quay west... · web view7.33the site report undertaken on 22 december 2014 is attached to the email...

CEREDIGION COUNTY COUNCIL

TOWN & COUNTRY PLANNING ACT 1990

APPEAL BY BOURNE LEISURE LIMITED

SITE AT QUAY WEST HOLIDAY PARK, NEW QUAY, SA45 9SE

REBUTTAL STATEMENT OF THE PROOF OF EVIDENCE

prepared by: Ian McGrane PCert, MCIHT

PREPARED BY -

MARGARET G. JAMESSENIOR ENGINEER (PLANNING LIAISON)

TECHNICAL SERVICESCEREDIGION COUNTY COUNCIL

PLANNING INSPECTORATE REF: APP/D6820/A/15/3134757

LOCAL PLANNING AUTHORITY REF: A130830

MARCH 2016

1. INTRODUCTION

The Local Highway Authority (LHA) notes the statements made in the introduction.

2. RELEVANT PLANNING POLICY AND GUIDANCE

2.1 Error – ‘Transport Advisory Note 18’ should read ‘Technical Advice Note 18’

2.2-2.11 The LHA note the statements made.

3. SITE LOCATION AND CONTEXT

For clarification, the roadway referred to in the evidence as ‘Cei Bach Lane’ is the County Class III Road No C1035. The Class III Road extends from the junction of the Class II Road B4342 at Cnwc Y Lili Cross roads to the Trunk Road A487, east of Llanarth. The roadway is open to all traffic and is subject to the National Speed limit of 60mph.


3.8-3.9 Fig 7.1 of Manual for Streets 1 (MfS1) illustrates that a 4.8m wide paved carriageway ‘provides sufficient width for two cars to pass one another with lateral clearance between each vehicle’.

At 4.7m the carriageway will allow a wide car to pass a large service vehicle with an overall tolerance of 0.4m. Hence whilst being restrictive, a width of 4.7m will provide two-way flow for the majority of residential traffic with a tolerance of 1.1m. However, a 4.7m width does not provide refuge within highway limits for pedestrians/cyclists to step clear of two-way traffic flows.

Fig 6.8 illustrates width of footways and pedestrian areas for a range of functions.

Appendix 1 (p79, Fig.7.1 - MfS1)Appendix 2 (p68, Fig.6.8 - MfS1)

Highway Gradient


Forward Stopping Sight Distance (FSSD)

3.15 No plan has been provided to the LHA to indicate the location of the (FSSD) measured.

3.16 The LHA note the statements made.

Access to Public Transport


3.19 The bus shelter is located at Cnwc Y Lili Crossroads; adjacent to the Class II Road No B4342. The pedestrian desire line from the appeal site junction to the bus shelter is along the Class III Road. The Class III Road is de-restricted, is unlit and devoid of footway/verges to allow pedestrian to step clear of passing vehicles.

Fig 3.1 ‘Cei Bach Lane-Carriageway Width Profile from jct with B4342’ illustrate that the section of roadway between the B4342 and the appeal site junction has 6no pinch points, with a width of below 5m.


4. DEVELOPMENT CHARACTERISTICS

4.1 Disagree. Should the appellant decide to operate the pitches as ‘holiday lets’ it may materially alter the traffic profile that is contained in Chapter 5. Unlike ‘owner-occupier’ caravans, ‘holiday lets’ may be likely to generate peak ‘Arrival and Departure Traffic Flows within the busiest hour (11am-12pm) and thereby likely alter the traffic flow profile. As a broad guide the Assembly Government would regard an increase in turning movements in the order of 5% as material in most cases, that is, a 5% increase of traffic using any link of the junction.


5. PLANNING APPLICATION HISTORY (HIGHWAYS RELATED)


Assessment and Quantification of Baseline Conditions


Pedestrians Counts along Cei Bach Lane

5.12 The pedestrian counts are not daily counts; they are restricted between the hours of 10am and 6pm.


Volumetric Vehicle Surveys within Quay West Holiday Park

5.15 Disagree. As a broad guide the Assembly Government would regard an increase in turning movements in the order of 5% as material in most cases, that is, a 5% increase of traffic using any link of the junction.

Appendix 3: Planning Policy Wales (PPW) Technical Advice Note (TAN) 18: Transport. (p.55/56)

5.16 Disagree. A survey to record vehicle volumes at the entrance to the ‘Traeth Gwyn’ area of the existing site does not provide an acceptable method for calculating the potential level of vehicle movements along the Class III Road.

