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Page 1 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324 Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 1. Summary The May 2018 Transport Assessment (TA) prepared for Gladman by Prime Transport Planning fails to address the specific issues associated with the current traffic congestion on the one primary and two subsidiary routes used by the residents of South Stowmarket and the communities in the southern hinterland. The topography of the site and the surrounding road network is completely ignored. Verneuil Avenue and its continuation, Edgecomb Road, on to Combs Lane is an important alternative route to using Poplar Hill for accessing the west of Stowmarket and other locations north, south and west of Stowmarket. The Traffic Flow analysis ignores the Poplar Hill Verneuil Avenue junction traffic flows. The base traffic flow volumes are significantly lower than those surveyed by Suffolk County Council (SCC) Highways and those of the nearby, approved, Edgecomb Park development (Mid Suffolk District Council planning application 1492/15). Projected traffic flows are also correspondingly lower. This TA predicts that the Combs Ford mini roundabout year 2023 AM and PM peak traffic flow volumes will be more or less the same as those in 2013. The topography, the need to walk 800 metres to access the nearest bus services during the AM and PM peak traffic periods and the additional distances from Stowmarket mitigate against pedestrians, cyclists and users of train services. This development does not provide a genuine choice of transport options. The Edgecomb Park junction capacity assessments show that the Combs Ford mini roundabout (the Combs Lane Poplar Hill junction) is at and probably exceeding its practical capacity even before the impacts of the Edgecomb Park and this development. The RFC projections in this TA are very significantly lower than those of the Edgecomb Park TA: in 2 out of 3 instances more than 50% less despite relating to later dates. The projected travel to work percentage proportions in this TA for car drivers, car passengers and pedestrians are completely unrealistic and irreconcilable with those of Edgecomb Park or the Office of National Statistics data for South Stowmarket, Stowmarket and Mid Suffolk. Land East of Poplar Hill, Combs Ford, Stowmarket Appeal ref APP/W3520/W/18/3214324 Supporting document Traffic and road safety A critique of the Transport Assessment (submitted with planning application DC/18/02380)

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Page 1: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 1 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

1. Summary

The May 2018 Transport Assessment (TA) prepared for Gladman by Prime Transport Planning fails to address the specific issues associated with the current traffic congestion on the one primary and two subsidiary routes used by the residents of South Stowmarket and the communities in the southern hinterland. The topography of the site and the surrounding road network is completely ignored. Verneuil Avenue and its continuation, Edgecomb Road, on to Combs Lane is an important alternative route to using Poplar Hill for accessing the west of Stowmarket and other locations north, south and west of Stowmarket. The Traffic Flow analysis ignores the Poplar Hill – Verneuil Avenue junction traffic flows. The base traffic flow volumes are significantly lower than those surveyed by Suffolk County Council (SCC) Highways and those of the nearby, approved, Edgecomb Park development (Mid Suffolk District Council planning application 1492/15). Projected traffic flows are also correspondingly lower. This TA predicts that the Combs Ford mini roundabout year 2023 AM and PM peak traffic flow volumes will be more or less the same as those in 2013. The topography, the need to walk 800 metres to access the nearest bus services during the AM and PM peak traffic periods and the additional distances from Stowmarket mitigate against pedestrians, cyclists and users of train services. This development does not provide a genuine choice of transport options. The Edgecomb Park junction capacity assessments show that the Combs Ford mini roundabout (the Combs Lane – Poplar Hill junction) is at and probably exceeding its practical capacity even before the impacts of the Edgecomb Park and this development. The RFC projections in this TA are very significantly lower than those of the Edgecomb Park TA: in 2 out of 3 instances more than 50% less despite relating to later dates. The projected travel to work percentage proportions in this TA for car drivers, car passengers and pedestrians are completely unrealistic and irreconcilable with those of Edgecomb Park or the Office of National Statistics data for South Stowmarket, Stowmarket and Mid Suffolk.

Land East of Poplar Hill, Combs Ford, Stowmarket

Appeal ref APP/W3520/W/18/3214324

Supporting document

Traffic and road safety

A critique of the Transport Assessment (submitted with

planning application DC/18/02380)

Page 2: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 2 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

2. Transport policy and guidance

The TA takes as its reference the 2012 National Planning Policy Framework (NPPF), which has been superseded by the 2018 update. NPPF 2018, Section 9 Promoting sustainable transport para 102 sets out the objectives for development proposals. Para 103 states “Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.”

3. Existing situation

3.1 Site description

The site description fails to describe the site’s surrounding topography.The site is on the side of Poplar HILL. The highest point is at the north west of the site. All modes of travel from and to the site must negotiate the summit of Poplar Hill. The topography is a very serious disincentive to pedestrians, cyclists and (potential) users of bus and train services. Street lighting is only provided for half the length of the west side of the site.

3.2 Existing pedestrian and cycling provision

All movements to and from the site must negotiate the steep slopes within and around the site. Journeys via the proposed Church Road access will be longer whilst providing negligible relief from steep gradients. Realistically, the residents of the proposed development walking, cycling or using public transport will, proportionally, be significantly less than those in South Stowmarket. A further disincentive for the residents of the proposed development is that they will have to travel further and expend more energy than south Stowmarket residents to reach the same destinations.

