THE A2/A28 “BELLMOUTH” JUNCTION AT THANINGTON

PROPOSED ALTERATION: SAFETY ISSUES

Submission to Rosie Duffield MP

December 2018

Prepared for the Wincheap Society, Canterbury, by Gillian Bull

gillianbull766@btinternet.com

�1 December 2018

Purpose of Report

We submit this Report and its accompanying Appendix to the Rt. Hon. Rosie Duffield, MP for Canterbury, and request that she use it to bring to the attention of the Minister for Transport a failure by Highways England, together with Kent County Council Highways and Transport Department and Canterbury City Council, to acknowledge the concerns expressed by the residents of the Wincheap Ward in Canterbury over the hazardous nature of plans for road construction and alteration at the junction of the A2 and A28 on the west side of Canterbury.

The Report focusses on one particular unsafe area - the “bellmouth” junction of the A2 north bound off-slip with the A28 where, by construction of a contra-flow system, a sharp 45 degree left turn is proposed over a sheer drop to the A2 carriageway below. In our opinion plans for road construction and alteration in the WIncheap Ward propose several traffic and pedestrian hazards, but this is the most dangerous.

For reasons that we hope are made clear in this Report and the supporting evidence in the Appendix, there has been a systemic failure of the checks and balances that should operate to hold councils and government agencies accountable to their residents. After four years of effort, including a Notification of Breach of Duty of Care to Highways England and the two Councils, there seems to be nothing more that Canterbury residents can do but appeal to the Minister to look into this matter. Wincheap Ward is one of the two poorest in Canterbury, and the residents cannot afford to take this matter to Judicial Review.

Summary

Part 1 of this Report provides an introductory outline, showing where the junction area lies within Thanington, that the difficulty of accessing what is now known as the “Thanington Park” development area was a main reason for rejecting planning applications in the past, and that in 2014, and subsequently, planning applications have been approved. Highways England’s and KCC’s Highways’s determination to construct a 4th east bound slip road to exit the A2 at Wincheap, and Canterbury City Council’s using developers’ speculative proposals at Thanington to satisfy the requirements of the Local Plan, now override all other considerations including residents safety and well-being.

Part 2 of this Report comprises illustrations of the current problematic turnings at the A2/A28 junction and along the A28 (Wincheap) to the east, in order to contextualise Pentland Properties Ltd’s (the developer) plans for alterations to the A2/A28 north-bound slip road.

Part 3 of this Report follows the development of Pentland’s presentation of plans for the altered slip road, including plans produced by their agents, including Peter Brett Associates, with extracts from documents and correspondence produced by the developer, local residents and their councillors, officers of Highways England, Kent County Council and Canterbury City Council. There is some commentary on these.

Part 4 of this Report sets out our concerns specific to the swept path analyses used by Pentland’s agents to justify the feasibility of traffic using the bellmouth junction, together with some data on the very long vehicles now being trialled on roads in England, Wales and Scotland (but not Northern Ireland) and their impact on the road system.

The Appendix document provides extensive documentary evidence to substantiate the claims made in this Report and identifies links to other sources.

�2 December 2018

MAIN REPORT

Contents

1. Introductory outline

1.1 Thanington in relation to the A2 and A281.2 Applications to develop land north and south of Cockering Road1.3 Access 1.4 Why the policy volte face?1.5 The Decisions See-saw1.6 Deleterious effect on Applications procedures

2. “Bellmouth” Junction Safety Issues: illustrated

2.1 Junctions at the A2/A28 intersection2.2 The “bellmouth” junction now2.3 Proposed alteration to bellmouth junction2.4 Concerns with the proposed alterations: traffic safety2.5 Current problematic turnings on the A28 Wincheap

• Turning 90 degrees right from the north bound off-slip.. • Turning 90 degrees left from Simmonds Road at the Maidens Head junction • Turning left 90 degrees into Homersham

2.6 Concerns with the proposed alterations: pedestrian safety2.7 Increased heavy traffic using the junction

3. Highways England Kent County Council and Canterbury City Council and their responses

3.1 Pre-“Thanington Park” Application3.2 “Thanington Park” Application3.3 The s.106 Agreement, CCC’s Decision Conditions, and HE’s Annex A Conditions3.4 Thanington residents’ concerns over PPL’s/PBA’s plans3.5 Quinn Estates Ltd’s Application CA/17/005193.6 Wincheap Society’s Reports3.7 The Notification of Breach of Duty of Care3.8 Highways England, CCC and HGVs on the contra-flow3.9 The missing safety audits

4. Swept path analyses’ relationship to physical reality at the A28, plus information on LSTs (longer semi-trailers)

4.1 Issues with swept path analyses4.2 The swept path analyses of the bellmouth junction4.3 Longer semi-trailers (LSTs): press coverage and DfT releases.

