A new Road Safety Audit (RSA) was submitted in June 2022 and can be found on the Planning Portal in the document list titled:
"RSA - StationRoadToddingtonRoad - Stage1RSAV1.0 - REDACTED - 16.06.22.pdf"
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The RSA, like the previous one, was submitted by “Acorns Projects Ltd” on behalf of the Applicant (Willis Dawson Ltd) and their planning consultants WSP.
The site visit took place during a school half term week which also happened to be the double bank holiday week of the Queens Jubilee. This was a very quiet week for the local roads as would be expected, and highly likely to be the lowest pedestrian and vehicular traffic volumes of the whole year! It is also a total misrepresentation of the truth of the situation regarding the road safety issues of the proposed development scheme.
Refer to the RSA page 5, Section 1.6, Quote:
“1.6 A visit to the site was undertaken between 15.30 pm and 17.25pm during the afternoon of the 30th May 2022 by both Audit Team Members together ...”
Not only was the RSA was conducted during a school half term and double bank holiday week the surveyors even had the audacity to mention the small number of pedestrians and vehicles!
Quote from Section 1.6:
"Vehicular traffic conditions in Toddington Road and Station Road at the time of the afternoon site visit were observed to be light to moderate. Eight pedestrian and three pedal cyclists were observed during the afternoon site visit.”
One of the key policy requirements of this site allocation (HAS20) in the Local Plan was to provide “safe access to the school” and parking provision for child drop-off as also stated by the planning inspectors in their review of the HAS20 allocation. The RSA again fails to address or even mention these as issues or requirements of the development scheme.
The issues in this latest RSA are much the same as the previous RSA, no mention of the school or children in relation to the safety of the scheme. In this version, Station Road is mentioned but the issues raised are limited to relatively minor issues of skid risk and surface water drainage. The glaringly obvious pedestrian Safety Issues that already exist and that will be made worse by the recommendations have been ignored.
[OPINION]This so called “Road Safety Audit” is the latest attempt by the applicant to deceive the public and to get away with the bare minimum of improvements and leave the infrastructure in it’s current substandard state despite a proposed new large school and 400+ houses.[/OPINION]
As should be expected, and be common sense, the main goal of an RSA for a proposal involving a school should be to assess public safety in relation to children and parents accessing the proposed new school, in this case, from the existing village which is on the opposite side of the “Midland Main Line” railway line from the proposed school and houses.
There is no mention of children anywhere in the document, even searching for the words children, child, parent, returns no results, the word school is only mentioned once and is only in relation to the description of the proposed development.
According to the RSA the issues are minimal and it even makes the claim that there are no issues for pedestrians, cyclists or horse riders.
Section 3.4:
"3.4 WALKING, CYCLING AND HORSE RIDING
3.4.1 No Problems identified in this category at this Stage 1 Road Safety Audit.”
It is a known fact that school children (and other pedestrians) walking to and from the Train Station along Station Road can regularly be seen having to walk in the carriageway to avoid other pedestrians due to the footway not being wide enough. None of the proposals address this issue as there is very limited scope for footway widening. Obviously, no school children would have been present to observe during their site visit.
In terms of the timing of the visit, I would have thought that the purpose of the visit to Station Road and Toddington Road was to determine the baseline conditions on a typical school day during a time range which is most relevant in terms of pedestrian (especially children) and vehicular traffic movements, ideally covering 3 to 7pm.
By choosing a day in a week which was both a school holiday and a never seen before, double holiday week, it is clear that the “Road Safety Auditors” were attempting to establish a false baseline in order to misrepresent the maximum available headroom for future traffic increases resulting from the planned development.
This is clearly immoral and should be illegal, the primary concern of the Road Safety Auditors should be public safety especially where there is a school planned as part of the development.
Road Safety Auditors are governed by the CIHT Society of Road Safety Auditors (SoRSAa) who have a code of conduct:
https://www.ciht.org.uk/become-a-member/ciht-membership-for-individuals/membership-code-of-conduct/
"The Code of Conduct covers the areas of competence, conduct and professionalism in members' duties to employers and clients, to the profession and to the Institution. The Code details members' obligations to safeguard the public interest. Any allegation of a breach of the Code is investigated by the Professional Conduct Panel and appropriate action taken under CIHT's disciplinary procedure."
[OPINION] It is clear that in this case, the road safety auditors primary concern looks to be for the profits of their client (WSP / Willis Dawson & Landowner) and obtaining future business from said client rather than actual road safety. [/OPINION]
Anyone concerned about this RSA and the behaviour of the company and individuals involved should use the CIHT complaint form available from the above link. The names of the Auditors can be obtained from the RSA document linked at the top of this page.
A Road Safety Audit was carried out in November 2021, it is not listed directly on the Planning Portal document list for the Outline Planning Application, but can be found buried inside the “Technical Review” document which is listed in the document list.
The document is titled:
"Appendix D-E Technical Review 08.12.2021.pdf”
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The Road Safety Audit (RSA) Document starts on page 40.
The RSA Brief starts on page 64 and the designers (WSP planning consultants / Willis Dawson) reponse to the RSA starts on page 19.
**There is no mention of any mitigations for station road and no mention of any road safety issues on station road, despite it being probably the biggest road safety issue for the school children and parents. In fact the words 'Station Road' cannot even be found in the RSA **
There is no mention of children or parents anywhere in the RSA, nothing at all, not even in relation to any of the roads that are actually mentioned. The word School only exists in the introductory description of the development, it is not mentioned at all relation to any road safety issues.
The RSA fails to either explore or address the 2 most important issues raised by the planning inspectors in their review of the HAS20 local plan allocation, safe access to the school and parking provision for parents who need to drop-off children. These are not even mentioned as issues to be considered.
As part of the RSA, a site visit took place, see section 1.6, Quote:
A visit to the site was undertaken between 13.15 pm and 15.30 pm during the afternoon of the 1st November 2021 by both Audit Team Members
13:15 to 15:30 is one of the quiestest times on the local roads and Section 1.6 then goes on the state that traffic conditions were light on the 3 local roads with no cyclists and only a few pedestrians, 1 on Toddington Road, 3 on Westoning Road and none on Barton road. There was no mention of the most dangerous road for pedestrians, Station Road. The timing of the site visits appears to have been chosen in order to misrepresent the local conditions.
The words children, child or parent do not even exist anywhere in the entire "Technical Review" Document. The word school only exists in 3 places and only in relation to the description of the development.
Although cyclists are mentioned in the document in relation to the roads that are mentioned, there is no mention of horse riders who are frequent road users in the village.
There is a section titled "3.4 WALKING, CYCLING AND HORSE RIDING" but that is the only place the word horse is mentioned at all in the document.
It is important that the safety of all road users is taken into account.
There is also no mention of the other large proposed developments and their cumulative future impacts on Station Road, Toddington Road, Westoning Road and Barton Road.
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