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Responses to Land Allocations - Examination Stage - Updated Main Modifications
Response from Mr & Mrs Edward Craker (Individual)
1. Mr & Mrs Edward Craker (Individual)   :   8 May 2013 15:38:00
Please add your response below, quoting the main modification reference number: (limit 3000 words)
5th May, 2013.
SLDC LDF DPD

SUBMISSION TO THE INSPECTOR
Consultation on the Updated Schedule of Main Modifications to the DPD.

Submission by E.W.Craker.

1. General point regarding submissions.

Although my main interest is in the proposals for Quarry Lane, Storth, this point is relevant to all the SLDC Planning area.

Submissions have been invited by an email from Mr D Hudson dated 5th April.
That email states that “Comments must only relate to the published updated Schedule of Main Modification (Quoting the main modification reference number)”.

There are of course other recently published documents, e.g. the AECOM highway Study and the HDH Viability Assessment.

It is only because of correspondence with Mr Hudson and Mr McNeill that I am aware that comment may be made on these new documents.

Others are therefore not likely to be aware, and thus effectively have been denied the opportunity to comment.

This is not as it should be, and is not in the spirit or interest of democracy or open government.

2. Comments on the March 2013 AECOM Highway Study.

This includes 4 options for access to M683sM-mod

As a general comment on the Study, the AECOM unit cost figures seem very low. By their own admission, they are taken straight from a textbook, and make no allowance for the fact that the underlying strata is rock (therefore very high excavation costs) and that most of the necessary highway works are immediately adjacent to a deep and almost vertically sided railway cutting.

Option A. (Road in thro’ Travis Perkins yard).
On its own this only gives access to EN 40. Other than to emphasis my general point above regarding optimistic costings, I make no further comment at this stage.

Option B. (Access to M683sM-mod from Storth Road.
AECOM make no allowance for upgrading the existing (unadopted) road between Storth Road and the entrance to the site, a distance of some 60 metres.
CCC (Mr McGeough, at a site meeting on 12th November 2012 said that the minimum acceptable would be a 6m carriageway and two 1.8m footways, i.e. a total of 9.6m.
Quarry lane is only 5.8m wide at best, and is constrained by private land on one side (my garden for the major part of the length) and the almost vertically sided railway cutting on the other. Even using AECOM’s optimistic rates for new carriageway, that would be an additional cost of £78,000 plus very significant extra costs to deal with the railway cutting.
Also, there is no allowance for providing the necessary visibility sight lines at the Storth Road/Quarry Lane junction. CCC require 2.4m x 45m.
This is not achievable without major alterations to the existing bridge and its parapet (Owned by BR). 2m extra width would be required, and using AECOM’s figures, 25m (the bridge is on a skew) x 2m x £3000 = £150,000.
In addition the southward visibility problem remains, for which land purchase would be required.
Therefore the total cost would be £83,952 + (£78,000 + £150,0000)1.44 = £412,272 plus land purchase, which is unlikely to be achievable.

Option C (New bridge from Dallam Drive)
AECOM admit that (even at their optimistic figures) this is not feasible.
Therefore I make no further comment at this stage, other than to say there would almost certainly be numerous objections from Dallam Drive.

Option D (Widening of Quarry Lane in conjunction with Option A)
AECOM make no allowance for the significant probability of contaminated land (part of the site was an oil distribution dept – an oil storage tank and fuel delivery pump are clearly visible.
Again, there is no allowance for the proximity of the almost vertically sided railway cutting.

3. HDH Viability Assessment.

The calculations in this document for M683sM-mod are based on 42 units. This is 11 units (an increase of 35%) more than SLDC have proposed up to now!
Also, the calculations are based on the AECOM estimated figures for the necessary highway improvements. As I have shown above, these are very optimistic.
The HDH Viability Assessment for site M683sM-mod is based on erroneous information (cost of highway works, number of units and purchase of private land) and is therefore seriously flawed.

4. Conclusion.

• SLDC have (as at 5th May) not replied to questions I put to them in an email on 1st April (and have sent reminders since) therefore I have possibly been denied the opportunity to make a full and fully reasoned response.
• The existence of the growing evidence base, particularly the Highway Study and the Viability Study has not been made aware to the general public. Indeed the email from SLDC of 5th April inviting comments strongly steers potential consultees away from these key documents. This is wrong, and is not in the interests of democracy and open government.
• The Highway Study, whilst thorough in its selection of alternative accesses for the Quarry Lane sites is highly optimistic in its costings ad assumptions.
• The Viability Study is largely based on the highly optimistic highway figures. Additionally, it is based on 42 units, 35% more than the 31 units used up to now.
• If this site (M683sM-mod) were to make its way into the adopted plan, it is highly unlikely that it would be taken up. This would not serve the planning process well.
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