Appendix 4: Photograph of path between caravans No 42 & No 43 at ‘Traeth Gwyn’ that connects to the coastal path. Photograph of path near ‘Traeth Gwyn’ that connects to the B4342.

5.17 No evidence provided of the ’proportion of units which are ‘owner occupied’ or ‘holiday let’ within the ‘Traeth Gwyn’ area of the existing complex.


5.19 Disagree. ‘Using the traffic data associated with the ‘Traeth Gwyn’ area of the existing holiday park does not provide an acceptable

method for calculating the trip generation associated with the proposed development for the following reasons:

Geographically, the ‘Traeth Gwyn’ area is located at the western side of the site near to New Quay. ‘Traeth Gwyn’ has inclusive safe pedestrian links to all leisure facilities with the Quay West complex and to the beach. The local amenities at New Quay are located within a 700m radius of ‘Traeth Gwyn’. Within the ‘Traeth Gwyn’ area there is a path leading between caravans No.42 and No.43 to the coastal path; that leads to New Quay. Therefore, there is reduced demand for car use once the visitors have arrived on-site.

In comparison, the Appeal Site is located at a remote location to the east of the Main Complex and is bisected by the County Class III Road. The local amenities at New Quay are located a distance of some 1.5km away; this would result in increased reliance on travel by private car to access these local amenities.

Consequently, using the traffic data associated with the ‘Traeth Gwyn’ area within the main site to derive vehicular trip generation figures, where walking would be the dominant mode of transport, is not comparable with the proposed site.

Notwithstanding the above, no data has been provided to the LHA to validate the vehicle trips.

Trip Generation from the Proposed Development

5.20- 5.21 Disagree. As detailed in 5.19 above.

No data has been provided to the LHA to validate the survey results.

Cei Bach Lane – Baseline Traffic and Development Traffic Flow

5.22 Disagree. The base line traffic from the ‘Traeth Gwyn’ area does not provide an acceptable method for calculating the trip generation associated with the proposed development.

5.23 Disagree. The vehicular trip generation from the ‘Traeth Gwyn’ area does not provide an acceptable method to calculate that the proposed development will, ‘during the peak season, generate a

daily traffic flow that is significantly lower than corresponding baseline conditions.

Vehicle Speed Survey – Cei Bach Lane

5.24 Agreed.The TS does not include data to validate the survey results.


Cei Bach Lane – Application of Appropriate Design Guidance


5.37 The ‘Stage 1 Road Safety Audit’ does not confirm that ‘the positioning and measurement was correct bearing in mind the horizontal alignment of Cei Bach Lane’.

The Audit reads: ‘you asked for comment on the visibility spays; specifically whether the positioning and measurement of was correct bearing in mind the horizontal alignment of Cei Bach Lane. We advised that it would not be appropriate to include such advice as part of the Audit Report and we agreed to make some general comments to assist you with this matter.’


Cei Bach Lane – Proposed Vehicular and Pedestrian Access Design

5.39-5.40 Disagree. Drawing No DWG/1336/001 Rev A referred to as the ‘preliminary engineering design’ for the vehicular and pedestrian access prepared as part of the Transport Statement does not provide vertical levels. A topographic survey is required, to determine visibility envelopes in both the horizontal and vertical plane.

MfS1 (page 91, para 7.6.4) reads ‘The Stopping Site Distance (SSD) figure relates to the position of the driver and the front of the vehicle is typically up to 2.4m , which is a significant proportion of shorter distances. It is therefore recommended that an allowance is made by adding 2.4m to the SSD’.

Accordingly, there is a requirement to adjust the SSD from 43m to 45 m.

Drawing No 1336/001 Rev A does not contain visibility splays to the south of the proposed junction and to the south of the proposed pedestrian access to the site. Due to the curvature of the Class 111 Road, visibility in the southern direction would cross over the carriageway. When this occurs, an additional visibility splay should be shown plotted from the “x” point, to the nearside carriageway edge on the tangent of the curve in line with MfS1 (page 92, para 7.7.4). The LHA maintain that the additional inter-visibility splay areas to the south of the proposed site junction and proposed pedestrian access would cross over third-party land outside the application site.

