INTRODUCTION

My name is Alan James. I have a Bsc (Hons) in geography, and MA in Landscape Architecture. I am a consultant in the field of environmental transport, and also a fully qualified landscape architect and Member of the Landscape Institute (MLI). I have worked for four years in what is now generally termed green transport planning, and am an Associate of the consultancy Eco-Logica.

I was a team member of the pioneering Derriford Hospital (Plymouth) transport study in 1996, with particular responsibility for analysis of data on modal split and modal shift forecasting. I have since worked on a number of Green Transport Plans and gained considerable experience in what can be achieved by way of changing travel behaviour. I am working with Surrey County Council on the preparation of the Local Transport Plan package for Guildford, and on the County Council's own Company Transport Plan. I am at present taking part in the Public Examination of the South West RPG, considering transport issues in relation to the spatial strategy for development. I worked in 1999 on providing guidelines to DETR on proposed parking standards at hospitals and educational establishments, as incorporated in the revised PPG 13. I am a member of the DETR/ ETSU advisory panel providing assistance to organisations in the implementation of Green Transport initiatives.

This Proof of evidence relates mainly to the "Transportation Impact Assessment" by Tucker Parry Knowles partnership (TPK) dated 11 May 1999 and submitted with Planning Application no 54859/ 99 on 14 May. Although called a 'Transportation Impact Assessment', this is largely an old-style Traffic Impact Assessment, with an overwhelming emphasis on 'predict and provide' methodology, forecasting future traffic flows, predicting the impacts of traffic forecasts on junction and link capacities, and proposing highway measures to solve flow problems in above-capacity situations. There is some work on transfer of trips from car to bus, but this is used solely to feed into the traffic forecasts and the impact on traffic flows. I have seen:-

no transport assessment of walking or cycling

no assessment of potential rail use for travel to and from the site beyond a discussion of the location of the site relative to railway stations

no bus access strategy, merely proposals for one single bus route

no forecast modal split for travel to the site

no statement of total vehicle trips generated by the site (only peak hour information)

nothing about levels of parking provision, which is in my view indivisible from a discussion about traffic generation and means of access

no assessment of environmental impact of generated traffic on surrounding areas

My evidence to the Lee Hall Public Inquiry is presented under the following headings:-

Sustainable development and transport

National and Local Policy Context

Information deficits in the TIA

Detailed issues

SUSTAINABLE DEVELOPMENT AND TRANSPORT

Sustainable development is among other things about minimising resource use - land, energy, other natural resources - and safeguarding the opportunities for sustainable resource use in the future. In terms of land use, there is now an established preference on grounds of sustainability to recycle 'brownfield' land which otherwise has little or no potential positive use, rather than develop greenfield land and thereby remove its potential for productive agricultural use. Only if it can be demonstrated that no brownfield sites meet development needs in a given area should consideration be given to greenfield development. Lee Hall is a greenfield site in an area with considerable amounts of brownfield land, so appears to fail the most basic test of sustainable development. There appears to have been no sustainability appraisal for the site in the current planning application; if this is so, the claim that "The development at Lee Hall is to be promoted as an example of sustainable development" (TIA 2.1) is hollow and totally lacking in credibility.

Sustainable transport strategies are based on the same principles of minimising resource use, by:-

minimising the need to travel, by land use planning and lifestyle strategies,

minimising the distances that need to be travelled, and

promoting the more sustainable forms of transport and demoting the less sustainable.

It is not enough to claim (TIA 2.2.4) that the Lee Hall development satisfies the criteria of sustainable transport by being next to bus routes and not too far from a railway station. Quite apart from the inadequacy of the Lee Hall TIA transport strategy in promoting public transport, it does not begin to address the first two criteria above. The TIA condemns itself in sustainable transport terms by concluding that the transport strategy will deliver no more than a 4.7% shift (TIA 10.3.2) from car use to a more sustainable mode.

