SUMMARY OF EVIDENCE OF Neil James Stevens

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1 LCC19 TOWN AND COUNTRY PLANNING ACT 1990 (AS AMENDED) CONJOINED APPEALS BY CUADRILLA BOWLAND LIMITED AND CUADRILLA ELSWICK LIMITED FOR MONITORING WORKS AND EXPLORATION WORKS AT PRESTON NEW ROAD AND ROSEACRE WOOD Planning Application Ref: LCC/2014/0101 Planning Inspectorate Ref: APP/Q2371/W/15/ SUMMARY OF EVIDENCE OF Neil James Stevens TRANSPORT LANCASHIRE COUNTY COUNCIL

2 1.0 Introduction 1.1 Qualifications 1.2 I am a Bachelor of Engineering with Honours in Civil Engineering from Bolton Institute of Higher Education and a Master of Science in Transport Planning from the University of Salford. 1.3 I am the Highways Development Control Manager within the Network Management section of Community Services, Lancashire County Council (LCC). I have over 20 years experience in Transport Planning and the assessment of highway impact from major development proposals. 1.4 The evidence which I have prepared and provided in my proof of evidence is correct and I confirm that the opinions expressed are my true opinions. 1.5 I have prepared my highway proof of evidence following the lodge of an appeal by the appellant, Cuadrilla Elswick Limited, in response to the refusal of the application by Lancashire County Council as Local Planning Authority. 1.6 My evidence in conjunction with the Statement of Common Ground and the statutory consultation responses provided to the Local Planning Authority provides the Local Highway Authority response to the Transport Assessment and associated addendum/technical reports produced as part of this appeal application. The evidence considers both the highway impact of the proposed development and the mitigation measures proposed, including the influence of Traffic Management Plans. 1

3 1.7 Scope and Structure of the Evidence 1.8 My evidence considers in detail the key components of the Matters in Dispute in regard to traffic impact, as set out in the Statement of Common Ground, for ease of reference these are: 1. '. the proposed development would result in an increase in the level of traffic movements on the local network in the vicinity of the Site and in particular a significant increase in HGV movements at peak periods of each phase of the proposed development that would be severe. This is a concern given the nature of the local rural lanes, their limitations and constraints to provide suitable means of routeing to access the site from a primary corridor. 2. The LCC officer's report concludes that the impact of the increase in traffic, particularly HGV movements would be severe and which would result in a material impact on existing road users, particularly vulnerable road users and overall highway safety of which the potential is considered severe. The maximum daily flows are at a level that is a significant cause for concern when location and routeing to access the Site is considered. The routes proposed (taking into consideration pass-by provision) would still result in conflict compromising the surrounding network and environment used by existing and also unfamiliar users, particularly vulnerable road users, as well as the development related traffic. 3. LCC considers that the development would give rise to unacceptable impacts on existing road users that would be contrary to Policy DM2 of the Lancashire Minerals and Waste Local Plan. 2

4 1.9 My evidence relates principally to the highways issues associated with the rural lanes of the local road network in the area of the proposal by which it is proposed to access the site. It covers the following matters: a) Section 2 describes the site location in the context of the local and strategic road network and the proposed development. b) Section 3 highlights the relevant national and local planning policy applicable in regard to transport and this appeal application. c) Section 4 sets out the appellants submitted Transport Assessment and supporting information. d) Section 5 describes progress on transport matters which has been achieved post determination. e) Section 6 sets out why I consider the information provided in support of the appealed planning application is inadequate and why the proposed access routes are inappropriate. f) Section 7 of my evidence presents my conclusions I have considered all the planning application documentation submitted in relation to the appeal application covering 'Exploration' for the proposed site at Roseacre Wood, including mitigation measures, the original and amended Traffic Management Plan and the Traffic Management Plan Addendum (alternative proposal) as described below My evidence sets out why I consider the information provided in support of the appealed planning application is inadequate and why the proposed access routes are inappropriate. 3

5 1.12 Lancashire County Council takes its responsibility seriously with respect to the current and future use of the highway network whilst also giving a high priority to supporting growth, including supporting private sector led economic growth, the creation of jobs and access to employment, education and training. 7.4 I have highlighted the rural, narrow nature of the access roads proposed as a means of access for the Roseacre appeal application. Further, I demonstrate, with consideration for both the appellants TA and the further analysis presented within my evidence, that the proposed development will generate significant HGV movements on the existing rural lanes required for access to the proposed site. In addition, I consider the analysis presented by the appellant could underestimate demand. 7.6 I have concerns and I am of the opinion that elements of the Traffic Management Plan are unenforceable or simply are not in the control of the applicant and cannot be delivered. Therefore, the Traffic Management Plan is unacceptable with particular reference to the methodology and the approach in regard to assessment of, and the impacts on the operation of the highway network. 7.9 I consider the impact of the increase in traffic, particularly HGV movements, would be severe and would result in a material impact on existing road users, particularly vulnerable road user's pedestrians, cyclists and equestrians. I do not consider that suitable access from the major road network can be provided and this would result in highway safety issues that would be contrary to policy I consider the impact on the amenity of the local community due to increased movement of HGVs is moderate to high; the development would give rise to unacceptable impacts on existing road users that I consider would be contrary to policy. 4

6 7.11 In conclusion, my proof of evidence demonstrates that the site is remote from the major road network requiring the use of inappropriate rural lanes as a means of access. A safe and suitable access cannot be achieved due to the failings of the Traffic Management Plan and that the residual cumulative impacts of the development would be severe The development would give rise to unacceptable impacts on existing road users that would be contrary to Policy DM2 of the Lancashire Minerals and Waste Local Plan It is concluded therefore that the development should be refused on transport grounds. 5

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