The height within the visibility envelope for the site junction shall be measured at an eye height of 1.05m (for car drivers) down to a point 600mm above the carriageway, to ensure small children can be seen MfS1 (page 91, para 7.6.3 and Figure 7.17 - Vertical visibility envelope). The visibility envelope shall extend for distances of 45m, measured along the nearside edge of carriageway in each direction.

The height within the visibility envelope for the pedestrian access site shall be measured from a 2m ‘x’ distance to a ‘y’ distance of 43m. The visibility envelope shall be measured 600mm above the carriageway, to ensure shall children can be seen.

Visibility should be checked at junctions and along the street. Visibility is measured horizontally and vertically, MfS1 (page 91, para 7.6.1)

Appendix 5: MfS1 (p92, para 7.7.4)Appendix 6: MfS1 (p91, para 7.6.3 & Figure 7.17 Vertical visibility envelope and para 7.6.1)

5.41 No evidence presented to the LHA of appropriate ‘design checks’ undertaken.


5.45 Disagree. Drawing No 1336/001 Rev A submitted as part of the Transport Statement clearly shows the alignment of the Class III

Road to be curved. The site junction and pedestrian access join the Class III Road on the outside of a bend.

MfS1 ( page 92, para 7.7.4) states ‘when the main alignment is curved and the minor arm joins on the outside of a bend, another check is necessary to make sure that an approaching vehicle on the main arm is visible over the whole of the Y distance. This is done by drawing an additional sight line which meets the kerb line at a tangent.’ The LHA maintain that this further design check was necessary.

A site survey carried out by the LHA identified that visibility in the southerly direction at the proposed site junction and proposed pedestrian access are restricted by third party land, not identified within the applicant’s ownership/control.

Measured Vehicle Speed and Achievable Visibility: Junction of B4342 / Cei Bach Lane


5.50 Disagree. A visibility splay of 90m should be provided as per Planning Policy Wales (PPW) Technical Advice Note (TAN) 18 Table A.

Appendix 7: Planning Policy Wales (PPW) Technical Advice Note (TAN) 18: Transport (p44, Table A)

5.51 The survey has not captured vehicle speeds on the New Quay, west bound approach to Cnwc Y Lili Cross Roads.

5.52 Agreed. The equipment was installed 43m east of the Cnwc Y Lili Cross road at Site 3. No vehicles speeds were recorded on the westerly approach to the junction, travelling from New Quay.

5.53 The LHA agree that the 90m Stopping Sight Distance (SSD) from the New Quay approach is in line with the current speed restriction of 30mph.

Disagree. The LHA disagree with the statement that ‘the current geometric alignment’ of the junction meets design standards. The geometry of the junction is substandard in terms of junction radii, carriageway width and footway provision.

Transport Statement – Post Planning Submission

5.54 Email dated 31 January 2014 from the LHA to the Local Planning Authority (LPA) recommend that permission shall be refused for the following reasons:

The proposed development would involve the construction of a new pedestrian crossing and a new vehicular access to the County Road at a location where visibility is restricted which will lead to danger for emerging vehicles, cyclists and pedestrians; contrary to National Guidance contained in Planning Policy Wales TAN 18.

The development does not secure safe access to site in addition to a safe and secure layout for all people from a road safety perspective.

Appendix 8: Email dated 24 December 2014 from the LHA to the LPA

B4342 / Cei Bach Lane Junction – Achievable Visibility Splay


5.58 Noted. The landowner adjacent to the Class II Road B4342 east of Cnwc Y Lili cross roads has removed the roadside hedge bank and erected a fence. Visibility at the junction accords with Table A of TAN18.

Modification of the Proposed Pedestrian Crossing Point – Cei Bach Lane


Transport Statement – Post Planning Submission Acceptance


5.64 The LHA initially advised the LPA that any permission granted shall be subject to conditions. Condition 1 is a Grampian condition; as the construction of the pedestrian crossing within highway limits will require the consent of the LHA. The Grampian condition prohibits occupation of the holiday accommodation until the provision of supporting highway infrastructure.

Condition 7 reads: ‘The development shall include any necessary adjustment of any public utilities apparatus, highway drains, street lights, traffic signs or road markings arising from the works, that may include the full cost of introducing any traffic order at the developers expense’.

The principle of a pedestrian crossing across the Class 111 Road cannot be supported without traffic calming; any form of physical traffic calming can only be implemented within a 20, 30 or 40 mph speed limit. The application site is not within a speed limit and the implementation of a road traffic order is subject to a lengthy public consultation that may/may not be supported.