Furthermore, the shift is only to public transport, which is better than car use but by no means the most sustainable form of transport. There is a hierarchy of transport modes, as follows:-

walking

cycling

public transport

car share

two wheeled motor vehicles

single occupancy cars

The hierarchy is sequential. For a development to have a sustainable transport strategy it should first look at walking and ensure that in all respects, starting with location, the opportunity to walk has been maximised. It should then do the same for cycling, then for public transport, and so on down the hierarchy, with the aim of reducing to an absolute minimum the need or opportunity for people to travel alone by car. Walking and cycling will only be promoted if distances are practicable and the quality of experience is high in terms of comfort, convenience, and safety. It is necessary to determine what in any given situation will actively promote walking, cycling etc down the hierarchy in sequence, and to establish performance benchmarks against which success can be measured.

Far from the Lee Hall transport strategy looking first at walking and cycling, I have found not one mention of walking and cycling in the TIA.

There is no national guidance on what modal split for journeys to work is considered acceptable in sustainable transport terms, although the setting of traffic reduction targets in Local Transport Plans implies modal shift requirements over the plan period, and there are some general targets in PPG 13 for example to double and double again cycling use by 2002/ 2012. It is however reasonable to propose that a new development should perform significantly better than the current regional average in the modal share of walking, cycling, and public transport, since the current average includes all pre-existing places of work, whose location was determined without reference to sustainable transport issues and often specifically with ease of car access in mind. The modal share of walking in 1997 in Greater Manchester was 13.2% (Focus on Personal Travel, DETR 1998 Table 7.1). This figure is almost certainly unattainable at Lee Hall because of its location; I would challenge the developer to cite a single comparable site where walking to work exceeds 5% modal share.

Table 7.1 of the DETR Focus on Personal Travel also gives a modal share of 11.5% for buses in Greater Manchester: in other words, buses are less important than walking for journeys to work. This highlights the danger of not following the sustainable transport hierarchy, promoting not only a less sustainable but also a less important mode of transport and totally disregarding the most sustainable and inclusive mode of transport.

The Lee Hall TIA claims that the development's "location, adjacent to the A58, the main route between Wigan and Bolton, and just to the north of the railway line, will encourage greater use of bus and train" (TIA 2.5.4). This is unsubstantiated. Pfizer's site outside Sandwich is 500 metres from a railway line and accessible via Sandwich station, and only 2 out of almost 2500 questionnaire respondents travelled to the site by train, prior to the implementation of a Transport Plan; similarly, a service bus ran along the main road past the site and was used by a handful of people (exact number not available, as there were also contract bus users in the questionnaire). It is not enough simply to say that there are facilities for public transport, therefore people will use public transport, therefore the location meets the criteria for sustainable transport.

In summary, the location of Lee Hall does not meet the needs for sustainable development or sustainable transport. It is a greenfield site heavily dependent on access by motor vehicle - indeed, its raison d'etre in the UDP is its accessibility by road. Its location is poor for promoting walking because it is peripheral to settlements, and this will not be mitigated by providing safe walking routes since the distance problem is paramount. Neither the location nor the TPK transport strategy has anything to offer by way of promoting cycling. The location has public transport routes in the vicinity, but, as is clear in national policy guidance (see below), this is a very different thing from saying that its location is optimal for public transport use.

LOCAL AND NATIONAL PLANNING CONTEXT

The planning application for Lee Hall relies on the designation of the site for development under Policy PG 11 of Bolton MBC's UDP of 1995. The basis of this designation, contained in the reasoned justification of PG 11, is the strategic location close to the M61 and the proposed A5225 link to the M6. The site was clearly viewed as an opportunity to build a high quality business park at a node on the strategic road network highly accessible by car, along the lines of for example Aztec West outside Bristol.

It takes an enormous leap of imagination to jump from this characterisation of the site, to the claims that the development accords with current national transport policies and objectives to reduce reliance on car transport. A greenfield site outside an urban area next to a motorway junction is about as far removed as is possible from a 'model' development location under PPG 13. The applicant cannot have it both ways!

