National Highways have submitted a further holding objection asking for more details from Royal Mail before any decision can be made. 

Their objection is in full below. 

It is worth noting that they have also specified that the proposed exit is not "approved" by National Highways as outlined in the leaflet posted to residents of Patcham recently.

"We observe that the proposed access connects directly with the Local Road Network (LRN). The location of the proposed access has now been moved closer the junction with the SRN. Whilst this has been done on the basis of discussions with National Highways, the proposed location has yet to be approved.

As the access is closer to the Patcham Interchange, this will need to be assessed in terms of potential impact on the operation of the SRN junction."

National Highways Planning Response (NHPR 22-12)

Proposal: Demolition of existing buildings and erection of storage and distribution building (B8) with associated access, parking, landscaping, re-grading of land, enclosures, and infrastructure works including two sub-stations and an express vehicle maintenance facility

National Highways Ref: 95564

Referring to the consultation on a planning application dated 20 July 2022 referenced above, in the vicinity of the A23 and A27 Trunk Roads that form part of the Strategic Road Network, notice is hereby given that National Highways’ formal recommendation is that we:

1. c)  recommend that planning permission not be granted for a specified period (see reasons at Annex A);
   
   

Highways Act 1980 Section 175B is not relevant to this application.

This represents National Highways’ formal recommendation and is copied to the Department for Transport as per the terms of our Licence.

Should the Local Planning Authority not propose to determine the application in accordance with this recommendation they are required to consult the Secretary of State for Transport, as set out in the Town and Country Planning (Development Affecting Trunk Roads) Direction 2018, via transportplanning@dft.gov.uk and may not determine the application until the consultation process is complete.

The Local Planning Authority must also copy any consultation under the 2018 Direction to PlanningSE@nationalhighways.co.uk.

Signature: Date: 02 August 2023
Name: Matt Lewis Position: Assistant Spatial Planner

Where relevant, further information will be provided within Annex A.

Annex A

National Highways’ assessment of the proposed development

National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Recommendation

It is recommended that planning permission not be granted for a specified period of 3 months, ending on 02 November 2023.

Reasons

We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN, in this case, particularly within the vicinity of the A23 and A27 near Brighton.

We require further information to be provided by the applicant on this application in order that an informed decision can be made in relation to the potential impacts of the development on the strategic road network. In particular, the following comments should be passed onto the applicant:

Throughout this response ACTION points for the applicant are highlighted in underlined bold.

Transport Assessment

It is noted that an updated Transport Assessment (TA) dated July 2023 (Rev D) and updated Travel Plan (TP) dated July 2023 (Rev C) have been submitted; these documents are referred to as necessary in these comments.

During discussions, mention of a Collection Desk for the public has been mentioned, albeit no confirmation has been given if the proposed development will include this service. This clarification as to what the application fully entails is required.

National and Local Policy

The updated TA contains a summary of the previous National Highways Circular 02/13 at Section 3.2.3. This circular was replaced by National Highways Circular 01/22 on

23 December 2022. The new circular contains updated requirements with regard to the assessment of development impacts on the SRN.

The Policy section of the TA will therefore need to be updated to address the requirements of Circular 01/22, with associated amendments applied to other sections of the TA as appropriate.

Site access

We observe that the proposed access connects directly with the Local Road Network (LRN). The location of the proposed access has now been moved closer the junction with the SRN. Whilst this has been done on the basis of discussions with National Highways, the proposed location has yet to be approved.

As the access is closer to the Patcham Interchange, this will need to be assessed in terms of potential impact on the operation of the SRN junction.

The access also crosses a parcel of land identified as owned by National Highways. Consent to build an access across this land therefore needs to be sought before approval can be granted for its development.

Before carrying out any works within the limits of the SRN highway, the applicant needs to be aware that no works will be permitted on land owned by us without prior consent. All plans of the proposed access should therefore clearly show National Highways’ area of land ownership.

In relation to our land interests, at the appropriate stage of the planning process, we are minded to provide a conditional planning response which requires access construction that follows the approved plan alongside conditions relating to a Construction Management Plan or any other attached planning conditions within the NHPR response.

Personal Injury Accident Data Review

An analysis of the previously requested STATS 19 data is provided at section 2.6 of the new TA report.

However, this should cover the 5-year period prior to March 2020 and the Covid-19 period up to the latest data available (i.e., 2015 onwards).
Further examination of the data is also required, as whilst the spread and severity of incidents is examined, no consideration has been given to the National Highways Planning Response (NHPR 22-12) December 2022 makeup of identified clusters in the data, specifically why it is considered that incidents are clustered in those specific locations.

This is relevant to the outputs and conclusions of the highway capacity modelling exercises, which are discussed below.