Appendix 9: Recommendation from the LHA to the LPA dated 31st January 2014.

5.65 Drawings DWG/1336/001 Revision A and B are both dated October 2013.

5.66 Agreed


5.68 Disagree. The principle of a pedestrian crossing across the Class III Road cannot be supported without traffic calming; any form of physical traffic calming can only be implemented within a 20, 30 or 40 mph speed limit. Whilst the land required for the supporting highway infrastructure lies within the control of the highway authority the implementation of a road traffic order is subject to a lengthy public consultation.

5.69 Agreed

6. ENHANCEMENT OF PEDESTRIAN ACCESS ALONG CEI BACH LANE

6.1 Agreed

6.2 No agreement was sought /given by the LHA to the Permissive Right of Way.

The proposed ‘Permissive Right of Way’ linking onto the Class III Road would induce additional pedestrian activity opposite the site junction, at crossroads configuration would not be supported by the

LHA without traffic calming. Physical traffic calming can only be implemented within a 20, 30 or 40 mph speed limit. The proposed pedestrian access is not within a speed limit and the implementation of a road traffic order is subject to a lengthy public consultation.

6.3 The statement acknowledges that the Class III Road offers ‘an unsafe environment’.

6.4 The LHA support the proposal for the ‘Permissive Right of Way, which would align directly through the holiday park and onto the beach’.

6.5 Noted. The LHA is not the highway authority for public rights of ways.


7. BACKGROUND TO THE PLANNING APPEAL

Introduction

7.1 Dispute. The LHA initially advised the LPA that any permission granted shall be subject to conditions. Condition 1 is a Grampian condition; as the construction of the pedestrian crossing within highway limits will require the consent of the LHA. The Grampian condition prohibits occupation of the holiday accommodation until the provision of supporting highway infrastructure.


The principle of a pedestrian crossing across the Class III Road cannot be supported by the LHA without traffic calming; any form of physical traffic calming can only be implemented within a 20, 30 or 40 mph speed limit. The application site is not within a speed limit and the implementation of a road traffic order is subject to a lengthy public consultation that may/may not be supported.

At the Development Control Meeting held on 10 December 2014, Members requested the LHA carry out a site survey to ascertain

the actual visibility distances as they recalled a fatality at the cross roads.

Based on a review of updated plans received by email from David Middleton, Savilles dated 18 December 2014 the LHA withdrew the recommendation to approve subject to conditions and superseded with a recommendation to refuse.

Determination of Original Planning Application – 10th

December 2014


7.3 The email dated 24 December 2014 from the LHA to the LPA addressed road safety issues raised by Members at the Development Control Meeting held on 10 December 2014. It offers a review of the updated plans submitted on the 18 December 2014.

Drawing 1336/002 (Cross Roads Visibility Measurements)Drawing 1336/001 Rev B (Site Access Arrangements)


7.5 To clarify:

The record of Personal Injury Accidents over a five year period is agreed.

The visibility survey carried out on 22 December 2014 highlighted restricted visibility in the southerly direction at the proposed junction and pedestrian access to the appeal site.

The updated Drawing 1336/001 Rev B (Site Access Arrangements) submitted on the 18 December 2014 propose a painted crossing across the Class III road and pedestrian chicane barriers.


Person Injury Accident Data

7.8 The ‘Advanced’ search was duly undertaken by the LHA to address concerns raised by Members at Development Control Committee Meeting, held on 10 December 2014 of a fatality at Cnwc Y Lili cross roads.

7.9 -7.17 The LHA note the statements made.

7.18 Agreed

7.19 Disagree. The accident data contained within the applicant’s Transport Statement undertaken over a 5 year period refer to an accident in 2011, classified as ‘slight’ in severity that occurred within the previous five years prior to the submission of the planning application.

7.20-7.21 The advanced search was duly undertaken by the LHA to address concerns raised by Members at Development Control Committee Meeting, held on 10 December 2014 of a fatality at Cnwc Y Lili cross roads.

7.22-7.23 Disagree. No speed equipment was installed on the New Quay approach to the Cnwc Y Lili Cross Roads to capture vehicles speeds approaching the junction from New Quay.

The survey does not capture traffic speeds to calculate the 85th percentile Stopping Site Distance (SSD) for vehicles approaching the crossroads from New Quay.

