Transport Solutions for Lancaster and Morecambe (TSLM)

Reference: LCC Planning Application 01/05/1584

Report on LCC Response to Objections and Comments - June 2006

2.0 Executive Summary

• 2.1 Generally, TSLM has grave concerns about the many cases where -
  Investigations have not been carried out
  Reports have not been produced
  Objections have not been resolved
  Concerns have not even been considered
   
• 2.2 Ramblers Association objected to the proposal on landscape grounds and diversions to public footpaths, finding it destructive of the low coastal drumlin landscape. The response merely refers to false cuttings and planting, and treats the footpath issue as insignificant. LCC’s own Specialist Adviser points out that the Structure Plan, which makes recommendations on that type of landscape, has been ignored, both in the Planning Application and response document.
   
• 2.3 Sport England observed that, firstly, planning guidance requires a needs assessment, and secondly, the proposal could only be acceptable if comparable or better sports fields were offered. LCC ignores both points, and merely suggests new layouts for pitches on the residual land, only one of which would be full-size. No effort to mitigate loss of playing fields is shown and no attempt to source additional space in the locality is made.
   
• 2.4 Environment Agency (EA) objected on several grounds. Objections to the design of the River Lune Bridge were made, but the LCC redesign has not satisfied EA. The piers now create a concrete barrier in the bank corridor, which was previously an uninterrupted section for wildlife. EA requested compensation for the loss of watercourses, their habitats, and the loss of species-rich meadows. LCC has failed to provide any mitigation for this.
   
• 2.5 LCC’s assessment of the impact of lighting on the Lune corridor only serves to confirm EA’s fears that artificial lighting adversely affects plant & animal diurnal rhythms in the environmentally sensitive river area. Ground contamination has not yet been investigated and EA, as statutory consultee, has not been consulted. A Flood Risk Assessment (required under PPG25) for the Coastal Flood Plain in Zone 3 has not been produced at all.
   
• 2.6 English Heritage asked that the section of the Environmental Statement on cultural heritage should be improved, both in the grading of impacts and proposals for mitigation. Oxford Archaeology North, the original consultant, is meant to be producing reformatted cultural heritage information, but this has not yet been submitted. The requested information on surface treatments to bridges and retaining walls received incomplete explanations.
   
• 2.7 British Waterways has concerns for the Lancaster Canal Biological Heritage Site (BHS), whereby some issues have not been explored properly, especially those relating to the visual intrusion, noise and disturbance to canal users, direct shading of plant life by the bridge, and most importantly the potential for drainage systems to contaminate the canal.
• 2.8 Halton with Aughton Parish Council raised a number of concerns that affect residents at the eastern edge of the proposal. Inaccuracy of traffic figures and the lack of public consultation in the Halton area were of particular concern. Dramatic reductions of traffic in Halton village have been predicted, despite the inherent failings of the local traffic model and the tendency for east-bound traffic to avoid the convoluted bridge route and use the village as a short-cut.
   
• 2.9 Access to McDonalds, Morecambe Road School and Hadrian Road residential area has been redesigned with an additional set of traffic lights. This means three sets of traffic lights, close together, which will slow traffic and adversely affect both the predicted journey times and the cost benefit calculations. It fails to provide adequate solutions at this point. Coupled to other modifications in the response, the economic justification for the scheme must be recalculated.
• 2.10 Lancaster and Morecambe College was particularly concerned for the loss of playing fields, as it reduces its ability to provide sports related education. LCC merely suggests an alternative layout and does not address the issue. Loss of 180 car-parking places without mitigation will create chaos in surrounding residential areas, but LCC merely says that no additional land has been identified to accommodate the needs of the College. Noise has a serious and devastating impact, but the LCC response is ineffectual.
   
• 2.11 Many letters of objection were received by LCC from the Torrisholme Road and Russell Drive areas. These are held at LCC Development Control offices. LCC Highways, as the applicant, notes "Without copies of the actual letters of objection it is not possible to make any constructive comments." TSLM believes that LCC Highways, the applicant, was neglectful in failing to read the letters and respond to the concerns raised.
   
• 2.12 Additional land purchases at Junction 34 of the M6 will increase the cost of the scheme quite dramatically. Concerns expressed by United Utilities may mean substantial deviations for some essential services, which are additional significant expenses. The convoluted highway design also brings into question the forecast time saving. When set against the speculative regeneration benefits there is great cause for concern that financial ratios are incorrect. The response fails to consider a range of design possibilities for Junction 34.
   
• 2.13 Comments from LCC Development Control support the concerns expressed regarding the access arrangements for McDonalds’ customers, Hadrian Road residents and Morecambe Road School. LCC Highways’ solution, to merge all three traffic flows, is inappropriate for this busy section of road. Development Control also expressed concerns over the extreme heights in the Railway/Canal area, where a “false drumlin” is proposed. These concerns are ignored.
   
• 2.14 Increased levels of noise are a major concern, particularly at Torrisholme Road, Russell Drive and Endsleigh Grove. The calculations show a dramatic increase in noise levels, yet any reduction caused by the proposed mitigation of noise barriers is slight. Removing the level of mounding behind Endsleigh Grove merely worsens the noise and visual impact of the road. There is a general failure to provide adequate data, with the calculations that are presented with respect to noise appearing speculative at best.
   
• 2.15 Drainage issues at the A6 junction are not addressed, which could have severe environmental consequences due to inadequate provision for surface run-off. Concerns over the extreme size of the Beaumont junction, and the safety issues arising from it, are not adequately dealt with. Similarly, drainage at Shefferlands Roundabout and Shefferlands Retaining Wall are causes for concern, due to potential polluted run-off flowing into a single pond with no overspill capacity.
• 2.16 Statutory guidance on Green Belt, agricultural landscape and townscape is still ignored by this scheme, and the response fails to consider fully the visual impacts of the road. Development Control's concerns on biodiversity are largely ignored. There is little protection offered for principle species, and poor ecological value of replacement areas. The Structure Plan demands that there should be no net loss of ecological resource, but the response fails to comply.
   
• 2.17 The measures to replace mature and veteran trees and hedgerows are inadequate, as are the measures to protect bats. To answer concerns over rare fungi at Valley Meadow and Howgill Brook Meadow, no further mitigation is proposed; for Powder House Lane field, no mitigation is proposed at all. The LCC Specialist Adviser expresses many concerns about ponds and watercourses, but no further mitigation is proposed. Similarly, two species of bryophytes (mosses) will be completely destroyed without any thought of mitigation for BHS species.
• 2.18 We question the method of assessing great crested newts, as does the LCC Specialist Adviser, who notes that only one type of assessment was used, despite the recommendation that refuge sites be checked up to 500 metres away. The Specialist Ecology Adviser also expressed great concern on 23 items in the Environmental Management Plan. These have not been answered.
   
• 2.19 Many other questions and criticisms have not been answered despite substantial data provided at the MSBC stage of the scheme, one of which is the uncertainty about the exact planning status of the scheme in the Local Plan. There are major concerns about the failure to comply with, or support, policies at national, regional, district and local level. The scheme contravenes many other government policies, such as promoting health and well-being.
   
• 2.20 Many key regional policies, such as promoting freight by rail to Heysham port, or making best use of existing infrastructure, are completely ignored. TSLM believe that substantial areas of concern remain unresolved and that LCC are progressing the scheme without due thought and attention to the issues.

Download the full TSLM Response Document here

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