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Documents: PA15/04394 | Highways England Response 03/06/2015

Via http://planning.cornwall.gov.uk:8181/rpp/showimage.asp?j=PA15/04394&inde... [please note this has been put through an OCR so it is important to check the original]

Our ref: as yours
Your ref: PA15/04394 1
Sally Pan'sh
Asset Manager

Mr Peter Bainbridge Ash House

Planning & Enterprise Service FaicOn Road

Cornwall Council Sowton industrial Estate

Circuit House Exeter EX2 7LB

Pydar Street

Truro TR1 1EB Direct Line: 01392 312505

3 June 2015



Dear Mr Bainbridge

A30(T) : Erection of retail development comprising Class A1 and Class A3 and/or A1
units, including all associated access, servicing and infrastructure works, car parking,
public realm improvements and landscaping together with enhancement works including
footpaths. car parking, bird hide and landscaping to the nature reserve and surrounding
land - Hayle Shopping Park and Marsh Lane Nature Reserve, Marsh Lane. Hayle,
Cornwall


Thank you for consulting Highways England on the above planning application. We have
considered the submitted information and our formal recommendation is attached.

In summary, the transport evidence base is incomplete and further work is required in order to
address Highways England’s concerns. We are recommending that permission is not granted
for a period of 6 six months to allow the applicant sufficient time to undertake the additional
work, the details of which are described therein.

I trust the above is clear but if you have any queries. please do not hesitate to contact me.
Yours sincerely

Network Delivery & Development South West - Growth & Improvement
Email: saily.parish@highwaysengland.oo.uk
cc: Mike Howell, CH2M
Registered office Bridge House, 1 Walnut Tree (Jose, Guldford GU14LZ f INVESTORS
Hg'ways England Company Lin-fled mastered in England and Wales number 09346363


Developments Affecting Trunk Roads and Special Roads

Highways England Response & Formal Recommendation to an

Application for Planning Permission


From: Divisional Director. Network Delivery and Development, South West
Region, Highways England.

To: Cornwall Council
CC: DtT c/o Highways England Growth and Economic Development Team

Council's Reference: PA15/04394

Referring to the notification of a planning application dated 13 May 2015 your reference
PA15/04394 in connection with the A30,- Erection of retail development comprising
Class A1 .and Class A3 and/or A1 units, including all associated access, servicing and
infrastructure works, car parking, public realm improvements and landscaping together
with enhancement works including footpaths, car parking, bird hide and landscaping to
the nature reserve and surrounding land, Marsh Lane Hayle, notice is hereby given that
Highways England’s formal recommendation is that we:

a) offer no objection;
b) recommend that conditions should be attached to any planning permission that may be granted (see Annex A - Highways England recommended Planning Conditions);
c) recommend that planning permission not be granted for a specified period (see Annex A - non determination);
d) recommend that the application be refused (see Annex A - Reasons for recommending-Refusal):

Should you. decide to not accept this Recommendation you have 21 d ys to aka a
challenge, through referral to the Secretary of State for Trans - (SoStT
Signed by
Date: 03/06/15
Name: Sally Parish Position: As manager
Highways England: Level 1, Ash House, Falcon Road, Sowton Industrial
Estate, Exeter, EX2 &L)

-------------------
Annex A

HIGHWAYS ENGLAND ("we") has been appointed by 'the Secretary of State for
Transport as strategic highway company under the provisions of the Infrastructure Act
2015 and is the highway authority, traffic authority and street authority for the Strategic
Road Network (SRN). The SRN is a critical national asset and as such works to ensure
that it operates and is managed in the public interest, both in respect of current activities
and needs as well as in providing effective stewardship of its long-term operation and
integrity.

This response represents our formal recommendations with regard to planning
application PA15/04394 and has been prepared by the Asset Manager for Devon and
Cornwall.

We have undertaken a review of the relevant documents supporting the planning
application to ensure compliance with the current policies of the Secretary of State as
set out in DtT Circular 02/2013 “The Strategic Road Network and the Delivery of
Sustainable Development” and the DCLG National Planning Policy Framework (NPPF).
being advised on this matter by our consultants. CH2M.

Statement of Reasons

Proposals

The proposal site is located off Marsh Lane, east of the existing West Cornwall
Shopping Park (WCSP). The retail development proposals consist of a total of 9.848m2
of net tradable area and 765m2 GFA of cafe/restaurant use. This is a small reduction of
total floor space when compared to the previously application for development on the
site which was refused by Cornwall Council (PAM/00532). It is noted that the previous
application was not refused on highway grounds.

The application is supported by a Transport Assessment (TA) prepared by Vectos.

The revised development will provide approximately 516 car parking spaces together
with cycle parking. It should be noted that the 516 car parking spaCes has been taken
from the application form whereas the TA refers to 460 parking spaces. To put this into
context, the existing West Cornwall Retail Park, which is adjacent to the proposed
development, has approximately 200 spaces.

It should also be noted that the applicant has offered to enter into a Unilateral
Undertaking, such that development will not commence until such time as the
redevelopment of the Hayle Rugby Club (application PAM/02920) has commenced.
The purpose of the Unilateral Undertaking is to resolve the second reason for refusal of
application PA14/00532, that there is a sequentially preferable site (the Rugby Club
site).‘This means however that the Cranford development would only proceed On the
basis that it would be the second major retail development on Marsh Lane.