7.24-7.25 The advanced search was carried out by the LHA to address concerns raised by Members at Development Control Committee Meeting, held on 10 December 2014 of a fatality at Cnwc Y Lili cross roads.

Visibility Survey


7.28-7.29 Disagree. Email from David Middleton to Rosemary Rhys dated 18 December 2014 reads:

‘Each update plan is also enclosed and is as follows,

Drawing 1336/002 (Cross Roads Visibility Measurements) is an update of figure 3-4 in the TS (rear of page 13) to show the full 87m splay ‘potential’ referred to.

Drawing 1336/001 Rev B (Site Access Arrangements) is an update of the Rev A drawing produced at Appendix B of the TS to show the painted crossing point and pedestrian chicane barrier.

Appendix 10: Email from David Middleton to Rosemary Rhys dated 18 December 2014


7.33 The Site Report undertaken on 22 December 2014 is attached to the email dated 24 December 2014 from the LHA to the LPA. The Site Report reads: ‘It is considered that, subject to maintenance works being carried out to cut back nearby vegetation, this junction accords with current visibility requirements.

7.34 Disagree. The extract from the DWG/1336/001 Rev B included in the ITP Technical Note dated 6 January 2015 does not resolve concerns relating to restricted visibility in the southerly direction at the proposed junction and pedestrian access to the appeal site raised by the LHA in the email dated 24 December 2014.

Appendix 11: ITP Technical Note, p4 submitted to the LHA on 8 January 2015.


7.36 DWG/1336/001 REV B dated February 2016 provides the LHA with the level of detail required to assess the site access arrangements in both the horizontal and vertical plane.

The topographical survey shows the alignment of the Class III Road to be curved. The pedestrian access joins the Class III Road on the outside of a bend. MfS1 ( page 92, para 7.7.4) states ‘when the main alignment is curved and the minor arm joins on the outside of a bend, another check is necessary to make sure that an approaching vehicle on the main arm is visible over the whole of the Y distance. This is done by drawing an additional sight line which meets the kerb line at a tangent.’

The LHA maintain that an additional sight line which meets the kerb line at a tangent would cross over third party land; thereby the plan does not resolve concerns relating to restricted visibility in the southerly direction at the proposed pedestrian access to the appeal site raised by the LHA.

The principle of a pedestrian crossing across the Class III Road cannot be supported by the LHA without a traffic management

scheme; any form of physical traffic calming can only be implemented within a 20, 30 or 40 mph speed limit.

The site access arrangement is not accompanied with a traffic management scheme.

7.37-7.38 The LHA maintain that an additional sight line which meets the kerb line at a tangent would cross over third party land; thereby the plan does not resolve concerns relating to restricted visibility in the southerly direction at the proposed pedestrian access to the appeal site.

7.39 The LHA advised the LPA on the 31 January 2014 that any permission granted shall be subject to conditions. Condition 1 is a Grampian condition; as the construction of the pedestrian crossing within highway limits will require the consent of the LHA. The Grampian condition prohibits occupation of the holiday accommodation until the provision of supporting highway infrastructure.



At the Development Control Meeting held on 10 December 2014, Members requested the LHA carry out as a site survey to ascertain the actual visibility distances as they recalled a fatality at the cross roads.

Based on review of updated plans received by email from David Middleton, Savilles dated 18 December 2014 and restricted visibility at proposed site junction and pedestrian access the LHA withdrew the recommendation to approve subject to conditions and superseded with a recommendation to refuse.

The LHA consider that the use of a Grampian condition may fail the tests of reasonableness and enforceability. The drawings do not demonstrate reasonable prospect that a safe pedestrian link, with supporting highway infrastructure can be provided within the time-limit imposed by any permission that the LPA may allow.

Appendix 9: Recommendation from the LHA to the LPA dated 31st January 2014.

Deferred Planning Application – 14th January 2014

7.40-7.42 The LHA note the statement made.

Deferral Period: Submission of Revised Design Drawings


ITP Email Submission - 28 January 2015


7.46 DWG/120/120/1294/003 dated January 2015 was attached to an email dated 28 January 2015 from David Hampton to the LHA.

ITP Email Submission 6 February 2015

7.47 DWG775/37/10 REV H was attached to an email dated 6 February 2015 from David Hampton to the LHA.


7.49 Agreed


Email from Local Highway Authority 20 February 2015

7.51-7.52 Agreed

7.53-7.54 The email from the LHA to the LPA dated 20 February 2015 provides a review of DWG775/37/10 REV H.