The original PPG 13 set out aims to minimise the need to travel by car and the distances travelled by car and thereby reduce reliance on the car, and gave locational guidelines requiring local authorities to

"... adopt planning and land use policies to :

promote development within urban areas at locations highly accessible by means other than the private car;

locate major generators of travel demand in existing centres which are highly accessible by means other than the private car" (PPG 13 para 1.8)

It is unacceptable to claim conformity with the objectives of PPG 13 solely on the basis of there being some public transport to serve the site; the guidance covers the whole range of alternatives to the car, and is much more specific in its views of the type of sites meeting its accessibility criteria. For locations to be "highly accessible" relative to public transport they have to be not merely somewhere on a public transport route, but for example:-

be served by public transport in as many directions as possible rather than along a single corridor;

maximise the practical appeal of public transport use in terms of quality of service - frequency, journey times, simplicity of journey; comfort; or

maximise the convenience of public transport use, for example by being located next to a railway station.

The draft revision of PPG 13 (October 1999), which "build(s) on the existing approach (of PPG 13), rather than initiate a change of direction" (introductory letter), expands slightly on the requirements for location of development in relation to transport:-

"local authorities should:

focus major generators of travel demand in city, town, and district centres and near to major public transport interchanges" (draft PPG 13 para 14)

Lee Hall fits none of these criteria.

The Lee Hall TIA uses a single selective quote from PPG 13, that:-

"the likely availability and use of public transport is a very important ingredient in determining locational policies designed to reduce the need for travel by car" (in TIA 2.2.1)

The public transport 'strategy' for the development is to increase the frequency of one bus route from 30 to 20 minutes, and to divert it through the site. This is predicted (dubiously, as discussed later) to achieve a 4.7% shift from car to bus use. Neither the availability nor the use of public transport envisaged for the Lee Hall development is very impressive, so even on this one narrow element of PPG 13 the proposal fails. A location that can only achieve a 4.7% shift from car use is manifestly not a suitable location in terms of national transport objectives (typical targets for Green Transport Plans are for a 20-30% reduction in car trips over 3-5 years, even at difficult sites).

The current draft PPG 13 also emphasises the role of parking management in traffic demand management, stating that:-

"Some studies suggest that levels of parking can be more significant than levels of public transport provision in determining means of travel" (draft PPG 13 para 11)

It is therefore implausible to proceed with a TIA - even a more comprehensively based one than the TPK document - without consideration of levels of parking at the site. It is not acceptable to treat these as a reserved matter in the planning application, as they are integral to the considerations at the heart of the present application.

The 1998 Transport White Paper sets out the 'New Deal for Transport' to deliver an integrated transport policy. The Lee Hall TIA claims that the site will be developed under the principles of the White Paper (TIA 2.3.3), which it recognises to be that:-

"future planning strategies should ensure transport provision that is both integrated and sustainable" (TIA 2.3.2)

Draft PPG 13 clearly states that an integrated transport policy

"means integration ... with the environment" (draft PPG 13, para 2)

The failure of the TIA to address the environmental consequences of traffic is a serious omission, and leaves a gaping hole in the claim to deliver the principles of the White Paper.

The Lee Hall TIA refers at some length to the Bolton TPP (TIA 2.5) for 1999/2000. Although this was a current document in May 1999, it has been replaced by the Provisional Local Transport Plan submitted in July 1999. This not only supersedes the TPP but heralds a radically different approach to strategic transport planning and funding. Furthermore, draft PPG 13 places a requirement on local authorities:-

"to ensure that strategies in the development plan and in the local transport plan complement each other" (draft PPG 13, paras 5/14)

Even though the TIA pre-dates July 1999, the failure even to mention the LTP and its likely implications for the policy context of the application, which would have been known at the time through LTP guidance and the then current state of preparation of the provisional LTP, is a serious omission. There is an urgent need to supplement the TIA with a discussion of the Provisional LTP, for the Public Inquiry to be properly informed.

UDP 1995 Policy PG 11 is now out of step with present national policy towards transport planning, and it is understood to have been revised already in the review of the UDP, with Lee Hall no longer zoned for any type of development. The lack of prospect for the construction of the A 5225 to some extent undermined the policy basis even as it stood, and the advent of the provisional LTP set in motion a requirement to review the policy to ensure complementarity between development and transport plans. There is also a lack of information on key aspects of any consideration of the means of access, especially the intended level of parking provision but also the target modal split for transport to the site. All these reasons support the refusal of the application by Bolton MBC, and undermine the view expressed in the Grounds of Appeal statement, that "The current UDP is sufficiently up to date and in step with national and regional planning guidance" in the relation of Policy PG 11 to transport issues.

