We understand that this proposal will be put before the Planning Committee on AUGUST 19th, around 10am.
We’re hoping to speak on behalf of residents at the meeting and it will all be streamed live on the day. We’ll let you know more as we find out.
We understand that this proposal will be put before the Planning Committee on AUGUST 19th, around 10am.
We’re hoping to speak on behalf of residents at the meeting and it will all be streamed live on the day. We’ll let you know more as we find out.
The Council have uploaded the Designers Response Report to the planning portal. You’ll see it at the bottom of the documents list for some reason and it’s called “RESPONSE REPORT – STAGE 2 RSA”. If you scroll all the way down to “Appendix B – Decision Log”, you’ll see the response to the concerns raised in the safety audit.
In a nutshell, the developers propose to do nothing to mitigate the NEW risks they introduce with this proposed change to the junction design.
The risks identified in the Safety Audit were;
We should not be surprised by this, as it is consistent with developers disrespect for public safety in name of profit.
So if you happen to think that this is a damning indictment of Barratt Homes, then please do feel free to object to the proposals on the grounds;
A) the developers do not propose to mitigate the risks as per their own Road Safety Audit and therefore the changes will introduce NEW serious risks to the junction that will impact pedestrians and vehicles.
B) the developers use the excuse that they would need to use more third party land at number 243 Longton Road to mitigate one of the risks and this is not feasible. The developers OWN this land, so this claim is ridiculous.
C) the developers are hiding behind the Inspectors rationale for granting planning permission. However the Inspector was not qualified in Highways Engineering and the detailed design must be signed off by the Local Highways Authority as technically safe and based on sound engineering principles, which of course the design the inspector ‘approved’ meets neither of these criteria.
D) the developers have not yet submitted a capacity assessment that follows best practice guidance and sound engineering principles which includes the modelling principles of TRL. Therefore the base model they rely on, is not fit for purpose and results in serious Highway Safety Risks.
There is critical information missing from the application that make it impossible for residents to develop a properly informed opinion on which they can comment on the application.
The developer could rectify the dispute about the Highway Safety technical issues related to the junction once and for all by simply being honest and demonstrating that the junction improvements are indeed safe by;
Finally, we would remind the LHA of their duty to ensure that;
The original junction design and the improved junction design fail on all of the points above and given that Local Authorities have statutory duties related to road safety, including a duty to;
It would be a deliberate act of negligence on behalf of the LHA and the Officers involved to knowingly grant technical approval for a design with the above Highway Safety issues.
Until such time as these documents (A and B above) are available, we recommend OBJECTION to the proposed improvements, but when the developer supplies them and they show that the junction will genuinely be safe in highway safety terms, we should be prepared to support this “improvement”.
UPDATE 21 July
To access the Council Planning Portal go to the website (www.planning.stoke.gov.uk/online-applications) to view the application and track its progress by searching for the reference: 65439.
Regrettably, there isn’t enough information provided by the developer to allow us to support or object to the specific proposal at this stage. There are plenty of technical aspects that will have a direct impact on safety at the junction that we’re working through and will update this site with shortly. A number of things we’re sure of is that the capacity assessments of the future junction are technically unsound;
We’ll pop more of a reasoned argument online shortly, however something you can do right now if you’d like to make a start is to ask the council;
The Road Safety Audit states that vehicles can not undertake all manoeuvres at the junction efficiently and safely and therefore collisions with other road users may occur and that there is potential for pedestrian strikes at the crossing point on Meadow Lane leading to injuries. The safety audit recommendation is;
“It is recommended that the right turn harbourage is extended on Longton Road to ensure vehicles can safely enter without overhanging the opposing running lane. It is also recommended that the eastern kerb line is amended to provide a greater radius for vehicles to exit Meadow Lane in the correct lane and reduce the risk of a vehicle overrunning the pedestrian crossing point.”