The redeveloped rugby club will have (subject to planning permission being granted)
596 parking spaces. 10,211 m2 of net tradable area and 951 m2 of cafe/restaurant use.
To put this into context of the existing retail development on Marsh Lane, should the
Cranfords development also be permitted, parking at the retail park would increase from
around 200 to 1,300, a sixfold increase. As part of the Rugby Club redevelopment, the
Loggans Moor roundabout is to be improved and converted to a traffic signal controlled
roundabout.

---------------------------------------
in terms of compliance with DtT Circular 02/2013, the Rugby Club site should be
considered as committed development 'and the traffic impacts of the Cranfords
development should be assessed on the basis that the Rugby Club development and
the associated highway interventions are already in place.

The access from the A30 into the development would be off Marsh lLane. No further
improvement to Loggans Mobr roundabout are proposed as part of the Cranfords
development. As stated in paragraph 4.5 of the'TA, the purpose of the report is to
demonstrate that the proposed Cranford retail park scheme at Marsh Lane and the
Hayle Rugby Club retail park scheme proposed at Hayle Rugby Club can easily be
accommodated in highways and transportation terms.

Assessment Methodology

All transport assessment work utilises the previously'acceptaj Loggans Moor VISSIM
microsimulation model. It is accepted that the base model validates to 2013 traffic
conditions and‘that the future year model adequately replicates the operation of the
highway improvements previously considered and accepted in relation to application
PAM/00532 which are identical to those proposed as part of the Rugby Club
redevelopment. Therefore provided that the traffic flows associated with the proposed
developments are included in the future year model correctly and that the model
demonstrates that the impacts of Cranfords development are not severe when added to
the RFC development, then the Cranfords development would be acceptable.

It should be noted at paragraph 5.4 of the TA that Vectos consider that the impact of the
revised development should be deemed to be acceptable by virtue only of the fact that it
is smaller than that already accepted. The basis against which acceptability is to be
determined has however changed in that the revised application effectively assumes
that the Rugby Club development is committed development already in place rather
than a competing option.

Set out in section 5 of the updated TA are a number of amended assumptions which
relate to the assessment of the traffic impacts of the proposed development. Each of
these is considered below:

Background Traffic Growth - Trads data is now available for 2014 and comparison with
the 2013 data shows a reduction of 1.8% in traffic flow. This has been taken into
account in deriving future year traffic forecasts. This is agreed;

Opening year - this has been revised to 2017;

Trip Rates - the selection criteria for Saturday assessments has-been changed to
exclude sites surveyed prior to 2004. This has resulted in slightly lower Saturday trip
rates than those previously accepted. The revised methodology is however accepted.

A3 Uses - it has been assumed that the trips associated with the A3 uses are all linked
to the retail uses. This is as previously agreed;

Cross Visitation - this has been increased from 20% to 30% to reflect the increased
retail offer of the combined retail developments when compared to that of a single
development. This adjustment is not evidence based. Reference to TRlCS Research
Report 05/1 “Trip Attraction Rates of Developments with Multiple Retail and Leisure
Uses" suggests that cross visitation can be influenced by a number cf factors. This
document should be reviewed and revised assumptions for cross visitation presented
based on the evidence contained therein. There is also the question of hOW the cross
visitation rates are applied. On the basis that 20% has previously been accepted for a
single development,.then it can only be assumed that any different cross visitation factor
would apply to those trips associated with subsequent development, ie, 30% (if that
figure is ultimately agreed) of trips to the Cranfords development would already be
visiting the RFC/WCRP development.

Paragraph 5.11 of the TA states that primary transferred and pass by trips have been
reduced by 5% each to balance the increase in cross visitation. Cross visitation is linked
to trip generation and transfer and pass by trips relate to the distribution of trips onto the
highway network. These factors'cannot be simply interchanged in the way that Vectos
have done. Without further evidence based analysis, it is not possible to determine if the
revised assumptions in the TA are correct;

Committed Development - this is stated to be as per the TA for the refused application.
On the basis of the application presented, the redevelopment of the Rugby Club site
should also be considered as a committed development. It is therefore apparent that
committed development may have been Underestimated.

Traffic Generation

No information is presented in the TA on how the traffic generation of the development
has been determined. On the basis of the information previously submitted and the
revised assumptions discussed above, it is clear that the additional traffic flow uplift
arising from the Cranford development would be significant. It is estimated that traffic
flows through Loggans Moor roundabout would increase by around 300 vehicles per
hour in the weekday PM peak and 500 vehicles per hour in the Saturday peak period.

Network Performance

As described above, the VISSIM microsimulation modelling work is not in question.
Therefore, provided that there is agreement on the traffic flow forecasts arising from the
Cranford development, then the modelling outputs can be taken as read. There is
however no agreement on this aspect of the TA and no weight can yet be attached to
the modelling outputs. Due to the magnitude of additional retail development now being
proposed, it is considered that there remains the possibility that without further
improvement to the strategic road network, particularly at Loggans Moor roundabout,
the impact of the Cranfords development could be severe. Further technical work is
therefore required in. order to the traffic flow uplifts likely to arise as a result of the
development prior to those traffic uplifts being tested using Highways England's VISSIM.
microsimulation model.

Recommendation

It is therefore recommended that planning permission not be granted for a period of 6-
months to give the applicant sufficient time to progress necessary technical work to
satisfy the concerns of Highways England.

 

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