Separate document: APPENDIX: SOURCES AND DOCUMENTS

Contents

1. “Bellmouth” Junction Events Timetable2. Chronological Listing of Extracts from Documents Relating to the Proposed Alteration to the “Bellmouth” Junction3. List of Canterbury City Council Planning Applications relevant to the Thanington Development Sites

�3 December 2018

1. Introductory Outline:

1.1 Thanington in relation to the A2 and A28

This north/south overview is of part of the Parish of Thanington Without. The Parish is situated on the west side of Canterbury, and south-west of the A2 - the major road running south-east to north west - and the A28 between Canterbury and Ashford - the lesser road running east-west at the top of the overview.

Between the A28 and the green fields to the west of the A2 lies the Thanington estate, which is bounded on the south side by a lane, Cockering Road, and bisected by two roads running north-south between Cockering Road and the A28. To the west, St Nicholas Road, which was built as an estate road; to the east, Strangers Lane, which was and is a lane.

Construction in the late 1970s of the deep chasm that is the A2 at Wincheap resulted in making the Thanington estate Canterbury’s very own small, sink estate. No other suburb of Canterbury is so brutally socially and physically separated from the city centre, with no shops, school or surgery, few amenities and a risible bus service. The 1980s in particular witnessed high levels of crime on the estate, public services refusing to go there, and a stand-off with the police earning it the name “little Beirut”.

All travellers between the major part of Canterbury lying to the east of the A2 and those parts of Thanington Without that border the A28, whether on foot, bicycle or motor vehicle, must cross the A28 bridge over the A2. Children attending the Wincheap Primary School (visible on the extreme right of this overview) and who are not driven there, are shepherded across the A2 twice a day by family members or carers. There is no alternative route south of the River Stour, and north of it only a bicycle and pedestrian path which is reached by two inconvenient crossings via footbridges.

Pedestrians crossing the A2 on the south side of the A28 must negotiate the A2 north-bound off-slip at the “bellmouth” junction, and the A2 coast-bound on-slip. Those crossing on the north side of the A28 must negotiate the mouth of the A2 north-bound on-slip, and a complex set of crossings over Ten Perch Road that provides access to and from the Wincheap Retail Park (just visible at the top of this overview).

�4 December 2018

Thanington remains a place unnoticed by most other Canterbury residents, even when driving through it on the A28, and ignored by the main political party in power as irrelevant. At the Canterbury South county district level there are too few residents on the estate to make a difference (even when they vote, which they seldom do), and at the city Wincheap Ward level the two councillors are LibDems. Social invisibility and political irrelevance form a backdrop to recent events concerning proposed infrastructure changes.

1.2 Applications to develop land north and south of Cockering Road

In the decades prior to 2014 several Applications were made to Canterbury City Council to develop the green fields south of Cockering Road. All were refused because of - among other issues, but primarily - the difficulty and unsuitability of vehicles accessing any development via Cockering Road and the two estate roads. In 2014 this was policy was suddenly to change.

• The green fields to the west of the A2 and south of Cockering Road are subject to a Planning Consent granted by Canterbury City Council to Pentland Properties Ltd to build a development of 750 dwellings, a school, a hospice and some commercial premises: “Thanington Park”. Date of Application: 3 July 2015; Consent granted: 13 July 2016.

• To the west of the Thanington estate, north of Cockering Road and south of the A28, Canterbury City Council has granted outline Planning Consent to Quinn Estates Ltd to build 400 dwellings: “Thanington Farm”. Date of Application: 3 October 2017; Consent granted: 12 November 2018.

• On the south side of Cockering Road, adjacent to the few houses already built there, and on the short stretch of that lane that will not border either Thanington Park or Thanington Farm, Canterbury City Council has granted Planning Consent to Frontier Estates Ltd to construct a care home. Date of Application: 7 March 2018; Consent granted: 29 June 2018.

1.3 Access

Kent County Council Highways and Transportation and Canterbury City Council Planning Department have agreed that the Quinn and Frontier developments can be accessed from the east via the A28, the two estate roads and Cockering Road. The Quinn development will also be accessed from the west via new road that will bisect the development and with Milton Manor Road.

Regarding the Pentland Application Highways England, Kent County Council Highways and Transportation and Canterbury City Council Planning Department have accepted Pentland’s plan to provide a new point of access to “Thanington Park” from the A2 north-bound off-slip, which is to become a contra-flow system from the bellmouth junction to a 90 degree turnoff into the development. When work on this alteration has been completed ownership of, and responsibility for, land affected under and around the the current slip road will be transferred from Highways England to Kent County Council.

It is with the proposed alteration to the north-bound slip road that this Report is concerned. Our concern is that this proposed alteration will be dangerous for both pedestrians and vehicles. We are bewildered that our attempts to raise this issue of road safety with Highways England, Kent County Council and Canterbury City Council have been ignored, or dismissed, or rubbished.