However as these recommendations will be difficult to put right for various reasons, we are not surprised that the developers have not put forward a corresponding Designer’s Response. BUT this is a requirement and the Council have to sign it off.
So, if you write the council asking for them to publish in plenty of time for you to make an informed decision, the designer’s response to the RSA, particularly on 4.2.1 “Basic Design Principles”, as they apply to the approved and proposed layout.
You can register your objection to the scheme until the Designer’s Response is published, and reserve the right to remove your objection if they manage to solve the issue.
Barratt Homes have responded to the one of the safety points for the junction and are proposing a few tweaks to the design. They widen the turn into Meadow Lane slightly and move the pedestrian refuge to the top of the junction.
As the proposed changes go, they seem sensible at first sight and are certainly better than the nonsense that was approved at the Appeal.
There are issues with some of the ‘facts’ stated by Knights in the application documents and the changes do absolutely nothing to improve overall safety at the junction given that permission for it was granted based on the developer endorsing what they knew was unsafe engineering practice and deliberately misleading the Inspector.
All of the documents are available on the Council Planning site, just search for Meadow Lane!
We will carefully consider the application and will update this blog with our views in time for residents to support or object to the proposal.
Barratt Homes, not content with the planning permission obtained by dishonest, underhand means, are now trying to circumvent due process at the cost of local residents again!
To be absolutely clear, Barratt Homes with their partner in crime Ascalon Properties, have planning permission to change the Meadow Lane / Longton Road junction to facilitate their scheme to destroy the Meadow. Their ‘approved’ plan for the junction is quite clear and according to them quite safe, despite the fact that there is nothing they can do to make that junction safe for the development.
To implement the plans for the junction, they need to come up with a detailed plan, have it approved by the Local Highways Authority, then get a Section 278 agreement in place to allow them to make the changes.
Because of their deceit at the Appeal about their plans for the junction being safe, they’ll now find it virtually impossible to be able to actually prove that it is safe enough to be added to the local highway network when it comes down to detailed planning.
And so, in Barratt’s usual weaselly way, they have started what we suspect will be a long campaign of underhand tactics to undermine our democratic processes with no regard for the impact on existing residents, because quite frankly they have proven that they only care about profit and do not care a jot about the people they impact, including their own customers.
They have, without providing any actual reason or explanation applied to have the double yellow lines at the junction doubled in length, thereby denying perfectly good parking at the end of Meadow Lane for residents, parents who then continue on foot to Ash Green, shoppers who walk round to the Brough Lane shops, visitors who go on to access the canal towpath on foot, and very importantly to staff, customers and delivery drivers related to Trentham Bathrooms.
The impact of displacing this parking, has not been considered and it will create a safety risk, as it will force drivers to park further down in Meadow Lane, adjacent to driveways and particularly near the bottle neck outside number 22.
The reason they do cite is; to ‘facilitate’ a s278 agreement. The issue with this is that the s278 agreement does not exist and no-one knows what will be in it, and if it is consistent with the approved appeal junction design, then there is no need to increase the length of the double yellow lines!
We at KOMG ask that if you believe like us, that this another cynical attempt by Barratt Homes to circumvent due and democratic processes that would require a proper assessment of the impacts in a detailed plan, or you do not wish for the top of Meadow Lane to become a dangerous congested parking area with displaced vehicles then please do object to the plan by ;
with reference MB/NM/TRO12/2019.
See the full Notice from the Council here: Notice and Documents from SOT CC
For more information such as details of the councils policy of approving Double Yellow Lines when there are;
David Follows on 01782 234963
Given Barratt’s track record, this probably won’t be the last of the double yellow lines they’ll apply for. We reckon that they’ll also apply for double yellows throughout the estate as they can not get the construction traffic safely through if residents park cars legally on the roads!
