Planning – Application Comments

Consultation Date: Mon 23 Sep 2024

Consultation Date: Mon 23 Sep 2024

Consultation Date: Mon 23 Sep 2024

Comment Date: Thu 17 Oct 2024

2400628FUL Land Adj. Millstones Hotel.pdf

Comment Date: Mon 14 Oct 2024

Land Adj Millstones EDG24.001.FRSR-039.pdf

Comment Date: Mon 07 Oct 2024

No Comments

Comment Date: Fri 04 Oct 2024

Plymouth City Council
Strategic Planning & Infrastructure

Transport Planning Team
Ext: 01752 307813
Date: 4th October 2024
Macauley Potter
Development Management
Strategic Planning & Infrastructure
Floor 2
Ballard House

Dear Macauley

Highway Authority Consultation Response to a Planning Application


APPLICATION NO: 24/01173/FUL

SITE: LAND ADJACENT TO MILLSTONES, TAVISTOCK ROAD, PLYMOUTH

DEVELOPMENT: Erection of one dwelling (re-submission of 24/00628/FUL)


Observations:

The response from the LHA to this application is going to be consistent with comments raised in respect of previous applications submitted for the erection of a dwelling on this site, the most recent being application no 24/00628/FUL. There are several different elements to this application which I would wish to comment upon as follows:

On-Site Turning Provision
The LHA have reviewed the tracking plans produced by the applicant and have since undertaken their own assessment of the on-site turning using vehicle tracking in AUTOCAD. This has revealed that there is insufficient space for a 5m long standard-sized vehicle to turn using a 3-point manoeuvre and that in order to turn around some back and forth movements would be necessary. Furthermore, the tracking assessment has shown that there would be insufficient space within the site to provide space for 2 vehicles to park if turning provision was to be retained.

The applicant has stated that they have provided a turning area which accords with the dimensions of a private turning area as shown in the DCC Design Guide. However, this is clearly not the case as the 16.5m length of the turning area should be measured from the back edge of footway/verge yet the applicant's measurement of 16.6m is shown to start from the edge of the carriageway (including the 2m footway width) which is not correct. If the 16.5m measurement is taken from the correct position at back of the existing footway, this amendments has the effect of moving the turning area back into the site by a further 2m (which impacts upon the location of the dwelling).

Furthermore Manual for Streets states the minimum distance required to manoeuvre into/from a 2.4m wide parking space at 90 degrees is 6m (this can also be determined from the above-mentioned plan included in the Devon Design Guide). Unfortunately, in this case providing a 6m distance to the rear of the space is impossible to achieve without taking land from the adjoining site located to the south.

On the basis of the above it is the view of the LHA that insufficient space is provided within the site which would allow a vehicle to turn around and enter the adopted highway in a forward gear. In addition, providing turning provision (al be it sub-standard) would also mean that only 1 off-street car parking space could be provided to serve the dwelling. This falls below the 2 spaces required by applying the indicative parking standards as outlined in the JLP SPD.

Reduction of Footpath Width
Even though the dimensions of the on-site turning area are below the required dimensions, the applicant has had to reduce the width of the adopted footway which runs along the northern boundary of the site by almost half in order to provide further space to allow turning to take place on-site.

The LHA fundamentally object to any narrowing of the existing pedestrian route which would necessitate an extinguishment of highway under Section 247 of the Town and Country Planning Act. Unfortunately, the applicant is incorrect in that stating that this is a matter which could be addressed following the determination of this application. In order for the S.247 extinguishment to proceed, planning permission would have to be granted which would include the LHA clearly stating that they have no in-principle objections to the extinguishment of HMPE. That is not the case in this instance and as such the LHA would not be willing to support the extinguishment. Clearly maintaining the existing width of the pedestrian pathway diminishes the amount of space for turning on-site even further.

Impact upon Highway Improvement Scheme (WTTG)
Having overlaid the most recent version of the WTTG Highway Improvement Scheme Plan over the Layout Plan submitted for this application, it can be demonstrated that a large part of the front driveway/turning area will be required as land considered necessary to deliver the said improvement scheme (over half of the area). Therefore, permitting this development could compromise the delivery of a strategically important highway improvement scheme which is required in order to unlock further development opportunity along the Northern Corridor.

Additional Traffic Movements giving Rise to Highway Safety Concerns
As outlined in the response of the LHA to the previous application, there is a concern that with there being no physical measures (in the form of a central reservation) in place on the A386 to deny them, there is the increased likelihood of vehicles of occupiers of the dwelling right turning into and out of the site from Tavistock Road. This would undoubtedly give rise to increased queuing on the A386 whilst vehicles right-turning into the development wait for gaps in on-coming traffic (which would be minimal in peak traffic hours due to the high volumes of traffic that use the A386). Such movements would therefore be detrimental to highway capacity and be likely to give rise to safety concerns.

Although the applicant states that there is an existing central island on the A386 that would prevent such movements from taking place, it does not extend fully across the proposed entrance into the site. Therefore, whilst right turn movements out of the site onto the A386 would be more difficult, the existing island would not prevent right turn movements being made into the site (it's highly likely most movements would be to and from the south towards the City as opposed to the north).

On the basis of the comments made above, the LHA would wish to repeat the recommendation made in respect of previous applications received, that being one of refusal on the basis of the following reasons stated below.

Recommendation:

The Highway Authority recommends that planning permission should be refused for the following reasons:-

Additional Traffic Movements giving rise to Highway Safety Concerns
The development hereby proposed is likely to lead to an increase in the number of vehicular movements taking place at and in the vicinity of the application site. The Local Planning Authority considers that the increase in vehicular movements arising from the development would give rise to conditions likely to cause:
(a) Prejudice to public safety;
(b) Interference with the free flow of traffic on the highway;
(c) Unwarranted hazard to vehicular traffic
which would be contrary to Policy DEV29 of the Plymouth and South West Devon JLP (March 2019) and Paragraphs 108-110 of the NPPF Feb 2019.

Prejudice to Highway Improvement Scheme
The proposed development encroaches onto land identified for the future widening of the A386 as part of the Woolwell to The George Highway Improvement Scheme which is required in order to bring forward capacity and safety improvements on the local road network. The development is therefore contrary to Policy DEV29 of the adopted Plymouth and South West Devon Joint Local Plan adopted March 2019 and paragraph 109 of the NPPF.


Scott Smy
Transport Development Coordinator

Officer authorised to sign on behalf of the Service
Director for Strategic Planning & Infrastructure

Comment Date: Tue 01 Oct 2024

952920 Consultation Response 2.pdf