1.4 Why the policy volte face?

November 2014Canterbury City Council’s draft Local Plan was submitted to the independent planning inspector. At about the same time that discussions were opened with Pentland and Quinn concerning their proposed developments of 1150 dwellings at Thanington, Canterbury City Council was endeavouring to find sufficient numbers of houses to satisfy the inspector, At this time “Mountfield Park” to the south of Canterbury had been included in the draft Plan, but the Thanington developments were not.

�5 December 2018

13 July 2016 The Pentland Application received Consent. Kent County Council and Canterbury City Council had agreed with Pentland that Pentland’s mitigation would include a contribution to a 4th A2/A28 coast-bound slip road, either of money or of construction work. The Conditions of the Consent and of the s.106 Agreement into which these three parties had entered on 6 July 2016 set out the terms (including a timetable) of this obligation. The Consent and the s.106 contained references to access arrangements to “Thanington Park” from an altered A2 north-bound slip road, which was to be completed prior to a specified number of dwellings being completed (see below). Highways England provided an Annex A to the Consent Conditions, containing an additional Commencement formulae for work on the alterations to the north bound slip road.

April 2017 Kent County Council Decision No 17/00025, Matthew Balfour, the Cabinet Member for Environment & Transport (a A2/A28 4th slip road plan was attached). This Decision concerned the construction of a 4th slip road at the A2/A28 junction, to be a coast-bound off-slip, Kent County Council having secured that £4.4m Local Growth Fund had been provisionally allocated to the project. Kent County Council and Canterbury City Council required additional Pentland funding to enable the project to be commenced.

June 2017 Canterbury District Local Plan cleared for Adoption. after some to’ing and fro’ing with the inspector, the introduction of 1150 additional housing sites at Thanington south of the A28 in Canterbury were included, although at this date the Pentland Application was yet to be given Consent, and the Quinn Application had not been lodged.

13 July 2017 Canterbury District Local Plan Adopted, with the inclusion not only of the Pentland 750 dwellings but also the Quinn 400 dwellings for which the Application would not be lodged until 3 October 2017.

Kent County Council and Highways England have had the 4th slip road on their agendas for some years. Over two decades Canterbury City Council have produced a number of plans designed to alleviate traffic congestion off the A28 at Wincheap - none of which have got beyond the “how about this?” stage.

1.5 The Decisions See-saw

The interests of Highways England, Kent County Council Highways and Canterbury City Council thus have became intricately enmeshed with the Pentland Application - and, in future, the Quinn Application which would also involve mitigation concerning roads and traffic flows in Wincheap. Under the terms of the Pentland Consent (with Highway England’s Annex A) and a s.106 Agreement, control of the timetabling of work on the 4th slip road was passed to Pentland Properties Ltd.

• Pentland will need access to the “Thanington Park” site. Under Canterbury City Council’s Consent Conditions, after a construction phase of up to 75 dwellings, during which construction traffic can access the development site via the estate roads and Cockering Road, Pentland is required to adapt the A2/A28 north-bound slip road to a contra-flow, after which construction traffic must use that contra-flow to access the development site.

• In parallel. Pentland must also comply with Highways England’s Conditions under Annex A and produce plans that achieve approval for changes to the existing A2 north-bound off-slip road before any work can be commenced on “Thanington Park”. Then, before any part of the development can be occupied (so this includes commercial, service and residential properties, not just dwellings) Pentland must comply with Highways England’s Conditions 2) and 4) concerning improvements to access and production of a Travel Plan.

• Pentland will expect to raise profits from sales of units at “Thanington Park”, if only to recover the costs of its Application. So, in order to commence work on more than 75 dwellings at

�6 December 2018

Thanington, Pentland must have made the necessary alterations to the contra-flow. To do this Pentland needs consent to the plans for alterations to the north-bound slip road from Highways England, Kent County Council and Canterbury City Council.

• Before Pentland will be required to provide its mitigation for the 4th slip road, they must produce drawings for the 4th slip road that are accepted by the [“Local Planning Authority”], and can start work and build up to 300 dwellings that can be occupied before choosing their commitment under s.106, Sched 3, Clause 6.2 (cash or construction). After that Pentland can build a further 149 dwellings that can be occupied before the 4th slip road is constructed.

1.6 Deleterious effect on Applications procedures

If construction of the 4th slip road is to commence within the near future, all of Highways England, Kent County Council and Canterbury City Council will be anxious to hasten commencement of Pentland’s construction in “Thanington Park” - including contra-flow alterations to the north-bound slip road. It is not only reasonable to expect this hastening: activity by these three bodies since 2014 has provided evidence of it.