3.3 Local highway network

Poplar Hill. The importance of Poplar Hill as the major route to Stowmarket and the hinterland communities and commercial operations is deficient in its brevity. It serves Combs, Battisford, Battisford Tye, Moats Tye, Little London, Little Finborough, Great Bricett, Wattisham including Wattisham army airfield and commercial and farming operations including the Tannery industrial complex, HVG servicing, grain storage facilities, etc. The footpath on the west of Poplar Hill adjacent to the site is less than 1 metre wide and barely suitable for single file use being overhung by brambles, stinging nettles, hedgerow debris and other vegetation for all but a few days a year. It has a long steep slope. When 2 users meet one of them must step into the road in order to pass the other. Further north the western footpath is equally restrictive and, except at driveway accesses, is not more than 1 metre wide. A survey of the northern section of Poplar Hill of the parking facilities available to the residents and businesses revealed the following:

No. of houses & businesses

Parking facilities:

Poplar Hill Off-road, in front

Off-road at the rear

Both On-road disabled bays

None

121 58 27 1 3 33

Page 3: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 3 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Hence 73% of dwellings have some parking facilities and 27% do not. The result is very high levels of on-street parking. Due to its permanent use for on-street parking, the speed reducing humps and the build out adjacent to Hill Rise, Poplar Hill effectively acts as single file road 24 hours a day. Traffic in both directions must give way to oncoming traffic leading to increased levels of noise and pollution particularly when HGV’s, and heavy agricultural vehicles and trailers are using the road. Using the local bus services entails a 20-minute walk to Combs Ford. Travelling to destinations beyond Stowmarket entails at least one change of bus. The local loop service from the centre of Stowmarket serving Poplar Hill and Verneuil Avenue/Edgecomb Road has been discontinued. The Church Road - Hillside route is one of the two routes used as a speedier alternative to Poplar Hill. It is used to gain access to Needham Road and hence Stowmarket or via Lavenham Way and Melford Road to other places further afield. Church Road slopes steeply downwards towards the junction with Hillside and beyond. A survey of the parking facilities available to the residents of Hillside revealed the following:

No. of houses

Parking facilities:

Hillside Off-road, in front

Off-road at the rear

Both On-road disabled bays

None

90 40 7 0 5 38

Hence only 58% of dwellings have parking facilities and 42% do not. The Hillside western verges are very steep and cannot be used for off-street parking. The result is extremely high levels of on-street parking. As with Polar Hill, Church Road is effectively a single file road due to the permanent on-street parking. Verneuil Avenue and its continuation, Edgecomb Road is NOT described in Section 3 Existing situation or considered in Section 6 Impact assessment. This is a serious omission in the TA. Verneuil Avenue and its continuation Edgecomb Road is the second of the two alternative routes used as a speedier alternative to using Poplar Hill. It is used to gain access to Combs Lane and hence to the services and facilities on the west side of Stowmarket including Stowmarket Leisure Centre, ASDA supermarket, in-town car parking and the shopping in the centre of Stowmarket. It also provides a more direct route to other places south west of Stowmarket including Great Finborough, Lavenham, Sudbury and Hadleigh. Both the Verneuil Avenue/Edgecomb Road and Church Road/Hillside alternative routes will be used by the residents of the proposed development. The Edgecomb Park development of up to 185 dwellings currently under construction feeds into the junction of Verneuil Avenue and Edgecomb Road via Farriers Road. A survey of the parking facilities available to the residents of Verneuil Avenue revealed the following:

Page 4: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 4 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

No. of houses Parking facilities:

Verneuil Avenue

Off-road, in front

Off-road at the rear

Both None

44 8 23 0 13

Hence 70% of dwellings have parking facilities and 30% do not. However, some of the parking spaces are not used because they are remote from and invisible to their residents. The residents prefer to park on the road. Hence the permanent presence of parked cars on the eastern side of Verneuil Avenue. Edgecomb Road. Similarly, not addressed in Sections 3 and 6 of the TA. Prior to circa 1990 Edgecomb Road was a cul-de-sac and its parking provisions reflect that status. When Verneuil Avenue and Hill Rise were built it became a through route. Edgecomb Road parking provisions remained unchanged. Additionally, some of the Edgecomb Road residents have converted their internal garages into habitable accommodation. This exacerbates the on-road parking. A survey of the parking facilities available to the residents of Edgecomb Road including residents of Thatchers Walk, Maltsters Walk and Chandlers Walk revealed the following:

No. of houses Parking facilities:

Edgecomb Road

Off-road, in front

Off-road at the rear

Both None

110 52 15 15 28

There is, on average, 0.75 parking spaces per dwelling and 25% of dwellings have no parking space. On-street parking is present 24 hours a day and is predominantly on the western side of Edgecomb Road. There are 4 road side parking bays distributed along Edgecomb Road. Vehicles parked in these bays are frequently parked at right angles to the road with the ends of the cars overhanging the footpath and projecting into the road.

3.4 Existing traffic conditions

The Poplar Hill – Verneuil Avenue junction was not included in the list of junctions surveyed. Verneuil Avenue is currently used extensively as a preferred alternative to Poplar Hill for accessing Stowmarket, particularly the services and facilities on the west side of Stowmarket and to other places – see previous comments in 3.3 Local highway network - Verneuil Avenue. The TA traffic flows on Poplar Hill compared to those in the Edgecomb Park Development TA (planning application 1492/15) and those of SCC Highways department are summarised in the table below:

Page 5: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 5 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

The table shows that in the 2013 AM peak 32 vehicles coming from Combs and going towards Stowmarket turned left onto Verneuil Avenue together with another 9 vehicles coming from Stowmarket: a total of 41 vehicles travelling north on Verneuil avenue. These movements are comparable to the 2018 Suffolk County Council ATC 5-day average of 45. In the same period 44 (11+33) vehicles were going south on Verneuil Avenue.This is somewhat lower than SCC’s 2018 5-day average of 55. Since only the northern phase of the Edgecomb Park development of 75 houses is currently under construction, these figures indicate the level of use of Verneuil Avenue as an alternative route to Poplar Hill. The residents of the proposed development will also use the Verneuil Avenue alternative route. The TA flow diagrams 14 and 15 do not show Verneuil Avenue. All traffic from and to the proposed access is shown as going either north towards Church Road/Stowmarket or south towards Combs. The SCC’s 2017 5-day average of 190 vehicles travelling from Combs towards Stowmarket compared to the 2013 figure of 147 is 29% higher indicative of 1.0663% increase per annum.