Lastly by the way of other news, we’re continuing to work on behalf of residents, and are at the final stage of a complaints process with Planning Inspectorate. So far, the Planning Inspectorate have had to apologise in writing for mishandling our complaint (trying to fob us off), and they’ve also had to uphold our complaint about the Inspectors decision on the junction. There is more to come……. keep an eye on the blog.
I write this post absolutely stunned that despite 4 years of substantive facts showing that the junction will not work, and the representatives for the Appellant’s constant misrepresentations and lies, the inspector has ignored the application of the law of mathematics in the traffic flow calculations and still granted planning permission.
What can you say! Click the link below to read the decision.
Update: We’re getting a lot of feedback on this and summing it up, it suffices to say that it just shows how tilted in favour of developers, this process is and that it must be acceptable to be dishonest, mislead the Inspector and have your lies taken into consideration in support of the decision. During the Appeal, KOMG did ask the Inspector if witnesses were considered under oath when giving evidence, however the inspector said no, he just expected them to be honest. So, they’ve got away with it. If they’d have been under oath, they’d have been guilty of perjury and could be prosecuted.
I have to say that this kind of decision which beggars belief and flies in the face of the facts, must be why the developers have been so blatantly sloppy and deceitful all along. They always knew they’d win irrespective of the lies or disregard of public safety.
This week saw the closure of the Inquiry and now we just have to wait for the Inspector’s decision, which will be published on or before 10th July 2019.
The developers somewhat to our surprise, took the same old dismissive approach as they have throughout the planning process, having seemingly little regard to either the truth or facts. They absolutely showed what they thought of residents and the poor people who would buy their houses if indeed they did win.
For our part, representing local residents, all we needed to do was to point out the usual lies and misrepresentations of the developers. It was much easier than usual this time, as they had resorted to huge whoppers to get their point across. It was embarrassing to sit there whilst local law firm Knights, sided with the developers and endorsed their position.
When the enquiry opened earlier in the year I was robustly interviewed by BBC Radio Stoke. In that interview I claimed that the developers had no regard for the safety and interests of the local community. The BBC, to balance the argument suggested that the developers might say otherwise. Well, it is now a matter of public record that I was right. In the developers evidence presented at the Inquiry on the last day was this;
I conclude that even if Mr Oates (the developer’s transport expert) is incorrect about this matter ( that the junction is safe ), and that there is some highway harm arising from the use of Meadow Lane, I still maintain that the proposal accords with S.38(6) because of the material benefits that I set out within my proof, and my opinion that these benefits would outweigh any such harm.
So, what they are saying in English, is that even if it is proven that the changes proposed to the Meadow Lane/Longton Road junction will result in increased safety risk and harm to traffic, cyclists, wheelchair users and pedestrians, then they really don’t care and still want the development to go ahead. They actually said this… honestly and it’s in writing too.!!!! I’m lost for words ( that I can write in this blog ) to describe their attitude of endorsing developers greed over the health, well being and safety of residents and drivers of vehicles through the junction.
This time around they have even taken the view the laws of mathematics don’t apply to the equations that predict traffic capacity at the junction…. and…. that the equations that predict traffic capacity at roundabouts are more applicable! It is truly astonishing.
Our points and those of the council are in full agreement so to finish off this post, below I have included our closing statement. (Mr Oates is the developers transport witness)
Keep Our Meadow Green
24 May 201
In our closing statement we focus on the remaining key areas of dispute between the Appellant and KOMG.
Mathematics and Entry Width
There is disagreement about the influence of minor arm entry width vs relative major arm flow on the capacity of a T junction. The TRL equation used in PICADY to calculate capacity at a T junction is agreed upon by all parties, however it is the view of Mr Oates in AP/9 1.2.13 that the capacity equation requires the “correct interpretation” to enable the solution to the equation to support his hypothesis; that adjustments to the width of the minor arm result in a more significant influence on capacity at the junction than would a similar proportional adjustment to the major arm flow.
Mr Oates’ hypothesis that a simple mathematical equation (such as the capacity equation) can be interpreted is illogical and does not stand up to basic tests.