During the past four years and more, the residents of Thanington and Wincheap, and their Ward councillors, have acted vigorously concerning all the proposed developments in Thanington south of the A28.  They have placed documents and comments on Canterbury City Council’s planning applications website, commissioned experts’ reports on traffic safety and pollution issues to counter the developers’ agents’ inaccurate reports, and spoken at relevant meetings of CCC’s Planning Committee. All to absolutely no avail. The sorry history of how our efforts have been ignored or dismissed is set out in detail on wincheapcampaigns.wordpress.com. 

The absence of formal procedures for communication with Kent County Council Highways Department and Highways England has been frustrating, and their responses quite inadequate. Our Ward Councillors have no remit to approach Highways England and KCC. The County Councillor for Canterbury South, which includes Thanington, has been reluctant to engage with his constituents on this issues, or to hold the unelected officials to account.

Highways England’s response has proved disappointing. We expected that developers’ agents’ reports and assessments (particularly those based on swept path analyses) would be subjected to assessments and further testing by Highway England’s expert officers. But these appear to have been accepted by Highways England as Holy Writ and without their carrying out any alternative tests as to the feasibility of the proposed amendments to the bell mouth junction.

The plans for the “bellmouth” junction, and indeed all the proposed A2/A28 junction changes, are unusual and controversial. Thus they merit particularly careful examination.  Given the facts we set out in this Report, we would suggest that any and all new road schemes should be future-proofed to accommodate all vehicles. At the least, a comprehensive and independent impact assessment incorporating worst case scenarios should be undertaken prior to proceeding further with alterations to the A2/A28 north bound off-slip.

�7 December 2018

2. “Bellmouth” Junction Safety Issues: illustrated

2.1 Junctions at the A2/A28 intersection

At the extreme left of this overview is the entrance to the north-bound on-slip to the A2, with a single lane left turn from the A28 (Thanington Road) and a single lane right turn filtered from the right hand of two lanes heading west. Both of these turns are of 90 degrees at the point of entry to the slip road ,following which the slip road curves gently to the left and continues towards merging with the A2. Both are controlled by traffic lights.

Moving from the left, the next junction is the north bound off-slip from the A2. This slip road lies at an angle of 45 degrees with the A2, right up to the exit at the bellmouth. It comprises two lanes:• one turning westward to the left, to run parallel with the lane for traffic queuing for the north bound on-

slip; • the other turning eastward to the right where there is a choice of two lanes of which the left hand one

gives access to a turning into Ten Perch Road (and the Wincheap Retail Park and Park & Ride), and the right hand one gives access to the coast bound on-slip. Both the turning lanes from the off-slip and both the turns from the A28 are control by traffic lights.

The Ten Perch Road junction on the north side of the A28 is complex (see below for an overview from the north). It comprises:• a single lane filter from the A28 merges with the left hand of two north bound lanes of Ten Perch Road; • the right hand northbound lane, which takes vehicles turning right from the A28 west bound lane;• the three lane south bound Ten Perch Road, from which the right hand lane turns right into the west

bound A28, the middle lane guides traffic into the A2 coast bound on slip, and the left hand lane that filters traffic into the east bound A28.

All these turns and filters are controlled by traffic lights, and all lie at an angle of 90 degrees to the A28.

Additionally, all pedestrian crossings at these junctions are controlled by lights.

�8 December 2018

Overview: A28 junctions from the north: Ten Perch Road on the left; north bound off-slip on the right

The coast bound on-slip opposite the Ten Perch Road junction comprises two lanes, accommodating vehicles turning in from left or right, or straight across the A28 from Ten Perch Road, such traffic flows being staggered by the traffic light system

Finally, on the right side of the first overview, and shown closer below, the south side junction of the A28 and Homersham.

Overview from the south: junction of A28 and Homersham

The left hand lane turns into the west bound A28. Traffic for Ten Perch Road and the Wincheap Retail Park moves into the far lane marked by a broken white line, the middle lane provides for turns right into the east bound A28, and the right hand lane is the entrance to Homersham for traffic turning left from the east, and right across the west bound lanes via filter on the east bound A28.

�9 December 2018

2.2 The “bellmouth” junction now

This overview clearly shows the 45 degree angle at which the off-slip road lies in relation to the A28. The pink areas on each side of the junction and the pedestrian island between the two exit lanes are pedestrian pavements. The two red cars in the queue clearly show narrow breadth of the two lanes before reaching the junction. The pedestrian pathway crossing the grassed area connects the A28 Thanington Road to Cockering Road.

Left: approaching the junction from the east. Note narrow left lane. Right: Arriving at the junctionLeft below: across the junction mouth. Right below: junction viewed from north side of A28.

�10 December 2018

2.3 Proposed alteration to bellmouth junction

Oct 2017 A28/A2 London bound off slip General Arrangement Plan (drawing 37827/2001/100/003)

The current north bound exit lane turning left is to be widened on its west side to provide for two lanes, one for right and one for left turns.

The current north bound exit lane turning right is to be converted into a south bound entry lane via a sharp 45 degree turn..