Poplar Hill - Verneuil Avenue Junction Movements

TIMELINE 20132014-

20162017 2018 2018 2019

2020-

20232023

Development Stage/Survey:

Edgecomb

Park

base1

SCC

Highways2

SCC

Highways3

Poplar Hill

base4

Edgecomb

Park

dev'd5

Poplar Hill

dev'd6

AM Peak (08.00-09.00)

From Combs to Stowmarket 147 190 166 172 245

From Combs to Verneuil Ave 32 - 45A? 40 ?

From Stowmarket to Verneuil Ave 9 - ? 11 ?

From Stowmarket to Combs 141 147 142 159 209

From Verneuil Ave to Stowmarket 11 55B17 ?

From Verneuil Ave to Combs 33 52 ?

PM Peak (17.00-18.00)

From Combs to Stowmarket 129 149E155 146 223

From Combs to Verneuil Ave 50 - 46C? 71 ?

From Stowmarket to Verneuil Ave 14 - ? 18 ?

From Stowmarket to Combs 121 167 153 141 230

From Verneuil Ave to Stowmarket 14 53D17 ?

From Verneuil Ave to Combs 39 52 ?

1. Edgecomb Park TA, Appendix J, 2013 Base Year 08.00 -09.00 & 17.00-18.00

2. Suffolk County Council ATC survey 4th May 2017 near proposed site access, 5 day averages

3. Suffolk County Council Highways ATC survey 6th September 2018, 5 day averages

4. Poplar Hill TA, Appendix C, Traffic Flow diagrams 1 & 2

5. Edgecomb Park TA, Appendix J, 2019 Future Year With Development 08.00 -09.00 & 17.00-18.00

6. Poplar Hill, Appendix C, Traffic Flow diagrams 1 & 2

A: Total 5 day 08.00-09.00 average movements going north on Verneuil Avenue

B: Total 5 day 08.00-09.00 average movements going south on Verneuil Avenue

C: Total 5 day 17.00-18.00 average movements going north on Verneuil Avenue

D: Total 5 day 17.00-18.00 average movements going south on Verneuil Avenue

E. The highest average 5 day PM peak was 16.00-17.00 at 158

Page 6: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 6 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Similarly, in the 2013 PM peak period 50 plus14 vehicles were travelling north on Verneuil Avenue compared to SCC’s 2018 5-day average of 46. There is no obvious explanation for the difference between the Edgecomb Park Development numbers and SCC’s 2018 5-day average figure. In the same period 53 vehicles were going south on Verneuil Avenue: the same number as SCC’s 2018 5-day average figure. Overall, the Edgecomb Park 2013 base traffic figures are comparable with SCC’s 2017 and 2018 5-day average traffic figures. Compared with the 2017 SCC Highway 5-day average AM peak figure of 190 this TA’s 2018 Combs to Stowmarket Poplar Hill base figure of 172 is 13% less. Similarly, the actual PM peak for Combs to Stowmarket Poplar Hill as measured by SCC Highways in 2017 during the 16:00-17:00 period was 158 compared to this TA’s 2018 figure of 153. This TA’s 2018 base figures for Poplar Hill traffic are lower than SCC’s 2017 5-day average figures.

3.5 Road safety

The SCC personal injury data system is NOT A COMPLETE RECORD OF ALL accidents just those resulting in personal injury and THEN ONLY IF REPORTED BY THE POLICE OR AMBULANCE SERVICES. Many accidents are not reported to the police. Indeed, the police will decline to visit the scene of an accident UNLESS personal injury has occurred. The first accident reported in para 3.5.15 occurred on Lavenham Way where “it was determined that the pedestrian was walking too close to the carriageway”! The footpaths along Lavenham Way are of a relatively high standard and width compared with the western side of Poplar Hill. From its junction with Tannery Road/Park Road and Verneuil Avenue the footpath is less than 1 metre wide and barely suitable for single file use being overhung by brambles, stinging nettles, hedgerow debris and other vegetation for most of the year. What then is a safe distance from the carriageway? In para 3.3.1 Poplar Hill it is reported as being “approx. 6m wide in the vicinity of the site frontage”. When 2 HGVs pass each other on Poplar Hill they are forced to slow almost to a stop. Whilst passing each other one will be touching or even riding on the footpath kerbstone whilst the other one will be hard against the grass verge bank. If an HGV and another non-HGV pass each other, at an average speed in excess of 35 mph (see para 3.4.9 table 3.1) pedestrians are forced to stand up against the hedge: overgrown vegetation not withstanding! For all pedestrians, Poplar Hill south of Verneuil Avenue is an unsafe road with a single, substantially sub-standard footpath. Pedestrians from the proposed development must cross Poplar Hill either at the proposed access or at the north west corner of the site (otherwise they must take the longer route via the Church Road access). SCC Highways in their response to the Edgecomb Park Planning application (reference 1492/15) stated their concerns regarding the sub-standard footpath on the western side of Poplar Hill and risks associated with a pedestrian crossing on Poplar Hill south of Verneuil Avenue – see SCC Highways comments dated 6 August 2015 on the Babergh-Mid Suffolk planning portal.