Given that the solution to the capacity equation is not open to interpretation, and would have enabled Mr Oates to have proven his point beyond any doubt whatsoever, whilst simultaneously dismissing Mr Parker’s evidence, one needs to ask why did Mr Oates not include such an analysis of this simple mathematical equation worked with parameters of the Meadow Lane T junction in his AP/9 document? During cross-examination Mr Oates could not account for the omission of what would have been pivotal evidence in support of the Appellant’s case.
Mr Oates when cross examined, also confirmed that he had run incremental sensitivity tests for the junction, which he indicated had proved his case and thus proved the benefits relating to the design of the junction improvements
One also needs to ask why did Mr Oates not include in his AP/9 document, any evidence at all from the sensitivity tests? If Mr Oates is to be believed, such sensitivity tests would have also demonstrated beyond any doubt whatsoever that minor arm entry width has a more significant impact on capacity than major arm flow, and would have unequivocally proven the case for the Appellant.
However, replicable results of the capacity equation and sensitivity tests always have, and always will support the facts presented by Mr Parker due to the absolutely certain and indisputable laws of mathematics. These same laws also make it impossible for the capacity equation to ever support Mr Oates’ hypothesis. Therefore, the only logical conclusion that can be reached is that the additional analysis undertaken by Mr Oates did no such thing and thus his statement should be afforded no weight at all.
Mr Oates’ AP/9 rebuttal also involved contacting TRL to obtain clarification regarding entry width and traffic flows at priority junctions.
However, the graph provided in the rebuttal statement is missing key information that renders it meaningless in proving the Appellant’s case – there is no title, there is no source quoted, there are no ‘Y’ axis labels, and there is no legend explaining what lines ‘A’, ‘B’ and ‘C’ represent.
Therefore, our view is that the graph should be afforded no weight at all.
Notwithstanding the above, it is our contention that it is quite clearly the same graph as that provided at the Inquiry (by Mr Parker) on page 4 of the TRL document (R/6) “Roundabout Capacity: The UK Empirical Methodology”.
If the conclusion is reached that the two graphs are the same, illustrating the same data and equations, then one must question why TRL would have sent Mr Oates a graph relating to roundabout entry capacity, when all other correspondence between them related to priority junction capacity? (Mr Oates did not present the correspondence relating to the graph to the Inquiry)
In respect of the graph itself, given that the straight lines on the graph represent the relationship between the two terms (‘x’ and ‘y’) within a specific linear equation – a mathematical fact that has no room for interpretation – if the conclusion is reached that the two graphs are the same, and that they actually refer to roundabout capacity; then it is simply not possible for the same graph to relate to priority junction capacity, as the equations relating to each are fundamentally different.
It is clear that there is a fundamental disagreement between the Appellant, the Council and KOMG regarding the current operation of the Meadow Lane junction with Longton Road, and the reasoning behind the calibration of the base model using the ‘Direct Intercept Adjustment’ (DIA), which as agreed at the Inquiry is also known as ‘Intercept Correction’.
However, the one issue on which all parties are agreed is that, at the give-way line, left-turning vehicles from Meadow Lane are not constrained; they can leave the existing residential estate with minimal delay once at the give-way line.
Therefore, one needs to understand why the correct geometrical inputs into PICADY do not replicate the existing conditions, and hence why the DIA is required?
The logical answer to this can only be that, if left-turners from Meadow Lane are not constrained in themselves (as agreed), and the only turns that are made at the junction from Meadow Lane are a left-turn and a right-turn (as evidenced by the count data); then it must be the right-turners that are constrained at the give-way line, due to a combination of influences on their movement that PICADY simply cannot replicate through geometry and traffic flow inputs alone (as evidenced by the fact that without the DIA, it materially under-represents the queueing and delay at the junction).
