Wednesday, 6 November 2019

Transport Assessments & HGVs: How consultants create an alternative reality

We’ve previously posted about how parts of Aggregate Industries' application to quarry Straitgate Farm have been a catalogue of fiction. We said:
It all makes this multinational and its consultants look like a bunch of cowboys, willing to say whatever it takes. It begs another question: If AI can’t act honestly before winning any keys to dig, what hope would there be afterwards?
Amazingly, Aggregate Industries is on its third Transport Assessment to support this proposal – and its third set of traffic consultants. The first Transport Assessment was from SLR in 2015, when the plan was to haul material to Blackhill. The second was from David Mason Associates in 2016. The third – the current one – is by Horizon Consulting Engineers. This last one, written in 2018 and still being updated this year, is (at least with the copy we have) already at Revision E.

These documents are supposed to be "thorough assessments of the transport implications of development", and yet each one from Aggregate Industries has played with the truth – the latest being no exception.


David Mason, produced more fiction – and was later ditched by the company. His traffic numbers for the B3174 bore no relation to reality. Highways England counts two months earlier showed almost 60% more traffic – numbers subsequently borne out by Horizon.

You won’t find the third Transport Assessment on Devon County Council’s planning website. It has only been sent to us after we made a Freedom of Information request.

How much better will this one be? First indications don’t bode well. On the matter of highway safety, Horizon claims for the "three year period" until the end of 2016:
6.3.1 Three accidents have occurred within the study period of which only one occurred at the junction which is the subject of improvement works. None of the accidents involved an HGV
It's not true. This accident happened on Monday 4 April 2016 – within a stone’s throw of Straitgate – on the relevant stretch of the B3174 Exeter Road that Aggregate Industries propose to use:


Fortunately no-one was injured, but police closed the road for the best part of a day.

If Horizon can overlook this sort of accident, what else can it overlook?

Perhaps, in an effort to be thorough, and given that this application will not now be determined before 2020, we should look at these accidents too – both involving an HGV, both in 2019, both involving police, and both a matter of yards from Straitgate Farm.



Another lorry in the ditch outside Straitgate


As these photos evidence, the B3174 Exeter Road is not as safe as Horizon makes out.

Devon County Council is aware of the accidents on this stretch. Earlier this year, in connection to the Straitgate proposal, the Council’s Neighbourhood Highways Officer advised of "HGVs going into unlined ditches" between Daisymount and Birdcage Lane.

And what – with plans to put another 200 HGV movements a day on this road – was the advice to the case officer responsible for the Straitgate application from the Council's highways planning department?
I really don’t know if this changes anything or not !
Why are so many trucks coming off this road? It's quite simple – but again it's not something that's been discussed in the Transport Assessment.

Consider that HGVs are 3.0m wide or more, including wing mirrors.


According to Horizon itself, the B3174 Exeter Road is as little as 5.3m wide. In other words, in places, the road is too narrow by as much as 70cm for two HGVs to pass each other with no room to spare. Consider also, with the speed limit of the B3174 Exeter Road at 60mph, how little margin for error there is, with vehicles approaching each other at speeds of up to 120mph.

You might have thought this would have rung warnings bells – given that the Straitgate proposal could generate in addition as many as "216 HGV trips per day" – but no. Firmly in alternative reality mode, Horizon says "the proposed development complies with policy M22: Transportation and Access of the Devon Minerals Plan 2011 - 2033", or in other words this the proposal "would not have a significant effect on: (a) road safety".

But Horizon’s grasp of M22 is tenuous, and not just on the safety front.

Because despite showing a map of the proposed haul route, Horizon fails to assess the distances involved. Horizon fails to say that each load would need to be transported 23 miles for processing. Horizon fails to say that there would be more than 105,000 such movements, and even more if, as Horizon says, we were "to account for the use of HGV’s with a lower load capacity". Horizon fails to say that this would amount to some 2.5 million miles, or perhaps even more with smaller loads.

Clearly, in trying to paint a rose-tinted vision of Aggregate Industries' HGVs criss-crossing Devon, Horizon does not provide "thorough assessments of the transport implications of development", and clearly the proposal does not comply with Minerals Plan policy M22, given that the same policy says:
mineral development should minimise the distance that minerals are transported