Page 7: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 7 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Cyclists also have the choice of using either of the proposed accesses. Crossing Poplar Hill will be no less dangerous for cyclists than it will be for pedestrians.

4. Development proposal

4.1 Access strategy For the visibility splays shown in Appendix E to conform to Movement for Streets (MfS2), section 10 visibility in the vertical plane must be provided from 2m down to 600 mm above the highway. The Poplar Hill gradient north of the proposed access at present does not meet the vertical visibility requirements. Additional specific development undertakings would be needed if this application were approved. 4.2 Pedestrian access The proposed development provides a footpath terminating in the NW corner of the site where pedestrians will have to cross Poplar Hill to gain access to the footpath on the west side of Poplar Hill. The proposed dropped kerb crossing point at the NW of the site will be south of the Poplar Hill - Verneuil Avenue junction (not Church Road as stated in 4.4.2 which in any case is badly worded). Traffic travelling towards Stowmarket will be negotiating a tight bend and be concerned primarily with on-coming traffic rounding the bend and possibly exiting Verneuil Avenue (and later the Edgecomb Park access as well). Traffic from Stowmarket will be concerned primarily with traffic exiting Church Road and Verneuil Avenue. Pedestrians will not be their first priority. Crossing Poplar Hill at this point will hazardous especially during peak traffic periods. 4.3 Cyclists The proposed development makes no specific provisions for cyclists who must share the roads within and without the site with vehicular traffic. Use of the secondary access may avoid having to surmount the Poplar Hill summit but routes from it must climb Church Road at least as far as Hillside and the return routes are no less arduous. 4.4 Access to buses There are no buses serving Poplar Hill or Verneuil Avenue during the AM and PM peak periods. During these periods the nearest bus stops providing services are at Combs Ford some 800m north of the site. As such and given the arduous topography this represents a significant disincentive to use public transport.

5. Access by sustainable modes

5.1 Access by foot

Between the site and Stowmarket is a hill, Poplar Hill, with steep and long gradients. Distances from the site by either of the proposed accesses to all facilities, services and amenities entails travelling up and down the hill on every trip. These distances are greater than those for the South Stowmarket residents on the far side of the hill. The site’s topography therefore mitigates against walking, cycling and the use of public transport.

Page 8: Supporting document Traffic and road safety€¦ · Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018 Hence 73% of dwellings have some parking

Page 8 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

It is highly unlikely and therefore unrealistic to assume that residents will achieve the walking speed of 4.8kph used in calculating the walking times in table 5.2 and over the greater distances. It would be more realistic to assume they will resort to using their cars.

5.2 Cycling

Cyclists will be deterred from making trips for the same reasons as those given in 5.1 above.

5.3 Bus services

There are no bus services from the Verneuil Avenue or Poplar Hill bus stops in the vicinity of the site during the AM and PM peak periods. During these periods the nearest bus stops providing services are at Combs Ford some 800m north of the site. Bus journey times are not less than twice those by car. Car journeys can be taken when it is convenient to the owner. Journeys by bus are dictated by the bus schedules, whether they are reliable and punctual. The proposed development provides no means to change the current status quo.

5.4 Rail

The provision of cycle parking spaces at Stowmarket Railway station is extremely unlikely to overcome the deterrents in 5.1 and 5.2 above for pedestrians and cyclists. Where there is an option to use a car for the whole or part of the journey it is very likely to be taken up.

5.5 Travel Plan1

The Travel Plan (TP) is simply a more verbose statement of that already in the TA. The governmental entreaties to the population at large to walk, cycle and use public transportation because it is good for the person and the environment have existed for years. Generally, people exercise less, are becoming more overweight and purchase ever increasing numbers of cars. The tendency of all levels of government to centralise their services at fewer and fewer locations to save costs and capital expenditure equates to more and longer journeys to reach those services. This TA and the TP contain no effective measures to change the current order and the topographical nature of the site will ensure the continuation or even accelerate the current trends. The proposed development is not in a sustainable location. The application contains no measures that would improve access by sustainable means. Contrary to NPPF para 103 this proposed development does NOT provide a genuine choice of transport modes.

1 Produced for Gladman Developments Ltd by Prime Transport, May 2018

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Page 9 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

6. Impact assessment

6.1 Traffic growth

With no access to the TEMPro and the NTEM products it is not possible to comment on the appropriateness of the “factoring” and “adjusted” operations referred to in paras 6.2.2 and 6.2.3 respectively. However, as previously shown in para. 3.4 above, Existing traffic conditions, this TA’s 2018 base figures for Poplar Hill traffic are lower than SCC’s 2017 5-day average figures. Since Poplar Hill – Verneuil Avenue were not surveyed their traffic flows are not shown in any of the 15 Traffic Flow diagrams in Appendix C. Consequently, the traffic flow diagrams are not representative of the current or future traffic flows in the local highway network. Future traffic growth resulting from the proposal and the Edgecomb Park development will impact Verneuil Avenue/Edgecomb Road, Poplar Hill and Church Road.

6.2 Vehicular trip generation

In order to validate this TA’s traffic growth and trip generation methodologies, its results and those of the Edgecomb Park development were compared where they overlap at the mini-roundabout at Combs Ford: the Poplar Hill – Combs Lane junction. The Combs Ford min-roundabout is a traffic congestion black spot in the local road network. Unfortunately, there are no comparable figures from SCC Highways. The results of the comparison are shown in the table below.