ITP Email Submission 9 March 2015

7.55 The LHA do not hold a log of the telephone calls.


7.58 Agreed. The ‘final submission’ attached to an email dated 9 March 2015 from David Hampton contained three engineering drawings, namely:

DWG/1336/004 DWG/1336/005 DWG/1336/006


Email from Local Highways Authority, 12 March 2015


7.61 Topographical Survey: A topographic survey is required to determine visibility envelopes in both the horizontal and vertical plane at each point of access. It is also required to determine forward visibility along the public highway. NB Forward visibility is equal to the SSD.

Visibility splays: The LHA accept that in line with MfS1; as the measured vehicle speed to calculate the 85 percentile to be 30 mph, there is a requirement to provide SSD’s of 45m ‘to include an adjustment of 2.5m for bonnet length’. The drawings do not demonstrate that visibility splays are attainable in both the horizontal and vertical plane at each pedestrian access, proposed junction and along the Class 111 Road.

7.62 Disagree. Based on the review of the revised and submitted drawings the LHA consider that the use of a Grampian condition may fail the tests of reasonableness and enforceability. The drawings do not demonstrate reasonable prospect that a safe pedestrian link, with supporting highway infrastructure can be provided within the time-limit imposed by the permission.

Cei Bach Lane – Provision of Proposed Pedestrian Crossing

Tom Delph-Janiurek, Senior Engineer Traffic Management, to respond on behalf of the LHA.

Background to the Appeal – Concluding Remark

7.80 For clarity, the LHA did not initially offer ‘no objection’; the LHA initially advised the LPA that any permission granted shall be subject to conditions. Condition 1 is a Grampian condition; as the construction of the pedestrian crossing within highway limits will require the consent of the LHA. The Grampian condition prohibits occupation of the holiday accommodation until the provision of supporting highway infrastructure.


The principle of a pedestrian crossing across the Class 111 Road cannot be supported by the LHA without traffic calming; any form of physical traffic calming can only be implemented within a 20, 30 or 40 mph speed limit. The application site is not within a speed limit and the implementation of a road traffic order is subject to a lengthy public consultation that may/may not be supported.




7.81 Agreed

7.82 Disagree. The Written Statement of Proof of Evidence prepared by Margaret G James provides a summary of plans received and responses given by the LHA, following the resolution of the Development Control Committee on 14 January 2014 to defer the application for a period of a month to afford the developer an opportunity to allow the developer the opportunity to submit an amended scheme for the written approval of the Local Planning Authority.

7.83 The technical input provided by the LHA’s in house consultancy was used to formulate the LHA response to the LPA.

Appendix 12: Email from the LHA’s in-house consultant dated 16 February 2015.

7.84 The LHA note the statement made.

7.85 The application seeks full planning permission for the means of access to the site. The drawings do not demonstrate reasonable prospect that a safe pedestrian link, with supporting highway infrastructure can be provided within the time-limit imposed by any permission that the LPA may allow.

8. THIRD PARTY OBJECTIONS


Configuration of Cei Bach Lane

8.3 The Transport Statement does not provide data of vehicle volume along the Class III Road.

The absence of reported personal injury accidents does not support the statement: ‘and ‘therefore it can be concluded that based on the scale and nature of the proposed development, existing levels of highway safety would be maintained’.

Fatal Accident at B4342 / Cei Bach Lane

8.4 Agreed.

8.5 The fatal accident was raised by a Member at the Development Control Meeting held on 10 December 2014. The LHA prepared a

report of the fatality to the LPA at the request of Members at Committee.

Disruption due to Deliveries of Caravans

8.6 Re: Drawings DW6/1336/004

Figs.1 and 2 illustrate that in order for a delivery vehicle to enter and exit the site junction the vehicle will take up the entire width of the Class III Road. Figs.3 and 4 illustrate that delivery vehicles will over run both traffic lanes and utilize the entire highway width of the B4342 in order to manoeuvre onto the Class III Road.


Increase in Noise Level

8.8 Disagree. The desire line for pedestrians from the appeal site to the bus stop and the Cambrian Hotel is along the Class II Road.

9. CONCLUSION


9.2 Disagree. The Appeal site is located at a remote location to the east of the Quay West Complex and is bisected by the County Class III Road. The local amenities at New Quay are located a distance of some 1.5km away; this would result in increased reliance on travel by private car to access these local amenities.

