Cuadrilla Elswick Ltd

Transcription

1 Cuadrilla Elswick Ltd Tewmporary Shale Gas Exploration Description Roseacre Wood, Lancashire Planning Inspectorate Reference APP/Q2371/W/15/ Local Authority Reference: LCC/2014/0101 CE 1/3 Summary Proof of Evidence David Bird March2018

2 Contents 1 SUMMARY AND CONCLUSIONS... 2 Introduction... 2 Existing Conditions... 2 Proposals... 3 HGV Route Assessment... 5 Differences from the Previous Inquiry... 7 Consultation Responses... 7 Overall Conclusions... 8 i

3 This is the summary proof of evidence of David Robert Bird. Any figures and appendices referred to are those that are contained in my main proof of evidence. Roseacre Wood 1

4 1 SUMMARY AND CONCLUSIONS Introduction 1.1 In this proof of evidence, I have examined the likely transport effects of traffic associated with the proposed temporary shale gas exploration at Roseacre. 1.2 My evidence is presented without any reference to the merits of the land use proposed. I have dealt only with the transport impacts and it is not relevant to my considerations whether the land use is building a new school, a housing development or the proposed exploration. However, I have taken into account the contentious nature of the application to the degree that it has an impact on the highway safety effects through potential protestor activity. 1.3 I have sought to engage with local stakeholders in developing and assessing the proposals. I am not aware of any factual, independently collected data (i.e. topographical surveys or movement surveys) having been put forward other than that referred to in this proof. I consulted with LCC and the Rule 6 parties before undertaking the surveys and have shared the results with them. Existing Conditions 1.4 The starting point in any proper assessment of the proposed HGV routes is how those routes perform at present. 1.5 The proposed routes are already used by HGVs of various sizes. The survey data I commissioned demonstrates that it is an entirely common everyday occurrence for an HGV travelling on the proposed HGV routes to meet and pass other vehicles including HGVs, agricultural vehicles and vulnerable road users without incident. It is also noteworthy that HGV speeds are generally significantly below the speed limit. 1.6 I have also identified that a number of residential schemes have been consented in the area that require HGVs to use parts of the proposed HGV routes for construction purposes. At reasonable build out rates these developments will generate a level of HGV traffic greater than the typical Roseacre day. 1.7 Taking the recorded HGV flows, I estimate there have been approximately 4 million HGV km travelled on the roads that form the three proposed HGV routes in the last 5 years. During Roseacre Wood 2

5 an equivalent 5 year period, for which accident data is available, there has not been a single accident involving an HGV. 1.8 With regard to vulnerable users, only four accidents occurred on the proposed HGV routes during the five-year study period. All of these accidents resulted in only slight injuries. 1.9 From my experience elsewhere, this is an excellent accident record and demonstrates that the routes currently operate in a safe manner. Proposals 1.10 The proposed temporary shale gas exploration will generate additional HGV movements on the local road network. I have undertaken a comprehensive assessment of the likely generation of HGVs, based on the recent experience at PNR It is important to distinguish between the worst-case HGV figures that I have used in my assessments and a typical day through the life of the project For assessment purposes I have assumed 50 two-way HGV movements per day on each of the proposed routes. This assumes that on any one day only one route would be used. I have also assumed that all HGVs are a maximum size 16.5m long articulated vehicle In reality, based on the Roseacre Revised Forecast, it anticipated that on only 93 days during the 6 year project there would be between 40 and 50 two-way HGVs generated by the Site. For the great majority of the time (88% of the project duration) the generation will be 24 two-way HGV movements per day or less. Furthermore, these are likely to be spread over more than one of the routes and therefore on any one route there is likely to be circa 12 two-way HGV movements (i.e. 6 HGVs each way) The size of vehicle will also vary with some 80% of the HGVs during the construction and restoration phases being 3-4 axle rigid HGVs with a length of 9-10m rather than the 16.5m articulated vehicles used in the analysis Two forms of mitigation have been developed to address the increase in HGVs. The first is the control of HGVs through the Updated Draft Traffic Management Plan (CD 11.1) and the second is physical mitigation that has been developed to address issues that arose from the HGV route assessment. Roseacre Wood 3