Combs Ford Mini Roundabout Peak Hour Traffic Flow Volumes

TIMELINE 2013 2017 2018 2019 2019 2023 2023

Development stage

Edgecomb Park base

1 SCC Highways

Poplar Hill base

2

Edgecomb Park w/o dev't

1

Edgecomb Park w/-dev't

1

Poplar Hill w/o dev't

3

Poplar Hill w/-dev't

4

AM Peak (08:00 - 09:00)

1271 ? 1023 1350 1395 1136 1216

PM Peak (17:00 - 18:00)

1268 ? 1095 1357 1398 1206 1284

1. Edgecomb Park TA, Appendix J: Traffic Flow Diagrams 2. Poplar Hill TA, Appendix C, Traffic Flow diagrams 1 & 2 3. Poplar Hill TA, Appendix C, Traffic Flow diagrams 9 & 10 4. Poplar Hill TA, Appendix C, Traffic Flow diagrams 14&15 The differences in the predicted traffic volumes of the 2 TA documents are so remarkable that their veracity is in serious doubt: How can the 2013 Edgecomb Park base AM Peak traffic volume be 50 greater than the 2023 Poplar Hill with development traffic volume of 1216? How can the 2023 PM peak traffic volume be just 16 greater than the 2013 Edgecomb Park base AM Peak traffic volume of 1268?

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Page 10 | Land East of Poplar Hill, Combs Ford, Stowmarket | Appeal APP/W3520/W/18/3214324

Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Why are the 2019 Edgecomb Park without development AM and PM peak volumes figures 32% and 24% higher than this TA’s 2018 base figures?

6.3 Junction capacity assessment

The maximum legal2 lengths of the vehicle types that use the local road network are:

MOTOR VEHICLES MAXIMUM LENGTH PERMITTED

Rigid axel 12m

Bus with two axels 13.5

Bus with more than 2 axels 15m

VEHICLE COMBINATIONS 16.5

Articulated HGV 16.5

Articulated HGV incorporating a low loader trailer 16.65m

TRAILERS

Drawbar trailer with at least four wheels and is drawn by a vehicle with a gross weight >3500kgs

12m

Other drawbar trailers 7m

Composite trailer that is drawn by an agricultural motor vehicle or motor vehicle with a gross weight >3500 kgs

14.04m

A trailer that is an agricultural trailed appliance manufactured on or after 1 December 1985

15

All the above equate to vehicles that would be equivalent to more than the 2 Passenger Car Units (PCUs) used in the junction capacity modelling. To satisfy the claim that the modelling is a robust/worse case a PCU of at least 2.5 should have been used for the above vehicle types.

6.4 Junction capacity assessment: Poplar Hill – Combs Lane

With no access to the PICADY and ARCADY products with which to validate junction capacity assessments, this TA’s results were compared with those of the Edgecomb Park development where they overlap at the mini roundabout at Combs Ford: the Poplar Hill – Combs Lane junction. The Combs Ford mini roundabout is a traffic congestion black spot in the local road network. The results of the comparison are shown in the table overleaf:

2 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/648185/information-

sheet-maximum-length-of-vehicles.pdf

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Edgecomb Park1 Poplar Hill2

Arm AM Peak 08:00-09:00

PM Peak 17:00-18:00

AM Peak 08:00-09:00

PM Peak 17:00-18:00

RFC Queue RFC

Queue RFC

Queue RFC

Queue

2013 Base year 2018 Observed

Combs Lane 0.637 1.71

0.508 1.02

0.560 1.30

0.480 0.90

Poplar Hill north (The Ford)

0.560 1.26

0.777 3.320

0.490 1.00

0.690 2.20

Poplar Hill south 0.870 5.69

0.778 3.25

0.400 0.70

0.330 0.50

2019 without development 2023 without development

Combs Lane 0.684 2.10

0.546 1.19

0.640 1.70

0.530 1.10

Poplar Hill north (The Ford)

0.596 1.46

0.832 4.60

0.530 1.20

0.760 3.10

Poplar Hill south 0.943 9.96

0.859 5.17

0.470 0.90

0.370 0.60

2019 with development 2023 with development

Combs Lane 0.708 2.34

0.560 1.25

0.670 2.00

0.550 1.20

Poplar Hill north (The Ford)

0.613 1.56

0.865 5.75

0.560 1.30

0.820 4.40

Poplar Hill south 0.987 14.74

0.892 6.41

0.560 1.30

0.420 0.70

1 Edgecomb Park TA, section 7, tables 7.4, 7.8 & 7.12 2 This TA, para 6.13, Table 6.11 In the above table ’Queue’ is the average queue length in PCUs. A car is 1 PCU, a HGV is 2. The higher the ‘Queue’ figure the longer the queue. RFC is the Ratio of Flow to Capacity and is a measure of a junction’s ability to process traffic. A RFC of 0.85 is generally considered to be a practical capacity and 1.0 to be its theoretical capacity. As with the comparison of traffic flow volumes in 6.2 above the comparisons of RFC’s make no logical sense. How can the RFC in the Edgecomb Park ‘2019 with development’ Poplar Hill south arm be 0.987 and the corresponding Poplar Hill ‘2023 with development’ figure be 0.560? Other observations are equally baffling… The Poplar Hill south arm AM peak RFC was over the practical level of 0.85 before the Edgecomb Park development commenced. It may well be over its theoretical capacity by 2019 and beyond even that by 2023. The Poplar Hill RFC’s for the Poplar Hill south arm in 2018 and 2023 are less than half those of the corresponding Edgecomb Park RFC’s in 2013 and 2019.