Trip Rates and Trip Generation

It has previously been noted by us in our review of the originally submitted TA report that, based on the locations of the Delivery Offices (Dos) in Brighton and Hove that were surveyed to create the stated modal split information, these are situated within the centre of each of their respective conurbations within easy access of sustainable transport alternatives. The proposed site at Patcham Farm is located on the edge of the suburban area and is 0.5 miles from the nearest bus stop.

The implications of this relate to both staff trips and operational trips. Whilst the HGV deliveries to the site would still be using the SRN, the move away from the centre of Brighton could reduce the level

The presented methodology within the updated TA report separately calculates staff trips for the existing distribution centre (which is more centrally located) and the new site (which as noted is less well connected to sustainable mode options). As a majority of existing staff are expected to transfer to the new site, those staff have been asked directly how they would travel to and from the new site (via surveys conducted in March 2022). The survey results indicate car driver/ passenger trips would be expected to nearly 50% of the total, with sustainable modes primarily comprising cycle and bus trips.

We consider that the methodology and associated results are appropriate for the purposes of an initial trip generation exercise for staff for the proposed development. However, there is likely to be some difference between staffs’ intended method of travel (as surveyed in March 2022) and their eventual methods once the proposed new DO is operational. A sensitivity test is therefore required to appraise how vehicle trip numbers would alter if a larger proportion of staff were to travel by car; the assessments within Section 5 of the TA report show forecast staff arrivals and departures by different modes (based on expected shift patterns and the 2022 survey data) but this is not currently compared to the 85 staff car parking spaces which are to be made available as part of the proposed development.

The trip generation sensitivity tests should include the following:

• A test with 70% of staff trips in each shift being car driver trips

• A test where the number of staff car driver trips is adjusted to match the available staff car parking spaces, i.e., resulting a maximum accumulation of 85 staff vehicles

These additional tests will identify any potential for the available car parking to be exceeded by demand, as well as demonstrating the differences between the current staff survey and possible changes associated with staff turnover and other changes in circumstance between the survey date and the opening of the proposed development.

Depending on the outcome of these tests, it may be necessary to apply the revised trip generation calculations to the highway capacity models.

During discussions, mention of a Collection Desk for the public has been mentioned, albeit no confirmation has been given if the proposed development will include this service.

As the facility of a Collection Desk would result in additional trips, confirmation is required that no such facility will be provided or, if a Collection Desk will form part of the site, further trip analysis will be required.

Trip Distribution/ Assignment

Section 6 of the updated TA report contains explanations of the data sources and methodology used to remove existing staff and operational vehicle trips (HGV and “red fleet” vehicles) from the modelled highway networks, and the addition of expected staff and operational vehicle trips to these networks. As has been requested, this analysis now provides the sources of data used to carry out the assignment calculations and the justification for these sources; these are confirmed to comprise active operational data and existing staff postcode data in a majority of cases. Given the purpose of the proposed development (to replace a named existing facility) and the age of more general Census journey to work data, this approach is considered to be appropriate, and the previously identified actions are considered to be complete.

Baseline Traffic Data

The raw traffic survey data (as referenced in section 2.2.5 of the TA) is not present as part of the new TA report; neither does it appear to be included with any of the other documents in the new submission. (The flows are present on the baseline trip diagrams, but as noted this is not sufficient as it does not include measured queue lengths etc).

As previously requested, the raw baseline traffic data must be provided to enable confirmation of the accuracy of the 2021 baseline modelling.

Use of TEMPRO

Details of the TEMPRO calculations referenced in the original TA report were previously requested; these have now been provided as Appendix G of the updated TA. These have been reviewed and are considered acceptable for the purposes of informing the strategic highway capacity modelling exercises.

Committed Developments

Following previous actions requested by us in relation to the assessment of committed development within the wider highway capacity modelling exercises, a list of committed developments is now provided at section 7.3.2.3 of the updated TA report. These are stated as having been supplied by BHCC (although no direct evidence such as an email from BHCC is provided).

The updated TA states that the trip generation relating to these sites has been considered from relevant planning documents and found to be “negligible”, however details of this exercise are not provided.

The applicant should provide a copy of the email or other correspondence with BHCC to confirm the list of committed developments, and full details of the planning documents considered, and the trip generation and trip distribution exercises referenced in reaching the stated conclusion with regard to the assessments in the updated TA report must be provided, before this statement can be accepted.

Assessment Years

As has been noted above, the assessment years for the highway capacity modelling must be compatible with the requirements of Circular 01/22, which have superseded

those previously set out in Circular 02/13. The updated TA presents modelled scenarios for a base year of 2021, and future years of 2026 and 2032. 2026 is stated to be the proposed year of opening (updated from 2024 as proposed in the previous version of the TA report), and 2032 represents 10 years from the application date. The current adopted BHCC City Plans part 1 and 2 are noted to have an end date of 2030. Circular 01/22 only formally requires assessment of the opening year, (as stated at Paragraph 50) so our appraisal will be based on the 2026 models (it is noted that the issues referenced above will require resolution before conclusions can be drawn).