6 1.16 The Updated Draft Traffic Management Plan is a comprehensive document that seeks to control HGVs generated by the Site and minimise their impact. The key features of the plan are: HGV cap of 50 two-way HGVs per day. HGV delivery hours HGVs will be permitted to access and egress the Site on weekdays between 07:30 16:30 and in the darker months of November - January (inclusive) the HGV hours will be limited to weekdays 08:00 16:00. There will be no HGV deliveries on weekends except in operational emergencies and with the prior approval of the police. In addition, HGVs will only be permitted to use the Red Route between the hours of 09:00-15:00 (during term time) in order to avoid the St Peter s school sensitive hours. DHFCS Inskip route - The Secretary of State for Defence has agreed that Cuadrilla may route HGVs through the DHFCS Inskip site in order to bypass the village of Wharles. This would cover all phases of the project other than the very low traffic during the extended flow test (EFT) phase when minimal HGV movements are forecast. Co-ordination of Roseacre HGVs - the site management team will be fully aware of the timing and routes of all HGVs accessing/departing the Site. As such, the timing and routing of HGV movements can be managed so that no two Cuadrilla HGVs will meet each other on any one of the three HGV routes, except for the section of Green and Red routes that overlap on the B5269 which is a Distributor Road. Driver Induction During induction, drivers will be instructed on protocols and routes to follow and to drive with caution. A disciplinary process will be put in place. Automatic Number Plate Recognition Scheme The ANPR scheme will include monitoring cameras at the Site access and on each of the three HGV routes to monitor compliance with the HGV Routes, HGV Hours and co-ordination of arrivals and departures. It will also allow HGV speeds to be monitored. Roseacre Wood 4

7 HGV Route Assessment 1.17 Following an extensive and objective exercise I concluded that there were three routes that were most suitable to be used by HGVs to transport goods and materials between the A road network and the Roseacre site I considered very carefully the appropriate methodology to use to assess the routes taking into account current guidance. The methodology I have applied is a detailed analysis of the key issues. The methodology considers: Baseline (existing) conditions; Environmental impacts; Embedded mitigation; The ability for two HGVs to pass each other; Junction visibility; Vulnerable road users; Required physical mitigation; Stage 1 Road safety Audit; and Cumulative effects with other consented developments in the area The results of the HGV Route Assessment can be summarised as follows: Environmental Impacts: Based on the worst-case assessment of 50 HGVs movements on one route in a day, the ES Traffic Addendum (CD 6.2) concluded that, with mitigation in place, none of the transport environmental impacts would be significant, which is consistent with the 2014 ES (CD 3.2). The Ability of HGVs to Pass: I have undertaken a detailed route assessment and identified where there may be difficulty in two HGVs passing. Notwithstanding the fact that such passing manoeuvres currently take place without incident and without causing any accidents, I have developed a mitigation strategy to address these issues. This is the introduction of passing places on the proposed HGV routes and part time traffic signals on Dagger Road. These proposals have been subject to an independent Stage 1 Road Safety Audit (CD 11.3) and a Designers Response (CD 11.4) was subsequently prepared. No residual safety issues remain as a result of the safety audit. Visibility at Junctions: I have assessed the available visibility at the junctions along the proposed HGV routes and compared these with design standards, taking into account relevant recorded speeds. It is important to note that the visibility standards are for the Roseacre Wood 5