INFORMATION DEFICITS IN THE TIA

It is difficult to gain a full picture of the transport effects of the Lee Hall development from the TIA, which provides information only on traffic generation forecasts and then only at peak hours. This emphasises the main intention of the TIA to model traffic flows for highway design purposes rather than provide a complete transport assessment and strategy.

The following essential information appears to be absent from TPK's TIA (provisional comment as a few separate pages of the document were missing):-

total daily number of trips to site

total daily number of vehicle trips

forecast parking space requirements

estimated modal split for journey to work purposes

assessment of traffic impacts other than on queue lengths and journey delays for vehicles

Without this information, and a reasoned justification of the parameters on which the forecasts are based, it is difficult to assess fully the validity or otherwise of the transport strategy for the development, on which the planning application depends.

On current levels of information, the application should be rejected, since:-

the means of access other than by motor vehicles has not been considered

the levels of use of proposed site access points by all modes of transport are inadequately defined

the consequences of traffic generation, other than in the narrow field of traffic flows, have not been explored, let alone demonstrated

what little of a transport strategy has so far been outlined - increasing the frequency of the 559 bus service and diverting it into the site - is hopelessly inadequate

DETAILED ISSUES IN THE TIA

There are three main issues of contention in the details of the TIA, concerning traffic forecasts, the methodology for predicting modal shift to bus use, and the position adopted in relation to other possible trends in transport policy; and a few comments on detail in individual paragraphs.

Traffic forecasts

There are several aspects of traffic flow forecasts in the TIA which are unsatisfactory

In the absence of overall data on levels of trip generation and modal share, it is difficult to verify the forecast levels of generated traffic

There is no recognition in the 'predict and provide' methodology that highway improvements to meet predicted demand will induce additional demand, as discussed in the 1994 SACTRA Report.

The TIA emphasises reductions in traffic flows along Park Road, but these are insignificant west of the Platt Lane junction and are achieved only by some unsubstantiated redistribution of traffic (the modal shift alone, notwithstanding its questionable derivation, does not achieve reductions west of Platt Lane)

The TIA does not draw attention to substantial forecast increases on other traffic flows in the network (eg 30% increase on Platt Lane/ Bag Lane 2006 am peak; 34% increase in traffic entering Chequerbent roundabout west side 2006 pm peak), and makes no comment on the environmental consequences of these substantial increases.

The TIA takes account of two known committed developments in the area (TIA 13.5), but not of the housing development at Belvedere Farm, Himley Green (outline permission approved), nor of the possible effects of new housing at Bowlands Hey (subject to appeal)

It would be erroneous to assume that a modal shift due to the proposals for the 559 bus route would apply to all existing traffic on Park Road as well as to trips to and from the site; at best it can only apply to traffic with origins and destinations along the rest of the 559 route, which will only be a fraction of the total traffic flow. It is unclear from the TIA how the modal shift calculation has been made.

The effect of a modal shift to bus use from existing traffic is assumed only to apply if the development proceeds, which is only valid if the purported improvements to bus services would not otherwise occur

Modal shift forecast

The logic appears to be that increasing the service frequency of a bus from 30 to 20 minutes will reduce the waiting time for a bus from 15 to 10 minutes, and that the time saved feeds through to notional cost savings for public transport use which can be calculated mathematically (TIA Appendix A) to give a percentage shift to bus use. Apart from the methodology being of very dubious accuracy, this forecast depends on a basic premise which is wrong, that people will wait longer for a less frequent bus service. Regular local bus users know the bus timetables and will allow exactly the same amount of waiting time for a 20 minute bus service as for a 30 minute one. Only when service frequencies are down to below at most 12 minutes will people turn up at random in the knowledge that a bus will arrive in an acceptably short space of time, and even then this behaviour is most likely in inner city areas where buses do not run reliably to timetables anyway. Unless people are arriving randomly at the bus stop, the modal shift forecasting model in the TIA does not even begin to make sense.

