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Technical Note No. 4 Project: Former Barkers Nursery, Clitheroe Title: Response to LCC comments on Transport Assessment (TL /3/2014/0071) Date: 14 April 2014 1.0 Introduction

1.1 The purpose of this Technical Note is to provide a response to the comments

raised by Lancashire County Council (LCC) as Local Highway Authority, dated 31

March 2014, on the proposed Transport Assessment, reference TL /3/2014/0071.

The comments also reflect discussions as per our meeting on 02 April 2014 and

subsequent email correspondence.

1.2 Cameron Rose Associates (CRA) response to each point is detailed under the

quoted LCC comment.

1.3 LCC Comment:

I have several comments on the adequacy of the car park.

1. Four motorcycle parking bays are required – there do not appear to be any

shown on the car park layout.

2. CRA should show that the car park will accommodate staff parking during

periods of peak demand.

3. Is it the intention to provide for one shopping trolley storage area only?

Considering the distances involved within the car park and between the

two units, it would seem that more trolley storage areas will be required.

This may reduce the number of parking spaces available within the car

park.

1.4 CRA Response:

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As requested four motorcycle parking spaces have been incorporated into the

Masterplan. These are illustrated on the attached Masterplan as discussed in our

recent meeting.

As discussed, staff parking is incorporated into the TRICS surveys that have been

used as a basis for the parking accumulation assessment. Surveys included within

the TRICS database incorporate all vehicles travelling into and out of the site,

therefore will also count staff travelling by car and parking on site. In addition, it

should be noted that Aldi seek to employ staff from a local area, maximising the

opportunity for staff to travel via sustainable modes. Active Aldi travel plans

highlight that a high proportion of staff walk to work. As highlighted in the

Framework Travel Plan submitted with the planning application this will form a key

objectives for the travel plan for the site.

As advised in our meeting, discussions have been held with the operator of Unit 2

and there requirements for trolley parking has been incorporated into the attached

Masterplan. As discussed Aldi use coin operated trolley locks as standard, this will

also be adopted by the other operator. This will ensure that trolleys are returned to

bays after use. The gradient of the trolley bay areas are such that the trolleys will

be prevented from rolling from the designated storage areas.

1.5 LCC Comment:

The maximum proportion of the car park used for parking should be 90% of the car

park capacity to ensure that the car park is effectively used. I would recommend

that a condition should be attached to any planning consent that may be granted

requiring the preparation of a car park management plan including provision for

quarterly monitoring of the car park and proposals for the reduction in demand to

95% of the car park capacity. If this is not successful, a management plan for

parking on the highway will be required.

1.6 CRA Response:

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We are concerned with the wording and suitability of the condition proposed. For

an employment land use, where employers have control over their employees use

of the car park, limiting the capacity of a car park to a defined limit is achievable.

In a retail environment the operator does not have the ability to dictate to

customers whether they use the car park or not. The operator can ensure that

measure are in place to encourage the use of alternative modes i.e. through the

provision of cycle parking and the upgrade proposed to the local bus stops. The

operator can also implement control measures to reduce long stay parking of the

car park, to enhance its efficient operation.

It is common place at Aldi stores that where issues with parking by non Aldi

customers occur, a two tiered management approach is implemented. The first

involves signage within the car park to notify users of the 90 minute parking

restriction and that parking charge notices will be applied to those in breach.

Should this be inefficient to prevent a breach, the second stage will be to

implement a management control system within the car park, using Automatic

Number Plate Recognition (ANPR). This ensures that the car park is only used as

a 90 minute shopper’s car park and not abused by long stay vehicles. If necessary,

this system will be implemented at the proposed store.

1.7 LCC Comment:

In LCC's estimation, the trip rate for the non-food component of the development

will be significantly higher than the CRA estimate. CRA have used 3 sites from

TRICS to determine the trip rates and TRICS cautions against using less than 20

sites for the determination of the 85th percentile trip rate. LCC have used 19 sites,

although this was possible only by using records from 2000.

The LCC Saturday peak trip rates for the non-food component are 4.86 arrivals,

and 4.54 departures. This compares with CRA rates of 2.48 arrivals and 2.14

departures. This results in an extra 15 vehicles using the car park on a Saturday.

This will take the demand to be greater than the capacity and will lead to customers

parking cars in the public highway.

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This new data will not significantly affect the traffic flow estimates on the highway.

1.8 CRA Response:

We are concerned that issues that were agreed, in writing, during pre-application

discussions are now being questioned. Our client paid for pre-application advice in

good faith, to minimise the number of issues faced post submission. Our

discussions and correspondence with LCC were extensive to ensure that we

addressed any potential concern/ issues LCC may have within the application

package. CRA are concerned that LCC’s need to question previously agreed

parameters is causing the client unnecessary costs and delays.