SRN Junction Capacity Assessments

We observe that the updated TA presents junction capacity assessment results for the following SRN junctions:

• A27 Link Road/ Vale Avenue – Junctions 9 PICADY model

• A23 London Road/ A27 Link Road/ Mill Road – Junctions 9 ARCADY model

• A27 Westbound Off-slip/ A27 Link Road/ A27 Overbridge – Junctions 9 ARCADY model

• A27 Eastbound Off-slip/ A27 Overbridge/ Braypool Lane – Junctions 9 ARCADY model

While not forming part of the SRN, we have also considered the model for the proposed site access onto Vale Avenue due to its proximity to the approach to the A23/ A27 Connector Road and the potential for interaction with the SRN.

The following scenarios have been assessed:

• 2021 Baseline – taken from traffic surveys set out in Section 2.2.5

• 2026 Future Baseline – 2021 Baseline with TEMPro traffic growth factors

• 2026 Do Something – 2026 Future Baseline with forecast site vehicle traffic

• 2032 Future Baseline – 2021 Baseline with TEMPro traffic growth factors

• 2032 Do Something – 2032 Future Baseline with forecast site vehicle traffic
  
  

As noted above, it is considered that the 2021 baseline and 2026 models are those which are required for compliance with Circular 01/22, subject to completion of the actions set out previously in relation to the committed developments assumptions.

Furthermore, the applicant has stated that model validation has been undertaken for the A27 Eastbound Off-slip/ Braypool Lane/ A27 Overbridge junction through the comparison of queue lengths illustrated in the ARCADY model with the collected survey footage. However, as no raw survey data has been presented within the submitted TA, we are unable to confirm the accuracy of this validation exercise. This needs to be performed for all junction models submitted as part of the TA.

The applicant is therefore requested to provide evidence of validation for all junction models through the submission of survey queue lengths and comparisons against the outputs of the local junction modelling.

We will additionally require model input files to be provided for all of the listed models, alongside geometry measurement drawings on a suitable map base to demonstrate how the models have been constructed.

Notwithstanding the above, we have undertaken an initial review of the updated models presented in the TA in relation to geometric inputs and model network structure, and the results as presented in the TA report, and have the comments as set out below. Any initial comments made below regarding the results of the modelling may be subject to change pending receipt/ verification of the items referred to above.

Vale Avenue - Proposed Site Access junction

We have noted that the updated model of the proposed site access junction now represents a four-arm arrangement (to include Vale Avenue to the west), as was requested in a previous version of this NHPR form. As such, subject to confirmation of the geometries via a suitable drawing, this is considered to be an acceptable approach.

Based on our initial appraisal, the model geometries appear to accurately represent the current layout of this junction. This will be confirmed via consideration of the requested geometry drawings, which are required to accurately assess the modelling. It should be noted the actual geometric design of the access will be for Brighton & Hove to comment on as the local highway authority as the access is on the local road network.

We note that the junction operates within capacity in all of the modelled scenarios and the results do not suggest that there would be any negative interaction with the assessed SRN junctions.

A27 Link Road/ Vale Avenue

We are unable to replicate the geometry used for this junction model based on the existing junction layout, specifically the carriageway width for the A27 link road and the widths of the Vale Avenue approach. We also note that the left and right visibility distance for the Vale Avenue approach has been taken from the give-way line rather than from 10m behind the give-way line as is normal practice.

The applicant is therefore required to submit drawings/ measurements used to calculate the geometries of this junction model.

Notwithstanding the above, the results of the 2026 and 2032 models indicate that the junction would operate within capacity in all modelled scenarios. (It is noted that the junction operates as a left-in, left-out arrangement and therefore only the Vale Avenue (East) arm has been assessed.

A23 London Road/ A27 Link Road/ Mill Road

Based on our initial appraisal, the model geometries appear to accurately represent the current layout of this junction. This will be confirmed via consideration of the requested geometry drawings.

The results of the 2026 assessments indicate minor changes in delay and RFC values across all arms of the junction in the AM and PM peaks. Some of these changes are small reductions in the “Do Something” models, however for the AM peak A27 Link Road data, the expected queues increase from 85.9 to 87.6 vehicles.

As this arm is already over capacity, a drawing should be provided showing the physical extent of the queues on this arm in both the 2026 Future Baseline and Do Something scenarios This is to enable checking that the additional vehicles will not lead to any issues in terms of sighting of the back of the queue by approaching drivers.