The pedestrian path running between the A28 and Cockering Road is to be re-sited up against the fence and the house side of No 19 Thanington Road. A pedestrian path is to be be provided alongside the left exit lane, leading southwards to the new 90 degree access road to “Thanington Park”.

One pedestrian island is to be retained, but this is now situated between the entry and exit lanes. There will be no longer be a pedestrian island between the two exit lanes.

2.4 Concerns with the proposed alterations: traffic safety

Feasibility of HGV’s negotiating a 45 degree angle left turn, to the left of which lies a sheer drop to the A2.

�11 December 2018

The adequacy of the various swept path analyses for this turn produced by the developer’s agents to justify this plan, and (astonishingly) accepted by Highways England and Kent County Council Highways are discussed further in Part 4. One issue is the absence of any swept path analysis for the 2800 18.75 metre (60 ft) LSTs (longer semi-trailers) that are now being “trialled” in the UK. See Part 4.

Both these and shorter HGVs (16.5 metres) are likely when turning to intrude onto the north bound right hand exit lane.

The LSTs have a rear “kick-out” 2 metres (7 ft) longer than that of 16.5 metre HGVs beyond the back axle, and that may intrude into the west bound lane on the A28 that leads to the filter to the north bound on-slip.

2.5 Current problematic turnings on the A28 Wincheap

Turning 90 degrees right from the north bound off-slip. Drivers in all lanes heading both east and west on the A28 as it crosses the A2 find themselves confronted from time to time by long vehicles straddling the entire A28. HGV drivers miscalculate the angle of their turn into the east bound A28, and become stuck. Getting themselves out of this predicament requires some reversing. These manoeuvres can take several minutes and last through several traffic light cycles.

Turning 90 degrees left from Simmonds Road at the Maidens Head junction. This junction on to the eastern end of the A28 Wincheap currently leads to and from the Wincheap Industrial Estate . It is used by commercial and customer traffic to and from the estate, and by east bound buses servicing the Wincheap Park & Ride. (However, this junction has been designated as part of the Wincheap Relief Road scheme required to mitigate traffic from the 4th slip, plus the Pentland and Quinn developments.)

�12 December 2018

The A28 is narrow at this point. Bollards placed on the pedestrian pavement adjacent to the left turn do not last long..

Left: looking west, white van emerging from Right: looking east towards the Wincheap roundabout withSimmonds Road by the Maidens Head pub. black car queuing on left hand side. Kwik Fit building on right hand side, busy entrance for car repair.customers.

Drivers of all longer vehicles, which include buses servicing the Wincheap Park & Ride, must wait for oncoming vehicles to halt and let them swing into the very short filter area opposite Kwik Fit. Drivers turning left out of the A28 frequently crash into the bollard dividing the in and out lanes.

Turning left 90 degrees into Homersham.: Long HGVs regularly turn left into Homersham in order to deliver to Dunelm and other stores on the site (light blue roofs in the overview below on the left) - which also requires a 90 degree turn into and out of the unloading yard at the back of the building

Long vehicle drivers tend take this bend very slowly and carefully, but none the less damage often results to the protective barrier on the central pedestrian island.

Left: turning into Homersham from A28 west bound Right: Homersham adjacent to Dunelm.

2.6 Concerns with the proposed alterations: pedestrian safety

The Canterbury Local Plan, and the Transport Strategy that supports and enables it, lay heavy emphasis on the expectation of “modal shift” from driving to walking and cycling. This expectation is a main justification of the quantum of development at Thanington (and to the south and east of the city). Thus safe and attractive pedestrian and cycle routes should assume far greater importance and need to be carefully designed and integrated into any new traffic schemes.

Al the drawings and traffic assessment to date show the very reverse of this to be true. We cannot obtain any reassurance from Canterbury City Council, Kent County Council or Highways England on this issue.

Pedestrians using the south side of the A28 to cross the A2 already experience waiting for several sets of lights: across the western exit of the bellmouth junction to the central island, from the central island across

�13 December 2018

the eastern exit to the bridge, then through two similar sets across the A2 coast bound on-slip, and then through the triple sets of crossings and islands at Homersham. There are multiple sets of traffic and pedestrian lights on the north side of the A28 governing a cats-cradle of lanes and slip roads. Pedestrians, with or without children or pushchairs, and mobility scooter users wait several minutes at light signals before completing their crossing of the A2 bridge.

The proposed plans reduce the pedestrian waiting areas at both sides of the bellmouth junction and, while retaining the pedestrian island as a standing point between the exit and entrance lanes - though much reduced - do not provide a replacement island between the two exit lanes. Currently pedestrian lights between the right turn and left tern exit lanes operate on differing sequences, and pedestrian can wait on the island for the relevant light signal. The new plans seem to envisage that both exit lane will operate concurrently - or else this issue has been overlooked altogether.