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

6.5 Person trip rates

The person trip rates used in this TA have been derived from the TRICS sample used to forecast the vehicular trip rates in 6.2 above. The person trip rates for both the Northern (75 dwellings) and the Southern (50 + 60 dwellings) parts of the Edgecomb Park development TA were derived using the Stowmarket South Ward 2011 census journey to work data. Both sets of results are reproduced below in the tables below:

The Edgecomb Park northern and the 50 dwellings of the southern developments and Poplar Hill are comparable forms of development and hence would be expected to produce the same person trip rate percentages. The remaining 60 dwellings in the Edgecomb Park southern development are expected to be sheltered/supported housing. Whilst the dwellings on Poplar Hill and the Edgecomb Park development will be approximately the same distance from the bus stops and from the services and facilities at Combs Ford, the residents of the Poplar Hill development will be on the far side of Poplar Hill. This will be a significant disincentive to making journeys on foot. At the AM and PM peak travel periods bus services are only available at Combs Ford and Lavenham Way. The following travel to work data was downloaded from the Office of National Statistics (ONS) web site:

Edgecomb Park Poplar HillNorthern Dev: 75 dwellings, Table 5.4 160 dwellings, Table 6.3 (extracts)

Trips % Trips % Trips % Trips %

Car drivers 51 67 52 67 Car drivers 84 53 82 60

Car passengers 4 5 5 6 Car passengers 34 21 23 17

Motorcycle 1 1 1 1 Motorcycle - - - -

Cyclists 5 7 5 6 Cyclists 3 2 5 4

Pedestrians 11 14 11 14 Pedestrians 35 22 23 17

Public Transport 4 5 4 5 Public Transport 3 2 3 2

Total: 76 100 78 100 Total: 159 100 136 100

Edgecomb ParkSouthern. Dev: 50 + 60 dwellings, Table 5.10

Trips % Trips %

Car drivers 56 64 51 71

Car passengers 5 6 4 6

Motorcycle 1 1 1 1

Cyclists 6 7 5 7

Pedestrians 12 14 11 15

Public Transport 7 8 0

Total: 87 100 72 100

AM Peak PM Peak

PM PeakAM Peak AM Peak PM Peak

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

The ONS data on Stowmarket South and Stowmarket percentage rates for car drivers, passengers and pedestrians (‘on foot’) percentage rates are comparable with the Edgecomb Park rates. However, given the relatively higher proportion of affordable and sheltered/supported dwellings in the Edgecomb Park development it is questionable whether the rates for the Edgecomb Park car drivers, passengers and pedestrians will exceed those of South Stowmarket. Given the adverse topography of the Poplar Hill site it is impossible to accept that during the AM and PM travel periods the residents of the Poplar Hill development will make 69% and 32% more pedestrian trips than the residents of the south Stowmarket. The position is similar for car trips. Indeed, it is impossible to accept that personal car trips will be proportionally lower for the Poplar Hill residents than those of south Stowmarket given the adverse topography of the site.

7. Local travel questionnaire

A travel questionnaire was delivered between Friday, 16 and Saturday, 18 November to all houses in:

Church Road Combs Wood Drive Verneuil Avenue including the Twinnings Edgecomb Road including Woolmers Close (part) and Tylers Way Farriers Road including Weavers Close and Millers Close Coppersmiths Park Road (the continuation of Poplar Hill) and Poplar Hill (part)

population

units

date

rural urban

Method of Travel to Work ward011qs:E05007155 parish2011 :E04012092 ualad09:Mid

: Stowmarket South : Stowmarket Suffolk

All categories: Method of travel

to work3,575 %age 13,665 %age

70,073%age

Driving a car or van 1,559 63 6,507 63 33,974 64

Passenger in a car or van 136 6 489 5 2,068 4

Motorcycle, scooter or moped 26 1 74 1 382 1

Bicycle 156 6 468 5 1,393 3

On foot 326 13 1,332 13 4,069 8

Bus, minibus or coach 50 2 121 1 719 1

Train 57 2 427 4 1,419 3

Taxi 4 0 17 0 70 0

Underground, metro, light rail,

tram1 0 6 0 61 0

Work mainly at or from home 67 3 367 4 4,163 8

Other method of travel to

work10 0 43 0 252 0

Employment 77 3 410 4 4,415 8

Sub-total: 2,469 100 10,261 100 52,985 100

Not in employment 1,183 3,814 21,503

QS701EW - Method of travel to work

ONS Crown Copyright Reserved [from Nomis on 14 November 2018]

All usual residents aged 16 to 74

Persons

2011

Total

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Approximately 400 questionnaires were delivered and 81 were returned by the end of November 2018. The travel questionnaire format is shown in attachment 1. The contents of each questionnaire were entered on a spreadsheet and data summaries produced for the 08:00 – 09:00 AM and 17:00 – 18:00 PM peak traffic periods. Except where indicated otherwise on the returns, all trips were recorded. By focussing on the AM and PM peak travel periods direct comparisons can be made with those predicted by this TA.

7.1 All results

The following table summarises the results of 81 travel questionnaires.