8 design of new junctions rather than the assessment of existing situations. Furthermore, research undertaken for Manual for Streets 2 (CD 8.2) shows that there is no evidence that reduced visibility leads to an increased accident risk. This conclusion is supported by the low number of accidents recorded on the proposed routes. Based on the available visibility, the evidence on speeds and the accident records at the junctions I do not consider that the additional HGVs using the junctions as a result of the Roseacre exploration will lead to a significant increase in accident risk Vulnerable Road Users: As with other aspects of the analysis it is noteworthy that whilst the proposed HGV routes are currently used by some vulnerable road users, there have been only 4 injury accidents involving such users in the 5 years analysed, none of which involved an HGV. Drivers will adjust their driving behaviour and in particular their speed to the prevailing road conditions and Cuadrilla drivers will be subject to specific training. Therefore, there is no evidence that the risk to vulnerable road users will increase significantly. Cumulative Effects: I have assessed the cumulative impacts of the consented housing developments in the area. I have concluded that the ES Traffic Addendum (CD 6.2) provides a worst case assessment of the transport environmental impacts. In terms of the cumulative highway safety effects, no physical improvement works were required for the consented schemes to mitigate the effect of the construction traffic and LCC therefore must have concluded that this traffic can route on the local highway network safely. The construction traffic generated by the consented schemes is greater than the typical Roseacre traffic. As part of Roseacre, a series of mitigation measures are proposed including passing places, which will facilitate the safe routing of HGVs to and from the consented development sites as well as to and from Roseacre Therefore, I conclude from the detailed HGV route analysis that, with the proposed mitigation (both the Traffic Management Plan and the physical proposals) in place, the HGV routes will continue to operate satisfactorily and there will not be a significant increase in the accident risk as a result of the Roseacre exploration. Roseacre Wood 6

9 Differences from the Previous Inquiry 1.21 In Section 7 of my evidence I have considered the key differences between the evidence before this inquiry and the previous inquiry and therefore why it is reasonable for the Inspector and the SoS to draw different conclusions I identified key differences as follows: Improved baseline data providing a comprehensive record of the current performance of the proposed HGV routes; Use of three routes rather than one, providing flexibility of use and a reduced use of any one route; Reduced hours when HGVs will use the local roads. There will be no use during Saturdays (except in operational emergencies) and hours during the week will be curtailed to avoid hours of darkness. There will be a further restriction on the Red Route to avoid school sensitive hours; The traffic generation has been comprehensively considered in the light of the experience at PNR and therefore provides an up to date estimate; A detailed route assessment has been undertaken based on current guidance and best practice; Mitigation is proposed to address the areas where two HGVs cannot easily pass. This mitigation has been subject to an independent Stage 1 Road Safety Audit and no residual safety issues remain I therefore conclude that the evidence before this inquiry is materially different from at the previous inquiry and many of the issues that were not agreed have been addressed in a comprehensive manner. I consider this new evidence is sufficient to draw a different conclusion to that reached by the previous Inspector. Consultation Responses 1.24 I have considered the consultation responses in detail in Section 8 of this proof. In particular I have sought to address each issue raised by Mr Stevens of LCC In particular I have addressed the potential for protestor activity. I refer to the letter from the Chief Constable of Lancashire Constabulary dated 24 January 2018 (CD 6.12). The chief Roseacre Wood 7

10 constable advises that if planning permission is granted then the police will endeavour to put in place an appropriate policing operation. The letter goes on to state that: However, as a matter of law, the prospect of significant unlawful protest activity is not a factor that ought to be taken into account in determining the planning application I would also note that by having three routes available for HGVs this provides flexibility if one route was affected by protestor activity. Overall Conclusions 1.27 Based on the evidence set out above, I conclude that the traffic generated by the proposed exploration at Roseacre can be accommodated on the local highway network satisfactorily. Whilst there will be some impacts, there is no evidence to suggest that there will be a significant increase in the risk of injury accidents occurring The correct test of the proposals is against the NPPF and in particular the third bullet point of paragraph 32 which states that decisions should take account of whether: improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe I conclude that improvements have been proposed within the transport network that cost effectively limit the significant impacts of the development and that the residual cumulative impact of the proposals will not be severe. On that basis the proposals should not be refused planning permission on transport grounds. Roseacre Wood 8

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