From: Scott Dickson [mailto:firstname.lastname@example.org]
Sent: 07 March 2013 18:18
To: Jamie Jamieson; email@example.com; Dominic Forbes
Cc: 'Denise Saliagopoulos'; 'Bannister, Christine (Councillor)'; 'Patterson, Alan (Councillors)'
Subject: Re: Fw: Planning application Nos. 12/01700/FUL and 12/01704/CAC: Development of 96 - 104 Church Street, Staines-Upon-Thames, TW18 4DQ, for Residential Use
Dear Mr Jamieson,
Thank you for your email and attached letter of 14 February 2013. Please accept my apologies for the delay in replying. In your letter you refer to concerns you and your neighbours have over congestion at the Church Street junctions withWraysbury Road and Bridge Street, the age and therefore relevance of traffic generation figures used by the transport consultant, use of proposed parking spaces by non users of the development, the speed of traffic, and the routing of construction vehicles. I will deal with each of the matters in the same order as they appear in your letter.
In order to assess traffic generation from the existing use of the site, the developer has used a range of sites from across the UK covering a period of years between 2007 and 2011. The Highway Authority considers the years used to be acceptable and comply with guidelines.
The selection of sites within suburban and edge of town centre locations by the developer is also considered acceptable for the existing use. The application site is located close to the edge of the secondary shopping area of Staines town centre as defined by Spelthorne Borough Council’s Proposals Map of its Development Plan Document adopted in December 2009.
Developers are required to compare likely traffic generation of an existing use with that of a proposed use. The developer therefore carried out a similar exercise for forecasting traffic generation for the proposed use. Again the developer selected a range of sites from across the UK, this time within a period of between 2006 and 2011. The sites were selected from suburban and edge of town centre locations in a similar manner to the existing use, again this is because the site is in an edge of town centre location.
In order to assess whether the developer has carried out a suitable assessment of likely traffic generation, I carried out my own assessment using sites from suburban and edge of town sites only. This assessment produced similar results to those of the transport consultant.
I am therefore satisfied that the developer has selected appropriate sites to forecast likely traffic generation from the existing use and proposed use.
In terms of actual traffic generation, you are correct that the proposed development will result in more residential traffic leaving the site in the AM peak in order travel along Church Street at the same time as employment traffic is accessing neighbouring employment sites. As you say the reverse is true in the evening peak.
The developer has assessed traffic generation on the bases of the site being B1c (Light Industry), B2 (General Industry), and B8 (Storage and Distribution). In assessing the B1c and B8 elements of the site, I am satisfied that the developer has used appropriate sites, for the reasons I have given above. However for the B2 use the developer has used an industrial estate to represent traffic for one building on the existing site. I have therefore carried out an assessment assuming that the B2 use has traffic generation rates similar to a B1c use (ie a lower rate of traffic generation than an industrial estate). The two-way traffic generation figure, assuming traffic generation rates for B1c and B8 uses, is 23 in both the AM peak and PM peak. The proposed use of the site is likely to generate two-way traffic movements of 20 vehicles in the AM peak and 23 vehicles in the PM peak. The existing use of the site generates more traffic in the AM peak than in the proposed use, and a similar level to the proposed use in the PM peak.
I have also assumed that the site could be used more or less intensively under existing planning permissions. The existing uses at the site are likely to generate between 17and 54 two way movements in the AM peak and between 18 and 32 movements in the PM peak. There is a large difference in the range of traffic generation because it depends on the type of land use. For example B8 uses (commercial warehousing) have lowers rates of trip generation, but with larger vehicles, than say an industrial estate, such as the existing use, albeit on a small scale, where there are higher rates of trip generation. As a robust assessment I considered that all of the existing units to be demolished are currently used for B8 (commercial warehousing) purposes.
The proposed use of the site is likely to generate two-way traffic movements of 20 vehicles in the AM peak and 23 vehicles in the PM peak. In the AM peak this is only slightly higher (three more vehicles) than the more robust assessment, which assumes that the existing use comprises B8 businesses. In the PM peak the traffic generation is again slightly higher (five more vehicles).
Although you correctly state that the proposed use will generate more outward movements compared to the existing use in the AM peak, this is off set by the reduction in inward movements associated with the existing use of the site. The reverse is also true in the PM peak. This means that the junctions at both ends of Church Street will still operate effectively because during the AM peak for example, where there is an increase in outward movements from the site, there is also a reduction in outward movements when compared with the existing use. The reverse is true during the PM peak.
The developer is proposing an adequate number of parking spaces. Across the site the average number of spaces is equivalent to 1.64 spaces per unit. This average level of parking exceeds the average level of car ownership within the ward,in which the proposed development is located. According to Neighbourhood statistics the average car/van ownership is 1.19 vehicles per household. This shows that the proposed level of parking is adequate. If there is rouge parking, this can therefore be accommodated. However if there is rouge parking, this is a private matter, as the site will remain in private ownership, as is the case with the existing use of the site. I therefore do think it is necessary from a highway safety point of view to impose a condition requiring the developer to install an entry control system. However I will advise the planning authority that I would have no objection to the developer having an entry control system should it feel one is necessary.
There are 20 mph signs at both ends of Church Street. They are as prominent as other 20mph signs in an urban location. If drivers are exceeding the speed limit, then that is a matter of enforcement by the police. I have looked at the accident history going back 5 years. There has only been one accident reported, which was in 2007. This was due to a driver losing control of their car, due to being under the influence of alcohol. I therefore do not think that there is a requirement for installing more street signs.
A condition can be imposed which would require the developer to access and egress the site from the eastern end of Church Street.
In coming to my conclusions I have been mindful of guidelines in the National Planning Policy Framework (NPPF) which was published in March 2012. This document replaces most of the previous guidance on planning matters. The document states under paragraph 206 that planning “conditions should only be imposed where they are necessary, relevant to planning and to the development to be permitted, enforceable, precise, and reasonable”. I do not think that imposing conditions requiring modifications to the junctions at either end of Church Street or requiring additional 20mph signs to be necessary or reasonable on the grounds given above. If we were to impose such conditions without being able to demonstrate the harm that would be caused by the development, the developer is likely to contest such conditions and make an appeal. This means that we should only impose conditions where we would otherwise have to refuse an application. The NPPF states under paragraph 32 that "development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe". I do not consider the residual impacts of the development to be severe based on the grounds given above.
Transport Development Planning Officer
Transportation Development Planning
Surrey County Council
Kingston Upon Thames
Tel 020 8541 7427