google Maps display of this area and the car park indicates clearly what a length of 18.75 metres comprises. 4

Trials of LSTs commenced in 2011, initially planned for 10 years with a maximum of 1,800 LSTs. This maximum number was achieved by 2015 and in January 2017 the UK government agreed to increase the number of LSTs by an additional 1,000 and to extend the trial by 5 years. It was envisaged that this increase would take the number of LSTs from 1,800 to approximately 2,800 over the 12 months to January 2018. The trials were to be confined to motorways, plus some urban road use for lading and unloading. The effects of LSTs tail swing or kick out are being assessed on an annual basis by Risk Solutions for the Department of Transport. Their annual Report for 2016 (published September 2017), contains the following: Our analysis found no simple relationship between LST kick-out and the overall rate of injury and damage incidents on either trunking or delivery routes. However, we have recommended that DfT consider studying the rationale behind the adoption of the (many) different trailer designs, including the geometry, axle choice and hence tail-swing measurements. This might provide some insights to inform design guidance in any future expansion of the trial or general roll-out of LSTs. and The results from the data collected on the trial can only reflect the position within the trial fleet and under trial conditions. Now that we have a substantial trial dataset we recommend that during 2017-19, DfT should plan to conduct initial scaling up analysis applying the data gathered so far on the trial to a theoretical scenario where LSTs were widely available at some point in the future. The would also require work to translate the journey saving results into measures of emissions reduction. We have also recommended that DfT start conducting evidence based conversations between DfT, the haulage industry and other interested parties such as Local Authorities and civil society groups, regarding what guidance or regulation might be required to maintain the positive results seen on the trial under post-trial conditions. Transport Network reported on 30th January 2017 that the Campaign for Better Transport has warned that these vehicles pose a significant road safety risk and should be restricted in towns and cities. They also quoted Philippa Edmunds, Freight on Rail manager (who we recognise may have the rail freight industry s fish to fry): The Government is continuing to ignore the danger posed by these longer lorries on urban roads. Our concern is that these longer trucks will become the new standard trucks operating on all roads, regardless of the dangers to other road users. We want to see the Government limit their use to designated local authority routes within urban areas to reduce the risks to other road users, protect pavements and property from damage, and reduce the current financial burden of repairs that currently falls on local authorities and taxpayers. Can such vehicles negotiate the 45 degree angle left turn into the contra-flow from the A28, of the 90 degree right turn into the development site, or the roundabout at the north end of Ten Perch Road? Can they do so without disrupting other vehicles? At the east side bell mouth junction of the contra-flow with the A28 there will be no bollards, only unshielded pedestrians waiting to cross and standing on a corner pathway much reduced from what it is now. And will not buses and lorries of the lengths actually considered in CA//17/02718 intrude upon the north bound lanes? What will happen 5

when an LST or road train attempts this turn, or the 90 degree turning into the site, or into the west bound A28? What will happen when one of these monsters turns into or out of St Nicholas Road and Cockering Road? (Regarding 90 degree left turns, the situation at the junction of Simmonds Road with Wincheap is informative. Single deck buses (11.98 metres) and lorries turning east from Simmonds Road into Wincheap now have to wait for a space in traffic to become available in the westbound lane in order to swing out while making this manoeuvre. The metal bollards set up on the pedestrian pavement to protect people waiting outside the Maiden Head pub to cross the junction mouth are constantly knocked over by such vehicles.) 2. Document: Transport Assessment, Thanington Park : Housing and employment (hybrid) application, November 2017 Much of this document merely reproduces much of PBA s earlier document in CA// 15/01479. We are disappointed that the mistakes and anomalies in the earlier document have not been corrected. For example: 4.2.6 The National Cycle Route 18 (NCR18) runs along Cockering Road linking Tunbridge Wells to Canterbury City Centre, via Ashford and Tenterden. Locally, this route links the proposed site to Canterbury East rail station, the City Centre (via the city wall) and Canterbury West rail station. This is an error: NCR Route 18 was shifted to the path north of the River Stour years ago, as the Wincheap Society and SPOKES Canterbury have pointed out. PBA managed to correct this in their recent Thanington 4th Arm Slip Road Walking, Cycling & Horse- Riding Assessment & Review. Why has it persisted into this Application? Does this indicate that PPL/PBA are now confident that CCC will not check their submissions? 1.3.4 The reconfigured westbound A2 slip road will be consistent with that proposed for the permitted Thanington Park development and will therefore be to current standards, and hence offer a betterment over the existing slip road. It will reposition the slip road so that a new two way link road can be provided from the A28 into the site, with the slip road ending to the south-east of its current position. A secondary vehicle access point will be taken from Cockering Road in the vicinity of St Nicholas Road. See all our comments above at 1.1 and 1.2. 2.2.2 The extant Thanington Park permission requires the London bound A2 off off slip access to be provided at 75 dwellings. Therefore, two assessment scenarios have been considered for the hybrid application area. The first scenario assumes 75 units (67 private and 8 affordable) are built and accessed solely from Cockering Road. The second scenario assumes 95 units (67 private and 28 affordable) and the employment use are built and accessed from Cockering Road and the new slip. So, construction of the contra-flow is imminent, but nonetheless St Nicholas Road / Cockering Road are to be used for construction traffic. The NPPF: 3.2.4-3.2.11 PBA concludes that the test whether any residual impacts could be considered severe in the context of NPPF, and it is clear from the assessment that follows that this is not the case, and that the location of the hybrid application area (and wider Thanington Park) site is consistent with Section 34 of the NPPF requirement that developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes maximised. 6