Currently the western site of the bellmouth junction provides a generous standing area for pedestrians - see on the left below, showing the entrance to the bellmouth seen from the north side of the A28..

Although most of this area is to be sacrificed to the entry to the contra-flow, very long vehicles manoeuvring left turn from the A28 may none the less intrude into the reduced pedestrian space (see Part 4).

The central pedestrian Island is to be reduced to a rectangular strip

�14 December 2018

The path on the south side of the A28 and the pedestrian path between the A28 and Cockering Road are to be pushed against the boundaries of No 19 Thanington Road

There is a two-foot drop from the pedestrian path to the eastern fence and wall of No.19. It is not clear whether the altered path is to be level with the bottom of the fence and wall, or raised to the current level of the exit road. If the former, traffic will be adjacent to pedestrians at shoulder height. If the latter the fence and wall of No 19 will be overshadowed by the raised ground.

None of the plans available show how the parallel needs of pedestrians and vehicles are to be safely dealt with.

�15 December 2018

2.7 Increased heavy traffic using the junction

The alteration of the off-slip to a contra-flow has been proposed to provide access for construction traffic for “Thanington Park”, as well as non-construction traffic required access during and after a long building period. The non-construction traffic will include commercial vehicles, service vehicles such as buses and trash collection lorries, and ambulances and people carriers attending the hospice that the development is to contain.

Currently such vehicles approach the bellmouth junction from the each or west via the A28. However, sometime during the long building period for both the Pentland and the Quinn developments, and that for the care home on Cockering Road, heavy vehicles approaching on the coast bound A2 will be provided with an off-slip, passing through part of what is now the Wincheap Park & Ride and then proceeding north and then south on Ten Perch Road. This “key hole” route will bring traffic on to the A28 facing west, and thence to the entry to the contra-flow. See the orange line and arrows on the sketch diagram below.

This problematic route has been the subject of protest by Wincheap and Thanington residents, and no plan has been provided by the developer, or anyone else, of how the two constructions are to interact - signage, traffic and pedestrian lights, changes to lane discipline and marketings, etc. - but as far as we can tell the

�16 December 2018

route envisaged is shown by the orange line and arrows above. Some swept path analyses seem to show a facility for traffic from the west (pink line) to turn into the contra-flow, but other plans do not. No officer of Highways England, Kent County Council or Canterbury City Council we have approached has responded with clarification of this point, when they have responded at all. See Part 3.

Our point made at point 2.4 above concerning the 45 degree turn left into the contra-flow should be re-considered concerning the weight of numerous vehicles using the south bound lane and the strength of the embankment bordering the A2. Highways England has specified certain requirements re sight lines and screening, signage and traffic light systems, but (so far as we know) none concerning prevention of vehicles or their loads deviating left from the south bound lane towards the drop to the A2, or into the north bound lanes to the right.

Addressing “worst case scenarios”, such as this, surely should be business of Highways England, rather than the developers and their agents, but we see no sign of their attending to this matter. See Parts 3 and 4.

�17 December 2018

3. Highways England (HE), Kent County Council (KCC) and Canterbury City Council (CCC) and their responses

Part 3 is an attempt to identify the origin and subsequent development of the actual plan to create a contra-flow at the top of the northbound A2 off-slip to the A28 at Thanington, which involves a 45 degree left turn over a sheer drop to the A2. Residents’ reactions to those plans in correspondence with Highways England, Kent County Council and Canterbury City Council are also listed.

Full versions of all the documents from which extracts are used here can be found either at Section 2 of the Appendix document that accompanies this Main Report, or where indicated in that Section 2.

*****

3.1 Pre-“Thanington Park” Application

November 2014 Canterbury City Council’s draft Local Plan submitted to the independent planning inspector.

20 November 2014 Application CA//14/02441 by Wardell Armstrong (for Pentland Properties Ltd) Land off Cockering Road - Scoping Note, and 11 December 2014 CCC’s Decision on 14/02441, No objection.

We have not seen the Scoping Note, and so do not know if any road plans for the A2 north bound off-slip were included in it. However, paragraph 58 of the Decision states:

“ I understand you are currently undertaking pre-application discussion with Kent Highway Services. Please include any documents which are requested as a result of these discussions. …”

HE’s agent’s comments show that the idea of the contra-flow was well developed:

“1.1.3 It is understood that in addition to the development land uses at the site, it is proposed that the A2 slip road north bound (NB) shall be reconfigured in order to lengthen and move it south east. Also, one access into the site will be taken from the new slip road termination point, and another access will be created onto Cockering Road from the site. … 1.1.6 The HA’s concerns at this site is the potential direct impact to the A2 (and junction with the A28) which is first point of contact with the SRN [Strategic Road Network]. The development also has a proposal for the creation of a direct access to the A2 slip road on the south, and this will be considered as part of the study area of the Transport Assessment. 1.1.7 Due to the proposal for a direct access from this section, as well as the nature of the overall junction A2/A28; it is considered that this is the only point of concern for the HA on the SRN as a result of traffic impact from this development. 1.1.10  It is noted that the developer intends to modify part of the SRN at the NB slip road of the A2 by lengthening it, and also providing a new junction as the development’s primary access in the form of a roundabout or signal controlled. …2.1.26  Due to the SRN having a high proportion of HGV’s in this area we will expect a construction traffic management plan, to be agreed with the HA at the planning application stage …”

So, all of HE, KCC and CCC were aware of this plan by December 2014 at the latest, and were involved in discussions prior to PPL’s Application for “Thanington Park”.

HE’s agent’s further comments identify discussion of other road and traffic issues in Wincheap and south Canterbury. The developer’s mitigation for “Thanington Park” was to involve funding for or construction of the 4th slip road at Wincheap. Henceforward, even though the Application had not yet been lodged, consideration of the details of the contra-flow system construction took a very second place to those of the 4th slip road.

“2.1.35  In addition, the HA has previously noted as highlighted in the minutes of meeting on Thursday 13th November 2014, that the potential for a 4th slip at the Wincheap Area and development at Mountfield Park in south east Canterbury including the new dumbbell junction, should be considered as part of the impact assessments for this development in the TA. The TA should demonstrate how, via modelling or other, this can be demonstrated as not impacting on this development.

�18 December 2018

2.1.36  The proposal for separate junction capacity models to be developed at the A28 Wincheap/Hollow Lane/Cow Lane, A28 Wincheap/York Road, and A28 Wincheap/Pin Hill/Castle Street/Rheims Way junction is acceptable.”

3.2 “Thanington Park” Application

6 July 2015 Application CA//15/01479 “Thanington Park”. Route Infrastructure Parameter Plan shows a “point of access, vehicle only” to/from the northbound A2 exit slip road.

Peter Brett Associates’ (PBA) Transport Assessment “6.5.2 The primary access will be from the re-aligned A2 westbound off-slip road, via a traffic signal controlled junction into the site. …“A2 westbound off-slip access … 6.5.9 The main vehicular access to the site is proposed to the east, via a reconfigured slip road arrangement from the A2. This has been discussed with the Highways Agency who have agreed the principle of its provision. …”

“1.1.17 The layout of the masterplan demonstrates that there will be four vehicular access points to the site. Three of these will be for general traffic whilst the remaining a bus, walk, cycle access. The primary access will be from the re-aligned A2 westbound off-slip road, via a traffic signal controlled junction into the site. Two further accesses for general traffic will be provided to Cockering Road whereby an alternative route to Cockering Road will be provided through the site for a short section.”

�19 December 2018

This is the first appearance available to residents of the plan for changes to the off-slip and contraction of a contra-flow. HE was to require some tweaking to this plan, but in essentials it has remained the same.

3rd August 2015 HE’s letter to CCC states that for the first time they had safety concerns on this plan.

This is the last evidence we have seen from HE, KCC or CCC of concern about these obvious issues. See section 3.8 for their refusal to engage further.

It may be that by the time HE wrote a second letter to CCC on 16 September 2015, the developer had satisfied HE on these points, but we do not know.

“At the junction with the A28: The revised radius of the eastern side of the junction bell mouth comes very close the parapet railing to the extent that at one corner the railing is too close to the edge of the carriageway and is likely to be prone to vehicle strikes. The other corner of the parapet restricts the footway width to the proposed crossing point to the extent that the layout is likely to be largely impracticable from a day to day usability perspective. We have reservations as to whether or not the correct clearance to the parapet can be obtained or practicable footway width past these pinch points.

Swept path analysis will be required to ensure that all vehicles likely to use this junction can do so safely without entering adjacent lanes. We have concerns that an HGV approaching the stop line northbound on the slip will to be able to make the left turn without encroaching into the adjacent lane and also the turn left onto the slip from Thanington Road looks dubious for large vehicles. [This is the 45 degree turn.]

Section of Two Way slip road: The new opposing third lane runs close to the main northbound carriageway of the A2 Trunk Road particularly at the new junction on the slip road. It is likely that to construct this carriageway the embankment separating the slip road from the main alignment will need to be reinforced and proactive safety barrier will need to be provided along its full length. There may not be sufficient verge width to enable this be be achieved particular {sic} with regards to working width and set back. Furthermore, an environmental barrier will need to be provided to screen headlights of opposing flows of traffic between the slip road and main carriageway of the A2.”

16 September 2015 HE in a second letter to CCC, following the developer’s response to HE’s letter of 3 August, plus supplementary information from PPL’s consultants, was still unhappy about the design, and in effect notified CCC (and KCC) that it reserved its power to require a condition to be placed on PPL to get it approved by Highways England. Its recommendations about speed limits and signal placements indicate what Highways England will look for in any revised design.