For your records, CRA presented average and 85th percentile trip rates in Table 6-3

of ‘Technical Note 1 – Transport Assessment Scoping Note’ (July 2013). In LCC’s

letter dated 07 August 2013, the use of the 85th %tile trip rates as opposed to the

average trip rates was recommended. CRA acknowledged and accepted this

request in ‘Technical Note 2 – Response to LCC’s comments on TA Scoping Note’

(August 2013). LCC again acknowledged and accepted the use of these trip rates

in an email dated 15 August 2013.

As stated above the data detailed will have little impact on trip generation and

therefore the operational performance of the local highway network. LCC are

however questioning the operation/ capacity of the car park.

As stated in my previous response the use of 85th percentile trip rates to estimate

car park occupancy is wholly inappropriate. The assessment combines a number

of worse case scenarios and takes no account of linked trips between the two units.

As stated in the Transport Assessment, the average shop duration of an Aldi

customer is 26 minutes, therefore each car parking space could potentially be used

by two vehicles within an hourly period, this is simply not reflected in a car park

accumulation assessment, which assumes that if a vehicle arrives within an hour

period, it occupies a space for the duration of that hour.

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As discussed in our recent meeting, Aldi have a minimum requirement for parking,

dependent on store size. This requirement is obviously increased with the

presence of an additional operator on site. The parking provision at the proposed

site exceeds this requirement. As commercial operators, Aldi would not prejudice

the successful operation of one of their stores by providing insufficient car parking.

Aldi are acutely aware that if a customer was continually unable to park at the store

they would simply shop elsewhere.

Furthermore, LCC have acknowledged acceptance of average trip rates for car

park accumulation assessment on numerous retail applications within the County,

even where 85th percentile trip rates were used for trip generation purposes.

Therefore, a precedent has been set for the use of average trip rates in parking

accumulations and the information detailed in the Transport Assessment is

appropriate.

1.9 LCC Comment:

Please refer to the (my) 'Comments on Transport Assessment scoping note', under

Committed Development traffic flows, 3/2012/0942 dated 7 August 2013.

Information from RVBC suggests that the Standen development should now be

considered to be a committed development. CRA is asked to confirm that proposed

developments (principally the Standen site) do not significantly affect the gravity

model used, bearing in mind that the main vehicular access to the Standen Estate

is off Pendle Road.

1.10 CRA Response:

Again, CRA express concerns that parameters that were agreed and confirmed as

acceptable, in writing, during pre-application discussions are now being

questioned. To clarify LCC requested that the distribution presented in Technical

Note 1 be re-examined in a letter dated 07 August 2013. As requested CRA

revised the distribution and requested acceptance of this in Technical Note 2. LCC

accepted the revised distribution in their email dated 15 August 2013.

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Planning application 3/2012/0942, is not a committed development and at the time

of application was not (nor still is) supported by Ribble Valley Borough Council, by

way of planning approval. Assessment of this application and a number of other

applications was undertaken as a sensitivity assessment on a without prejudice

basis within the Transport Assessment. This methodology was accepted by LCC,

during scoping discussions.

Although it is considered inappropriate that this issue be raised given the previous

acceptance of the gravity model, CRA have undertaken the required assessment.

An additional 1,040 households have been added to the gravity model to reflect the

potential Standen development. In order to calculate the potential increase in

population this number has been multiplied by the average household size in the

UK i.e. 2.3 people per household (2011 Census). The additional 2,392 people

have been added to gravity model based on access off Pendle Road.

This will result in an additional 1.7% of development traffic travelling to/ from the

A671 Queensway or six two-way trips during the PM and Saturday peaks, with an

associated reduction in traffic elsewhere on the network. This is therefore

considered not to be significant.

1.11 LCC Comment:

The local features mentioned by CRA do not appear to be unresolvable. In this

environment we would be looking to ensure a forward visibility of 43m which again

would seem to be achievable. I do not consider that on-street parking is so severe

here as to rule out the introduction of a pedestrian crossing. This location could

accommodate a new puffin crossing and I consider its benefits would outweigh the

impacts on residential amenity.

1.12 CRA Response:

As per Lancashire County Councils policy, the provision of a Puffin crossing facility

on Whalley Road, in association with the proposed retail development at the former

Barkers Nursery, has been assessed by reference to the Department for Transport

Assessment Framework (Local Transport Note 1/95).

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Drawing number 131-01/GA-02 shows the proposed location of a puffin crossing on

Whalley Road based on these requirements, for approval.

1.13 LCC Comment:

I do not see this request for a footway along Littlemoor as facilitating development

for a third party. I see this request as facilitating the development of this discount

store. The position is that this store will attract multi-modal traffic which otherwise

would not be so attracted. Considering the proposed pedestrian / cycle access to

the Standen Estate, not 150m from the propose discount store, it seems to be

entirely reasonable and appropriate to ask for a strip of land from the development

site to improve facilities for pedestrian traffic. It would not have been possible to

ask the Standen Estate developer to provide this facility as that developer does not

own the site. The provision of a footway along the discount store site can only be

created by the owner / developer of the site. The fact that the site is being

developed and will attract pedestrian and cycle traffic is sufficient reason for the

creation of a footway here.