Although of secondary importance, there is an extraordinary assumption in Appendix A, that non-fuel car travel costs are zero. In fact the marginal non-fuel travel related costs of car use (ie excluding fixed costs of ownership) are roughly the same as fuel costs, and a false comparison is being made if they are not taken into account.

Other transport policies

The TIA makes several references (eg TIA 9.3.4.1) to other general transport policies that may contribute to modal shift away from car use, such as the fuel tax escalator (in fact no longer government policy), and the workplace parking levy. These are not factored in to the transport strategy, which is therefore claimed to have a conservative/ low modal shift estimate. At the same time, it is argued that any effects of national policies will enhance the performance of Lee Hall in meeting the requirement to reduce reliance on the private car. It is suggested, at least by association, in TIA para 13.12 that this forms part of the case for the development proposals satisfying the objectives of national policy to reduce reliance on the private car.

It may be valid to use this line of argument to make a case that the traffic flow forecasts will if anything be on the high side - which is the main purpose to which the argument is put, although it is not necessarily correct - , but it cannot be used to contribute to the case for the particular development meeting national policy objectives to reduce reliance on the car. To the extent that national modal shift trends occur at all (an increasingly doubtful prospect as government is backing away from any policy actions at a national level) they will apply to any site and cannot be used to support the credentials of a given location. Lee Hall will be an under-performing location for alternative transport modes whatever the prevailing modal split nationally or regionally. Unless the transport strategy of the TIA is proposing a specific measure such as workplace parking charges, it cannot claim such a measure in support of the development's compliance with national policy.

There are a few further comments of detail on aspects of the TIA, although these do not have a significant effect on the main areas of discussion:-

Para 2.3.3 states that the transport strategy will be targeted to benefit new and existing workers, but there is no indication of how this will be done or even what it means, given the extremely limited measures proposed under the 'transport strategy'

Paras 2.5.6/ 5.1.4: it is not understood how a park and ride scheme at Westhoughton station will "encourage site generated traffic to use non-car modes", since in park and ride terms Westhoughton station is at the downstream end of journeys to the site

Para 7.3.2.3 confirms TPK's acceptance of the principles underlying the 1994 SACTRA Report, in that it admits to there being potential traffic growth that would occur with highway improvements that will not occur without improvements

Para 9.1.1: it is not understood how "The public transport strategy for the site ... aims to reduce car-borne trips to/ from the development by ... providing a mix of land uses on site to reduce the need to travel"; even if it is not the public transport strategy that is providing the mix of land uses on site, it is unclear what mix of uses it is that will reduce the need to travel

Para 9.1.4: the site is not "close to" Daisy Hill station, but around 1 km away, far enough to deter some would-be rail users

SUMMARY

The Lee Hall development site fails to conform with a number of aspects of current transport thinking, both locally and nationally, and the refusal of outline planning permission should be upheld. The main points are as follows:-

The application site fails the most basic tests of sustainable development, being a non-urban greenfield site located to maximise accessibility by car

The site fails to comply with locational guidance in PPG 13 to concentrate development within urban areas at locations highly accessible by means other than the private car; it fails still more comprehensively to meet criteria in draft PPG 13

The existing zoning designation under policy PG 11 of the 1995 UDP has not been examined for complementarity with the objectives of the Provisional Local Transport Plan, and is therefore potentially incompatible with a current local policy document, contrary to the requirements of draft PPG 13

The application makes no mention of walking or cycling, the two most sustainable modes of transport, and therefore the transport strategy supporting consideration of the means of access is flawed

The forecast modal shift from car to bus use is feeble compared with green transport plan targets and achievements elsewhere, and indicates the extent to which the site is inherently unsuitable for access by alternatives to car transport

The TIA supporting the application lacks some of the most basic requirements for assessing a transport strategy for promoting alternatives to the car, including a modal split estimate and analysis, forecasts of trip totals, access by non-vehicle modes, and a parking strategy; it is therefore not possible to determine the application, especially since it relates primarily to access to the development

There is no assessment of the environmental impacts of traffic generated by the development, such as noise, air quality, community severance, effects on accessibility for other road users, without which it would be premature to determine the application