Dear Mr. Kemp,
I object to the planning CB/21/05416/OUT for Land to the West of the Mainline Railway Line and North of Toddington Road, Harlington.
The general objections to the development, known as HAS20, raised as part of the earlier stages of the planning process have not been adequately addressed: the impact of taking Greenbelt and increasing Harlington’s population by over 1,000 (with further increases of 300 when the 140 houses proposed for Sundon Road get developed) leave Harlington worse off. The Council (CBC) has provided no firm or binding proposals for the schooling (installing a two tier school in a three tier area), the necessary increase in the medical facilities (apparently this is the NHS’s problem) or the material changes necessary to the road network to improve safety and prevent congestion (the current proposals only make the roads more hazardous, busier and slow travel times). The development should not proceed until firm and binding plans, that demonstrably improve road safety for the whole village, have been presented by CBC and accepted by independent oversight.
Notwithstanding the foregoing objections, this objection focuses on the impact of the increase in traffic that will be created by the proposed development. There will be increased traffic safety problems created during the many years of construction (more than five years was advised by the developers' representatives at a recent public consultation due to the works necessitating diversions, say). Thereafter, a further 700 cars (based on the ONS data that there are 1.6 cars/property) will be using the village roads, plus the additional traffic accessing and egressing the 2FE school (the school numbers have been expressly excluded from the analysis in paragraph 5.3.5 by reference to the WSP Transport Assessment). The current position of the CBC Highways is that more work is needed on the analysis of traffic, designs and implementation (see internal memo from Jethro Punter dated 19 January 2022).
Although a Transport Assessment (hereinafter referred to as the Assessment) has been done by WSP, on behalf of Willis Dawson Ltd. (TA1 dated November 2021), alleging that the increase in traffic can be addressed, the conclusions drawn in Section 10.2 erroneously state that the requirements of the NPPF should not prevent the development being refused on highway grounds. This is an error because there are unsupported assertions on the habits of NMU’s, inconsistencies in the arguments presented to support the proposals, no meaningful reference to the fundamental impacts on the village caused by the plans to rearrange the traffic flows throughout the village and makes no material reference to the flow of traffic to/from the A6 (and Barton).There is no proof provided that there will be any modal shift from cars to other modes of transport (walk, cycle or use the bus) by the residents and users of the proposed site or the existing residents of Harlington: (Page 7/70).
Irrespective of the Assessment being prepared to “encourage” sustainable travel for the proposed site there is no evidence provided that shows that those who move into the proposed site or those that already live in Harlington will not use their cars: existing residents drive to the shops, surgery, church, railway station and drop children at the schools. For example, a shopping trip will be to Flitwick or Barton, rather than Westoning (there is very limited parking at the shops) because supermarket shopping requires a car trip (once a week, say) and the residents of the proposed site will adopt exactly the same mode of transport – they do not and will not walk/cycle or use the bus/train to do a “big” shop! Making travel times and the journey through Harlington more difficult, will cause congestion not a modal shift. Moreover, the surgery is only open on weekday mornings; all afternoon appointments for Harlington residents are in Sundon Park for which access is only available by car/taxi. There is nothing in Section 4.2 or 4.3 that evidences that a modal shift will occur now, during the construction of the proposed site or during the time new residents start to occupy it.
The “comprehensive range of measures” for the proposed site (paragraph 5.1.2) may well support future sustainability in theory (albeit no meaningful evidence is provided for what this will look like), but it will only have an adverse impact on the rest of Harlington. The use of Greenbelt for the development should set a higher standard for ensuring that the impact of any development is at worst neutral but should show material improvements for the whole village – not just the junction with the railway station. The measures proposed in paragraphs 5.1.3 to 5.1.16 inclusive do not improve traffic throughout the village and will not encourage a modal shift away from cars by either existing or new residents.
The highway geometry and the local topography have not been meaningfully referenced in the Assessment either. The centre of the village (the crossroads) is at the top of a hill. The road network is generally below standard carriageway widths at 6m in most cases (not suitable for HGV or PSV) and less in many and the footways are narrower than 1.2m and absent in many cases. These existing highways are therefore not suitable for the large numbers of pedestrians and/or cyclists that the Assessment is trying to encourage. The roads that are on hills (Station Road, Westoning Road, Barton Road and Sundon Road) are not easily travelled by most walkers and cyclists due to age (young and old), infirmity, overhanging bushes, narrowness/absence and quite reasonable safety concerns. There is nothing in the Assessment that alleviates these issues and so it does not show that new residents will walk or cycle in preference to car driving.
The vertical and horizontal alignments keep traffic speeds below the 30mph limit; as was evidenced for the access to the development on Sundon Road several years ago (26mph). There is no need for traffic calming with the existing traffic numbers, even prior to COVID. The 2019 data used to uplift the “COVID” period data by 22% is not meaningfully cross referenced. The introduction of traffic calming measures (paragraph 5.1.12) that are intended to make the Goswell End Road more attractive will make access/egress to the Upper School more hazardous, compounded by the additional students arriving from the proposed site, making the junction with the Westoning Road busier, compounded by the bridge (traffic prioritisation), making the drop off of children by the 2FE school access/egress busy, causing queues on the approach to the A5120 and making the junction with the A5120 busier too. The roundabout at the access/egress from the Toddington Road to A5120 is the safest route used by many villagers whether travelling towards the M1 or Flitwick. There are no new safety measures shown in the Assessment (save for refreshing the white lining: see paragraph 5.1.6) at the Westoning Road/A5120 where the Assessment intends to encourage traffic flow increasing congestion and/or hazards.
The measures proposed for Station Road (paragraphs 5.1.14 to 5.1.16 inclusive) are disingenuous at best and arguably making safety and congestion worse: this will affect traffic using the crossroads. In particular the proposed 300mm widening of the footpath on the bridge will narrow the sub-standard lane widths further. This will create sight line issues for drivers, force vehicles into the middle of the road on a blind bend (multi-storey flats proposed here will exacerbate this further) and risk wing mirror collisions with pedestrians using the footpath, among numerous other hazards. In addition, the additional congestion caused by slower moving traffic, the increased traffic volumes and the traffic prioritisations will compromise air quality especially on Station Road and Westoning Road. The Assessment does not address air quality.
It is not known what the provenance of the statement that the existing lower school will be replaced by the 2FE school – the former is a three-tier academy and the latter is a two-tier CBC school. Notwithstanding this anomaly, the closure of the existing lower school would divert the 145 pupils (paragraph 4.3.5) to the new school via Station Road. Station Road is already below highway standards and unsuitable for large numbers of NMU’s at any time (see paragraph 3.2.16), but many of the pupils that live in Harlington are driven to school by their parents, on their way to their place of work, and many pupils are from out of the village and invariably are driven to school. These pupils will be driven to the new 2FE school: the pedestrian routes are not safe for parents with buggies/prams and/or escorting very young children.
Yours Sincerely,
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