It is normal practice to ask a developer to pay for and if necessary provide some

land for the creation or improvement of a footway along an adopted highway,

particularly in an urban area. Consequently, even if the Standen Estate

development was not to be developed, I would request an improvement to the

footway here, having regard to the residential areas along Littlemoor. The fact that

there is a good chance that the residential development on Standen Estate is to be

carried out provides a stronger case for this request.

The creation of a footway here will not mean that there would be no space for

landscaping along this boundary. I appreciate that these works will result in the

existing hedgerow being removed; but with the advances in landscape gardening I

would think it is possible to replant a similar hedge along the back edge of the

proposed footway fairly quickly which would provide a similar screen.

I would have an objection to this development proposal if the provision for

pedestrians along the Littlemoor frontage of this site were not improved.

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1.14 CRA Response:

Imposing a condition on a development should only be done if, without such a

condition the development would be deemed unacceptable.

As stated previously the Standen Site application is not supported by Ribble Valley

Borough Council at the present time, by virtue of the officer’s recommendation. It is

therefore not a committed development. Therefore any potential impact of this

development has no bearing on determining the acceptability of this application.

NPPF states that ‘Development should only be prevented or refused on transport

grounds where the residual cumulative impacts of development are severe’.

In order to assess the impact of the requested footway, guidance has been sought

on the recommended walking distance to a shop. The recommended walking

distance to a shop is identified as 400 metres (with a desirable distance of 200

metres) within the IHT guidelines Providing for Journeys on Foot (2000), this

distance is considerably reduced if carrying heavy shopping bags. Excluding the

walking distance within the proposed development, a 400 metre walking distance of

the proposed access via Little Moor Road would incorporate 16 residential

properties; this would be increased to 23 residential properties if increasing the

distance to 500 metres. Even if all 23 of these residential properties choose to

shop at the proposed development, the requirement for the provision of a footway

is considered wholly inappropriate and unjustifiable given these numbers.

It is therefore proposed that a footway will not be provided, as there is no

requirement in association with the proposed development. It is also noted that

based on the evidence provided the residual cumulative impacts of development

without the footway are not severe.

In addition and as discussed in our recent meeting, the land required to provide the

footway does not form part of the developable land option and it is therefore not in

the control of our client. Discussions with the landowner regarding the provision of

this land, have been unsuccessful. Therefore it is not possible to ask the developer

to provide this facility, as the developer does not own the land.

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1.15 LCC Comment:

It may not be possible to construct a full width footway here because of the need to

retain the mature trees. However, much of the verge is unusable because material

has been dumped within the verge. Some of this could be cleared up and part of

the verge made suitable for pedestrian use. The normal procedures should be

followed in carrying out this work.

1.16 CRA Response:

Following on site investigations we are unable to identify the material which has

been ‘dumped within the verge’ and therefore seek clarity on this issue so that this

matter can be resolved.

Furthermore the material that s present on the verge is a granulate material.

Installation of a footway at this location would require a construction depth of

250mm, which would result in significant damage to the mature tree routes and

likewise tree roots would cause significant damage to the footway.

1.17 LCC Comment:

The proposed bus stop improvements need to be investigated. My suggestion is

that the north-bound bus stop should be moved south away from Parker Avenue,

and away from the BT box. The designer of the improvements should undertake

site investigations and propose solutions to the issues raised by CRA. If at all

possible a shelter should be provided for both bus stops, although the north-bound

bus stop will be more of a challenge than the south-bound bus stop in this regard.

1.18 CRA Response:

As requested, improvements to the bus stops will be implemented. The proposals

are illustrated on the attached plan 131-01/GA-02 for approval.

1.19 LCC Comment:

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This response is probably acceptable, but in the absence of more detailed

information concerning the gradient of the paving and provision of barriers to

prevent the migration of the trolleys, it is difficult to conclude whether this measure

will be adequate.

1.20 CRA Response:

Additional information was provided in our recent meeting (02/04/14). I trust this

issue is now resolved.

1.21 LCC Comment:

The kerb radii at the vehicular access should be reduced to 6m, unless there is a

problem with access by delivery vehicles. If this is the case then tracking diagrams

should be submitted to show that 6m radius kerbing would be inadequate.

It is not clear what sort of delivery vehicles will use the service area north of Unit 2.

Please ask the developer to show that these vehicles will be able to turn around in

the service area and will not be required to reverse through the car parking area

west of Unit 2.

1.22 CRA Response:

Please see attached plan 131-01/GA-01_Rev B illustrating the 6m kerb radii as

requested.

As detailed in the accompanying Transport Assessment, Unit 2 will receive

approximately three deliveries a week. As can be seen from the attached tracking,

service vehicles are not required to reverse through the car parking area, west of

Unit 2. The proposed servicing strategy is in line with a number of other

developments within the County. Please see attached plan 131-01/ATR-04

illustrating the proposed service vehicle route.