It is noted that a similar situation exists in the 2032 models, with a similar degree of increase in the queue lengths on this arm between the future baseline and do something models.

A27 Link Road/ A27 exit slip west/ A27 entry slip west

We note that the junction arm labelling’s within the model outputs and associated tables have been corrected in response to our comments in a previous version of the NHPR.

Based on our initial appraisal, the model geometries appear to accurately represent the current layout of this junction. This will be confirmed via consideration of the requested geometry drawings.

The results of the models for 2026 and 2032 indicate that there will be minimal change between the future baseline and do something scenarios as a result of the proposed development.

It is noted that the results for the PM peak 2032 future baseline and do something models are identical, these models should be checked to confirm that this is in fact the case, and any updates made to the submitted model files and TA tables as necessary.

Braypool Lane/ A27 Off-slip/ A27 Overbridge

We note that the junction arm labelling’s within the model outputs and associated tables have been added in response to our comments in a previous version of the NHPR.

Based on our initial appraisal, the model geometries appear to accurately represent the current layout of this junction. This will be confirmed via consideration of the requested geometry drawings.

The results of the models for 2026 and 2032 indicate that there will be minimal change between the future baseline and do something scenarios as a result of the proposed development.

It is noted that the results for the PM peak 2026 and 2032 future baseline and do something models are identical, these models should be checked to confirm that this is in fact the case, and any updates made to the submitted model files and TA tables as necessary.


Boundary treatment, geotechnic and drainage

The edge of the carriageway is being separated from the site boundary by mature hedging and trees, the majority of which are located within the limits of the SRN highway. The applicant is proposing to plant native species within their boundary in the vicinity of the proposed palisade fencing.

The applicant needs to demonstrate by means of a topographical survey to OS datum that at no point along the length of the palisade fencing does it encroach within the highway boundary.

Observations made from the section drawing no. BDO-HLM-00-ZZ-DR-A-00200 Rev G appear to indicate that both the A27 carriageway and the road link to that joins the A27 with London Road are lower than the site.

There have also been local concerns raised regarding the geology of the site, and the potential impact the development could have on affecting nearby roads, including the SRN.

The applicant needs to demonstrate by means of a survey that the proposed development would have no detrimental impact on the nearby SRN.

The indicative drainage masterplan included in the Appendix D of Flood Risk Assessment dated in July 2022, indicates that the run-off of the site is proposed to be discharged into a combined Southern Water pipe under Vale Avenue to the south of the site entrance. However, the highway drainage records included in Figure 2.2

́Highway drainage ́ of the FRA appears to show a connection from the existing site to the highway drainage.

It is illegal to carry out works within the public highway without having first undertaken/ completed all required legal agreements with us (or other relevant highway authorities), nor is it permissible to discharge surface water on to or over the public highway.

The applicant is required to undertake a CCTV survey to further investigate the possible connection to the existing highway drainage and to ensure that no runoff from the site is discharging to the highway drainage system.

No outfall connection to any existing highway drainage system(s) is permitted.

Since our previous response, investigations to accommodate the hazel dormice which have been identified on site have taken place.

The applicant should look to avoid translocating the dormice as much as possible and confirmation that no translocation onto National Highways land will occur.

The above represents our current requirements. As the analysis progresses, it is possible that further requirements may emerge.

Conclusion

Given the above, it is currently not possible to determine whether the application would have an unacceptable impact on the safety, reliability and/ or operational efficiency of the SRN (the tests set out in DfT Circular 01/2022 and MHCLG NPPF2021 [particularly paras 110 to 113]). This response details the steps that need to be taken in order to resolve this issue.

In light of the above, National Highways currently recommends that planning permission not be granted (other than a refusal if the Council so wishes) for a period of three months from the date of this response (until 02 November 2023) to allow the applicant to resolve the outstanding matters.

This recommendation can be replaced, renewed, or reviewed during the three-month period, or at its end, dependent on progress made with regards to the outstanding matters.

Standing advice to the local planning authority

The Climate Change Committee’s 2022 Report to Parliament notes that for the UK to achieve net zero carbon status by 2050, action is needed to support a modal shift away from car travel. The NPPF supports this position, with paragraphs 73 and 105 prescribing that significant development should offer a genuine choice of transport modes, while paragraphs 104 and 110 advise that appropriate opportunities to promote walking, cycling and public transport should be taken up.

Moreover, the build clever and build efficiently criteria as set out in clause 6.1.4 of PAS2080 promote the use of low carbon materials and products, innovative design solutions and construction methods to minimise resource consumption.

These considerations should be weighed alongside any relevant Local Plan policies to ensure that planning decisions are in line with the necessary transition to net zero carbon.