Should not KCC/CCC be making these judgements as to whether PPL s plans are compliant with the NPPF? Any statements by PPL/PBA that they are compliant must be viewed as self-serving. Transport Policies 3.5.9-3.5.15 Our comment on 3.2.4-3.2.11 applies here mutatis mutandis. 3.6 Canterbury District Transport Strategy Revised Draft with Addendum 1 3.6.1 The Strategy replaces the Canterbury District Transport Action Plan Unlocking the Gridlock (2004) and the Canterbury District Walking and Cycling Strategy (2003). It is a joint document of Canterbury City Council (CCC) and Kent County Council (KCC) and has been prepared to provide the transport policy framework for the Canterbury District to the year 2031. The document was published as a draft document and has been revised in response to consultation comments received. 3.6.1 Unhappily the steady withdrawal of central government funding, which is likely to continue into the 2020s, has reduced this policy document to mere PR piffle. 3.6.3 Paragraph 1.34 states that Canterbury has a strong track record in encouraging walking and cycling for everyday journeys. Paragraph 2.11 of the Transport Strategy highlights that the Canterbury district lies 3rd in Kent for lowest proportion of trips to work by car and is the highest for walking and cycling trips to work. This demonstrates that walking and cycling encouragement in Canterbury is realistic. Canterbury is the second-smallest city in England & Wales (smallest, St David s Lampeter) so it is not surprising the people who live and work in it walk about it a lot. (It is also the most congested.) Thanington Without was sliced away, physically and socially, from Wincheap and the city centre by the construction of the A2 gully. This resulted in an alienated community on the Thanington estate, into which for a period the police and other services would not venture: Little Beirut. The relationship with the rest of Canterbury is rather better now, but even so it is folly to prattle about ease of modal changes in that community. 3.7.1 The development proposals respond to the thrust of the policies identified above on the basis of the following: Mixed use development on site has the potential to increase economic activity within the city centre and for residents to make this journey by sustainable means of transport. The site is in close proximity (certainly walk and cycle distance) to the city centre and sits alongside the existing bus network. The distances cited from the proposed development at Thanington to the city centre appear to have been taken from the extreme eastern edge of the Thanington estate. Walking or cycling in rain, cold, and in rush hour congestion is not a pleasant experience The proposed development accords with policy to place new developments in locations of high accessibility. PPL/PBA must be joking: inaccessibility of the Thanington site has been the reason for CCC consistently refusing applications to develop it, until scared into granting permission so as to be able to comply with central government s policy under the Inspector s kibosh. 7

The proposed site, whilst close to the city, does not result in severe residual transport impacts, and so meets the test set for these effects by the NPPF paragraph 32. Indeed, this report demonstrates that the transport effects of the hybrid application area site fit within the assessment completed and submitted for the wider Thanington Park site. Again, should not KCC/CCC be making these judgements as to compliance? Any statements by PPL/PBA that they are compliant must be viewed as self-serving. 4.3 Bus 4.3.1 There are numerous existing bus stops within the vicinity of the hybrid application area, which serve a number of bus routes.,,, 4.3.3 In summary, there is access from the site to a number of existing bus services and these provide access to a range of destinations, both the city and wider area. In addition, opportunities to support and indeed enhance the bus service offer would be unlocked by development at Thanington Park, including a bus route within the site. There may be numerous bus stops, but there are not numerous buses, and none in the evenings and on Sundays. There may be even fewer when KCC has made the service cuts, as recently announced. Again, funding is the issue, and this may make a nonsense of the relevant s.106 agreement provisions. See our report at wincheapcampaigns.wordpress.com Thanington Park Access. Summary and Conclusions 7.1.10 The traffic generation and distribution from the hybrid application area development have been obtained from the Thanington Park Transport Assessment on the basis that these were previously agreed with highway officers. A comparison has been completed for the Thanington Park development traffic and the proposed hybrid application area of that development (the subject of this Transport Assessment). 7.1.11 This analysis shows that the proposed hybrid application area development generates fewer two way trips on each link of the highway network than the permitted Thanington Park development. On this basis it is demonstrated that the proposed hybrid application area development (both the first 75 units and full hybrid application area) fits within the assessment already completed for the permitted Thanington Park development. The remainder of the Thanington Park permission will therefore comprise up to 655 residential units, no B1 floor area, a local centre, a primary school and a hospice or nursing home. 7.1.12 It is concluded that the proposed development would not have any transport effects outside, or in in excess of, that already previously assessed for Thanington Park. It is hence concluded that no further Transport Assessment modelling is needed to support the hybrid application area development proposed. Thanington Without Parish Council commissioned a report from Railton TPC Ltd in April 2017 which reviews (among other issues) PPL/PBA s Transport Assessments. It makes mincemeat of their conclusions, which are in essence repeated here in 7.1.10-7.1.12. All statements from the developer and its agents should be assumed by CCC (acting on behalf of residents and electors) to be self-serving unless proved otherwise. 30 December 2017 8