Given that the DIA is an adjustment made to the capacity of the give-way line itself, it therefore follows that if the future proposed layout does nothing to change Longton Road itself, and nothing to improve the right-turn movement from the Meadow Lane give-way line onto Longton Road (both points agreed by Mr Oates, under cross-examination), the DIA simply cannot be removed in the future year model.
Even though the proposed junction improvement provides a separate flared lane for the right-turning vehicles, the external factors influencing their movement from the give-way line (which required the DIA in the first place, and to which the DIA relates) have not changed.
Using engineering judgement, the DIA must be retained; there is no other logical conclusion to this issue.
Part of the Appellant’s case (albeit it is acknowledged that they do not seek to rely on this element) is that the provision of two separate lanes for traffic on Meadow Lane will afford the opportunity for right-turning drivers to reduce their delay at the junction (when waiting behind other right-turning vehicles) by utilising the left-turning lane, to instead make a left-turn from Meadow Lane and take a different route to their eventual destination.
Mr Oates’ AP/9 rebuttal includes journey time surveys, both from Google and from real time survey data.
Notwithstanding the fact that both the KOMG and the Council believe the survey data should be afforded little weight, it raises an important question.
Why does the existing traffic count data for Meadow Lane show that left and right-turning vehicles are roughly evenly split during the peak hours? (a matter of fact agreed between all parties)
Given that the journey times provided are from the give-way line at the junction of Meadow Lane with Longton Road, any delay on Meadow Lane itself is not included. Therefore, surely logic would suggest that if the current journey time savings were the same as those provided by the Appellant, more drivers would choose to turn left now?
The fact that they do not speaks for itself; therefore, the statement made by the Appellant that future traffic could choose to turn left rather than right should be afforded little weight.
Our view, as stated in the cross-examination of Mr Oates, is that the proposed junction layout will actually afford right-turning drivers with an opportunity to avoid the delay in front of them, by utilising the left-turning lane on Meadow Lane, but then either making a U-turn on Longton Road outside the care home (some 150m from Meadow Lane), or by turning right from the left-turn lane, i.e. undertaking those already waiting to turn right. There is comfortably enough space within the central reservation section of Longton Road to sit two vehicles side-by-side.
The suggestion by Mr Oates that a driver would not disobey the highway code, or would not undertake a blatantly reckless manoeuvre is missing the point somewhat.
The driver in such situations, as seen across the country on a daily basis, is not acting rationally; the reason they are not acting rationally is borne out of (either current or previous) frustration at sitting in a queue and being delayed. Indeed in his reply in cross examination, Mr Oates used the example of a red traffic light as a common method used to control traffic at a junction, at which he would expect drivers to be compliant with the highway code and not to make reckless manoeuvres.
However, running through red lights is a common occurrence that illustrates the fact that frustrated drivers will make reckless manoeuvres to save the delay of just a single traffic light cycle. The fact that authorities increasingly see it necessary to implement road safety cameras at busy signalised junctions to deter irrational driver behaviour clearly demonstrates beyond any doubt that some drivers do behave irrationally.
This is the case being made by Mr Parker (and the Council), that with the proposed layout doing nothing to improve the right-turn from Meadow Lane onto Longton Road (at the give-way line); queues and delays will increase significantly, at which point drivers will become increasingly frustrated when leaving the residential estate.
This will inevitably lead to inappropriate or hazardous manoeuvres being undertaken and causing an unacceptable impact on highway safety.
Entering Meadow Lane
Mr Oates in AP/2 section C, provided swept paths of large vehicles entering Meadow Lane which clearly show no room for error before kerbs are overrun. From the swept paths it is clear that there is no margin for deviation from a perfect path and even a small deviation of one tyre width from an unmarked entry trajectory will result in kerb overrun and an unacceptable risk to the safety of pedestrians and wheelchair users at the junction.