9.3 Noted however the Transport Statement does not contain evidence of vehicle volume captured, furthermore it does not provide the date of the vehicle speed capture.

9.4 The Transport Scoping Note dated 23 August 2013 summarises the 85 percentile speeds along the Class III Road to be 29.7 mph north bound and 28.3mph southbound. No data is presented to the LHA to validate that the Class III Road exhibits low traffic volume.

9.5 A topographic survey is required to determine visibility envelopes in

both the horizontal and vertical plane at each point of access. It is also required to determine forward visibility along the public

highway.The drawings submitted during the planning process do not show levels to enable the LHA to check visibility.

9.6 The LHA initially advised the LPA that any permission granted shall be subject to conditions. Condition 1 is a Grampian condition; as the construction of the pedestrian crossing within highway limits will require the consent of the LHA. The Grampian condition prohibits occupation of the holiday accommodation until the provision of supporting highway infrastructure.






9.7 Agreed. The landowner to the east of at Cnwc Y Lili cross roads has since removed a section of the roadside hedge bank adjacent to the Class II Road. Visibility at the junction of the Class III Road with the Class II Road B4342 accords with PPW TAN 18 Table A.

9.8 The LHA withdrew the recommendation to approve the development subject to conditions and issued a recommendation to refuse based on review of updated plans received by email from David Middleton, Savilles dated 18 December 2014 and a site survey undertaken on 22 December 2014 that recorded restricted visibility in the southerly direction at the proposed junction and pedestrian access to the appeal site.

9.9 Agreed

9.10 Disagree. The Written Statement of Proof of Evidence prepared by Margaret G James includes a summary of plans received and responses given by the LHA, following the resolution of the Development Control Committee on 14 January 2014 to defer the application for a period of a month to afford the developer an opportunity to allow the developer the opportunity to submit an amended scheme for the written approval of the Local Planning Authority.

Appendix 13: Margaret James’s Proof of Evidence Statement.

9.11 The ‘Advanced’ search was duly undertaken by the LHA to address concerns raised by Members at Development Control Committee Meeting, held on 10 December 2014 of a fatality at Cnwc Y Lili cross roads.

The LHA accept the accident data contained within the applicant’s Transport Statement undertaken over a 5 year period that record to a single an accident in 2011, classified as ‘slight’ in severity that occurred within the previous five years prior to the submission of the planning application.

9.12 Disagree. The Site Report undertaken on 22 December 2014 is attached to the email dated 24 December 2014 from the LHA to the LPA. The Site Report reads: ‘It is considered that, subject to maintenance works being carried out to cut back nearby vegetation, this junction accords with current visibility requirements.

The landowner to the east of at Cnwc Y Lili cross roads has since removed a section of the roadside hedge bank adjacent to the Class II Road. Visibility at the junction of the Class III Road with the Class II Road B4342 is fully compliant with PPW TAN 18 Table A.

9.13 Agreed

9.14 The roadway referred to in the evidence as ‘Cei Bach Lane’ is the County Class III Road No C1035. The Class III Road extends from the junction of the Class II Road B4342 at Cnwc Y Lili Cross roads to the Trunk Road A487, east of Llanarth. The roadway is open to all traffic and is subject to the National Speed limit of 60mph.

9.15 Tom Delph-Janiurek, Senior Engineer Traffic Management, to respond on behalf of the LHA.

9.16 Noted. The content of the internal email provided by the LHA’s in-house consultancy was included in the review formulated by the LHA to the LPA.

Appendix 12: Email from the LHA’s in-house consultant dated 16 February 2015.


9.18 Disagree. Based on review of plans received during the planning process and restricted visibility at proposed site junction and pedestrian access the LHA withdrew recommendation to approve subject to conditions and superseded with a recommendation to refuse.


9.19 Disagree. The Written Statement of Proof of Evidence prepared by Margaret G James includes a summary of plans received and responses given by the LHA, following the resolution of the Development Control Committee on 14 January 2014 to defer the application for a period of a month to afford the developer an opportunity to allow the developer the opportunity to submit an amended scheme for the written approval of the Local Planning Authority.

Appendix 13: Margaret James’s Proof of Evidence Statement.

Given that the section of road is derestricted and given its characteristics of restricted width and poor horizontal/vertical alignment, the access proposals and supporting highway infrastructure do not demonstrate that the design criteria can be met contrary to National and Local Policies.

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