TRAVEL QUESTIONNAIRE RESULTS 08:00-09:00 Hour Traffic 08:00-09:00 Hour Traffic %

Modal Split

Arrivals Departures

MON TUE WED THU FRI MON TUE WED THU FRI TOTALS

Car 2 2 2 3 1 26 19 26 23 22 126 64

Passengers 1 0 1 1 0 12 10 14 11 7 57 29

Van 0 0 0 0 0 2 1 0 1 1 5 3

Motorcycle 0 0 0 0 0 0 0 0 0 0 0 0

Cycle 0 0 0 0 0 0 0 1 1 1 3 2

Walking 0 0 0 0 0 0 2 2 2 0 6 3

Public Transport

0 0 0 0 0 0 0 0 0 0 0 0

Taxi 0 0 0 0 0 0 0 0 0 0 0 0

Total: 3 2 3 4 1 40 32 43 38 31 197 100

17:00-18:00 Hour Traffic 17:00-18:00 Hour Traffic % Modal Split

Arrivals Departures

MON TUE WED THU FRI MON TUE WED THU FRI TOTALS

Car 24 24 22 22 32 2 2 8 1 5 142 70

Passengers 8 10 5 5 9 0 0 4 1 2 44 22

Van 2 2 2 3 3 1 0 0 0 0 13 6

Motorcycle 0 0 0 0 0 0 0 0 0 0 0 0

Cycle 0 0 1 0 0 0 0 0 0 0 1 0

Walking 1 1 0 1 0 0 0 0 0 0 3 1

Public Transport

0 0 0 0 0 0 0 0 0 0 0 0

Taxi 0 0 0 0 0 0 1 0 0 0 1 0

Total: 35 37 30 31 44 3 3 12 2 7 204 100

The above table shows that the first-choice mode of transport is by car with the second by van. The percentage modal split for the AM and PM periods was 64% and 70% compared to 52.8% and 60.3% in this TA. No trips were made by Public Transport, only 3 by Cycling and only 4 by walking. The average number of trips per household during the AM and PM periods were 1.7 and 2.0 respectively compared with this TA’s prediction of 0.78 and 0.71 respectively.

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

7.2 Combs Wood Drive

The following table summarises the travel questionnaires results received from 22 households in Combs Wood Drive.

COMBS WOOD DRIVE TRAVEL QUESTIONNAIRE RESULTS

08:00-09:00 Hour Traffic 08:00-09:00 Hour Traffic % Modal Split

Arrivals Departures

MON TUE WED THU FRI MON TUE WED THU FRI TOTALS

Car 0 1 0 0 0 12 10 12 10 11 56 67

Passengers 0 0 0 0 0 5 3 7 4 4 23 27

Van 0 0 0 0 0 0 0 0 0 0 0 0

Motorcycle 0 0 0 0 0 0 0 0 0 0 0 0

Cycle 0 0 0 0 0 0 0 0 0 0 0 0

Walking 0 0 0 0 0 0 1 2 2 0 5 6

Public Transport

0 0 0 0 0 0 0 0 0 0 0 0

Taxi 0 0 0 0 0 0 0 0 0 0 0 0

Total: 0 1 0 0 0 17 14 21 16 15 84 100

17:00-18:00 Hour Traffic 17:00-18:00 Hour Traffic % Modal Split

Arrivals Departures

MON TUE WED THU FRI MON TUE WED THU FRI TOTALS

Car 11 14 9 11 12 0 1 0 1 0 12 71

Passengers 4 4 2 2 4 0 0 0 0 0 4 24

Van 1 1 1 1 1 0 0 0 0 0 1 6

Motorcycle 0 0 0 0 0 0 0 0 0 0 0 0

Cycle 0 0 0 0 0 0 0 0 0 0 0 0

Walking 1 1 0 1 0 0 0 0 0 0 0 0

Public Transport

0 0 0 0 0 0 0 0 0 0 0 0

Taxi 0 0 0 0 0 0 0 0 0 0 0 0

Total: 17 20 12 15 17 0 1 0 1 0 17 100

The above table shows that the first-choice mode of transport is by car with the second by van. The percentage modal split for the AM and PM periods was 67% and 71% compared to 52.8% and 60.3% in this TA. No trips were made by Public Transport or Cycling and only 5 by Walking. The average number of trips per household during the AM and PM periods were 2.8 and 0.6 respectively. There is a public footpath from the north-west end of Combs Wood Drive to the south-east end of Lindsey Way and hence to Lavenham Way, Combs Ford and Stowmarket which may account for the small number of walking trips.

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

7.3 Church Road

The following table summarises the travel questionnaires results received from 7 households in Church Road.

CHURCH ROAD TRAVEL QUESTIONNAIRE RESULTS 08:00-09:00 Hour Traffic 08:00-09:00 Hour Traffic %