Mr Oates claims that professional drivers of large HGVs will be able to follow the unmarked perfect trajectory (as indicated in the swept paths) to negotiate the “tight” entry to Meadow Lane safely. However it is unlikely that drivers will know the specific trajectory needed or be able to follow it exactly if they do. This will force drivers to decide either to continue on a trajectory that will overrun the kerbs, or to manoeuvre back and forth whilst blocking Longton Road to improve the position of their vehicle relative to the trajectory needed to safely enter Meadow Lane.
This issue should be afforded significant weight, particularly given that this is the route used by parents with small children & pushchairs to walk to and from school, and also frequently used by carers and vulnerable people in wheelchairs from the three adjacent care homes.
For the period in which there is no canal bridge after the junction works are complete, this is the only route into and out of the site for all users and construction traffic, thereby further elevating the risk of collisions with pedestrians.
Moving onto the issue of ‘outlier’ datasets. Mr Oates asserts that the 2015 dataset is unrepresentative of normal conditions at the junction.
In Mr Parker’s Proof of Evidence Appendix 3 “RDS October 2015 Queue Surveys”, highlighted on the 07:50 and 07:55 lines you see queues of 16 and 20 vehicles.
This too under Mr Oates’ assessment would class as an unrepresentative outlier.
However, given that out of six randomly executed traffic surveys on the Meadow Lane/Longton Road junction, two would contain anomalies and be classed as outliers is absurd.
The reason one in every three of the surveys contains an anomaly, is that it is not an anomaly at all. It is in fact the natural and regular result of the junction becoming more and more sensitive to small deviations from what Mr Oates considers to be representative conditions; a point made clear in Mr Parker’s evidence to the Inquiry as demonstrated by the poor ‘Level of Service’ of the junction.
Finally, the issue of accessibility is a disputed matter and KOMG has set out in detail distances in the Proof of Evidence including acceptable distances weighted with Journey Purpose and Length of Stay with reference to MfS and the IHT Providing for Journeys on Foot (IHT-PJF) and SHLAA (Appendix 1). When calculating acceptable walking distances for journeys on foot, various factors must be taken into account. Using a simple point-to-point baseline distance measure is unsafe and does not reflect observed behaviour.
Although the Appellant provided a drawing (AP/14) titled “Walking Routes from Proposed Pedestrian Bridge” at the resumed Inquiry, they yet again did not provide any verifiable location data as to where within the development the distances were measured from, nor state that the bridge would bring Trentham Mews Medical Centre (adjacent the Man in Space on Eastwick Crescent) within a comfortable walking distance and a significant benefit to residents of the new and existing dwellings.
Should the development be approved, it is essential that the pedestrian footbridge over the canal is built as soon after the junction improvements as possible to mitigate the unacceptable highway safety risks to pedestrians from the existing estate and the new development, that the new junction layout introduces.
In conclusion, it is our contention that even with the improved layout the Appellant significantly overestimates the capacity of the junction, and thus the impact of the proposed development traffic on the Meadow Lane junction with Longton Road, which would then become the sole point of access for 597 dwellings, would be severe.
The junction would fail to provide safe and suitable access to 597 dwellings.
There would be an unacceptable impact on highway safety.
Therefore, the proposed development would fail to meet necessary tests set out in paragraphs 108 and 109 of the Framework.
Accordingly, it is our view that the Appeal should be dismissed on highways grounds.
Residents and Councillors are holding a public meeting on Tuesday 7th May to update everyone on the progress of the appeal and the latest developments, including the recent application for a bridge over the canal.
Once again we need as much support as possible, so please tell you neighbours, friends and family to come along and join us at the meeting.
Please also take a look at our Just Giving page.
See you there!
To ensure the final refusal of permission to destroy the Meadow and its protected wildlife, a JustGiving page has been set up for supporters. To read more and kindly donate to towards the costs of professional representation at the Appeal, visit the page here:
For a quick reminder of what is being destroyed, swing by our Life in the Meadow page.