Modal Split

Arrivals Departures

MON TUE WED THU FRI MON TUE WED THU FRI TOTALS

Car 0 0 0 1 0 2 2 3 1 2 11 55

Passengers 0 0 0 0 0 0 3 4 0 1 8 40

Van 0 0 0 0 0 0 0 0 0 0 0 0

Motorcycle 0 0 0 0 0 0 0 0 0 0 0 0

Cycle 0 0 0 0 0 0 0 0 0 0 0 0

Walking 0 0 0 0 0 0 1 0 0 0 1 5

Public Transport

0 0 0 0 0 0 0 0 0 0 0 0

Taxi 0 0 0 0 0 0 0 0 0 0 0 0

Total: 0 0 0 1 0 2 6 7 1 3 20 100

17:00-18:00 Hour Traffic 17:00-18:00 Hour Traffic % Modal Split

Arrivals Departures

MON TUE WED THU FRI MON TUE WED THU FRI TOTALS

Car 1 0 0 1 2 0 0 2 0 2 8 73

Passengers 0 0 0 0 1 0 0 1 1 0 3 27

Van 0 0 0 0 0 0 0 0 0 0 0 0

Motorcycle 0 0 0 0 0 0 0 0 0 0 0 0

Cycle 0 0 0 0 0 0 0 0 0 0 0 0

Walking 0 0 0 0 0 0 0 0 0 0 0 0

Public Transport

0 0 0 0 0 0 0 0 0 0 0 0

Taxi 0 0 0 0 0 0 0 0 0 0 0 0

Total: 1 0 0 1 3 0 0 3 1 2 11 100

The above table shows that the first-choice mode of transport is by car with the second by van. The percentage modal split for the AM and PM periods was 55% and 73% compared to 52.8% and 60.3% in this TA. No trips were made by Public Transport or Cycling and only 1 Walking trip. The average number of trips per household during the AM and PM periods were 2.8 and 0.6 respectively. Combs Wood Drive and Church Road are adjacent to the proposed development. The mix of housing types, households and modes of travel in the proposed development will mirror those of Combs Wood Drive and Church Road. This TA predicts a completely different mix of mode of travel and, at the same time, much lower use of private transport. The above tables show today’s real modes of travel for people living very close to the proposed development. The travel questionnaires, the Edgecomb Park TA, the Office of National statistics and SCC traffic surveys all positively demonstrate this TA’s trips predictions to be at least severely optimistic and self-serving.

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

8. Conclusions The applicant has a statuary obligation to produce a Transport Assessment3. Clearly the primary objective of this TA is to demonstrate that the proposed development will have zero impact on the local road network and that it is a sustainable development. The topography of the site does not feature in any of the narrative or calculations. The topography of the site is a crucial feature of the site and its immediate surroundings. It will influence residents’ decisions on what modes of transport they will use and when. The travel questionnaires, the Edgecomb Park TA, the Office of National statistics and Suffolk County Council traffic surveys all positively demonstrate this TA’s trips predictions to be at least severely optimistic and self-serving. There is no evidence to support these over ambitious predicted modes of travel. Traffic. The assessment is based on an incomplete definition of the local road network. The 2 alternatives to using the Poplar Hill route to access Stowmarket and beyond are not considered for their impact on the local road network. When comparing this TA’s traffic flow projections and RFC’s with those of the Edgecomb Park TA for the Combs Ford mini roundabout the findings of this TA are illogical and incomprehensible. Report prepared by Mr R K Paton, Chartered Engineer, Fellow of the Institution of Engineering and Technology for the Save Mill Mount Field network.

Poplar Hill North Poplar Hill North with traffic calming

Edgecomb Road Poplar Hill south with Mill Mount Field to the right

3 NPPF para. 32 and 2012NPPF 2018 Para. 111 & Annex 2

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

Attachment 1: Travel questionnaire

URGENT

The Save Mill Mount Field network will be contesting the appeal by Gladman

Development Ltd for the application to build up to160 houses on Mill Mount Field. To

contest Gladman’s Traffic Assessment figures we need to have some actual traffic and

people movement numbers of those in the vicinity of Mill Mount Field.

The object of the questionnaire is to record ALL YOUR TRIPS in a TYPICAL WEEK to

and from your address. A trip is a single, one-way journey by one person. If you carry passenger(s)

then add the time and number in the passenger row. Please record journeys using cycle, taxi, public

transport or walking in the appropriate column.

This questionnaire was delivered by

It will be collected starting Wednesday, 21st November 2018

Or if you prefer, please deliver to

THANK YOU FOR YOUR HELP, ATTENTION AND CONSIDERATION

Travel Questionnaire: Trips made FROM and TO your address.

Your address including post code please:

FROM YOUR ADDRESS

Number at address

Time out Sunday

Time out Monday

Time out Tuesday

Time out Wednesday

Time out Thursday

Time out Friday

Time out Saturday

Total trips

Examples Car trips outward

2 10:00 14:00

08:00 09:00

08:00 08:00 08:00 09:00

08:00 09:00

11:00 19:30

12

Car

Van

Motorcycle

Passenger(s)

Cycle

Walking

Public Transport

Taxi

TO YOUR ADDRESS

Time in Sunday

Time in Monday

Time in Tuesday

Time in Wednesday

Time in Thursday

Time in Friday

Time in Saturday

Total trips

Example Car trips inward

12:00 7:30

16:30 18:00

16:30 16:30 16:30 18:00

16:30 18:00

12:30 22:00

12

Car

Van

Motorcycle

Passenger(s)

Cycle

Walking

Public Transport

Taxi

Name (please print) Signature

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Save Mill Mount Field Network | Supporting document -Traffic and road safety | December 2018

About the Save Mill Mount Field Network

We represent 1,500 local residents, from Stowmarket, Combs Ford, Battisford, Moats Tye

and Little Finborough, who signed a validated petition to Mid Suffolk District Council

(MSDC) objecting to planning application DC/18/02380. The proposed development site

is known historically as Mill Mount Field.

Our full submission consists of the following documents:

1. A statement of case

2. Grade 1 listed St Mary’s Church and its setting

3. Impact of the development on the landscape

4. Mill Mount Field – a valued landscape

5. Archaeological potential of the site

6. Mind the gap! Maintaining the strategic gap between Stowmarket and Combs

7. Traffic and road safety

Contacts for further information

Telephone: Desiree Shelley on 07801 949205 or Sara Waterer on 07702 102072

Email: [email protected]

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