The letter includes the following: “ … the intention is to de-trunk a section of the slip road and this would then revert to the local highway authority. We will need to speak to KCC about how we manage this process.”

HE also states it will require a non-motorised user context report and a road safety audit due to these modifications, and that it will consult with KCC about these requirements. In addition to the two preliminary audits, HE’s Annex A to CCC Decision Notice sets out some Conditions (see below).

5 November 2015 PBA’s Design & Access document for the “Thanington Park” Application, contains some small and large plans for site access from the A2 off-slip, and which at this date still contained a plan for a new Park & Ride, to be accessed from via the contra-flow system.

“The site will be accessed from a new signal controlled junction on the re-aligned A2 off-slip, linked to the A28 by a new two-way section of road running on the alignment of the current slip road.Secondary access points will be provided from Cockering Road in the vicinity of Strangers Lane and St Nicholas Road.”

3 December 2015 At a “Thanington Park” planning application: residents’ meeting, 7:00 p.m.Thanington Neighbourhood Resource Centre, great anger was voiced at the proposed use of the estate roads and Cockering Road. Also noted, showing that residents’ had limited knowledge of what had transpired at the pre-Application stage:: “1.1 Dave Smith: there is a history of planning applications for this site. Original application for 750 dwellings and amenities, September 2014, rejected on grounds of traffic access and environmental impact. Of the three access points,

�20 December 2018

the plan for access from the A2 slip road from Dover was not well constructed. ….”

3.3 The s.106 Agreement, CCC’s Decision Conditions, and HE’s Annex A Conditions

3.3.1 6 July 2016 The s.106 Agreement concerning 15/01479 between 3 parties: Pentland Properties Ltd (“Owner”). Kent County Council (“County Council”) and Canterbury City Council (“Council”). barely mentions the contra-flow plans. There is a defined term: “A2 Slip Road Works” means a scheme of works for the A2/A28 London bound off-slip at Wincheap, Canterbury approved in accordance with Condition 8 of the Planning Permission.”which is subsumed under another defined term, and never used again: “Highways Works” means the A2 Slip Road Works, the A2 Slip Road 4th Arm Works and ancillary works associated with the construction of the A2 Slip Road 4th Arm Works.”which is used solely as a heading in the main terms and conditions, and in two schedule clauses:

“Schedule 3, clause 5. The Council’s Covenants …Upon written request from the Owner to seek any necessary resolutions of the Council necessary for the purposes of making available and/or dedicating as highway any land within the Council’s ownership reasonably required for the purposes of the Highways Works and upon receipt of any such resolutions to under into any necessary agreement on such basis as is reasonably required to give effect to said dedication or to make said land available for the purposes of the Highways Works (subject to the Owner meeting the Council’s reasonable costs and indemnifying the Council to its reasonable satisfaction in respect of any reasonable costs or claims arising from its entry in the said agreement or the carrying out of the A2 Slip Road 4th Arm Works. ….”

“Schedule 4, clause 6.5 The County Council covenants:…6.5.2 To make available to the Owner at no cost to the Owner any land within the County Council’s ownership necessary for the purpose of providing the Highways Works.”

All the many other definitions and references to an “A2 Slip Road” actually refer to construction of or cash for the the 4th A2 off-slip, which is the major concern of the s.106 Agreement .

13th July 2016 CCC published its Decision Notice on PPL’s Application (with certain Conditions to be fulfilled by PPL. Condition 8 commences: “8. No development on any phase hereby permitted shall be commenced until detailed designs for the following highway works and a timetable for points (iv) and (v) below, have been submitted to and approved in writing by the Local Planning Authority: (i)  A scheme of works to form the site access from the A2 as shown indicatively on drawing 21227/5503/004C.

…”

That is, the layout including the 45 degree left turn into the contra-flow. Condition 8 concludes:“Thereafter no more than 75 dwellings within the development hereby approved may be occupied until the highway works listed at (i) to (iii) above have been completed and are available for/open to public use to the satisfaction of the Local Planning Authority and highway works listed at points (iv) and (v) shall be carried out in accordance with the approved timetable.”

The “trigger” for PPL to provide cash or construction for the 4th slip road is “prior to the occupation of 300 dwellings at ‘Thanington Park’”. Until Condition 8 is fulfilled and signed off as satisfactory by HE, KCC and CCC, the developer cannot sell (or rent) for occupation more than 75 dwellings (but note that commercial and other non-residential structures are not limited by this requirement). So, in order to get commencement of construction of the 4th A2 slip road, HE, KKC and CCC have put themselves under pressure to hasten sign-off of the contra-flow design.

HE’s Annex A Conditions to be attached to the planning permission confuses the definition of Commencement even further, by requiring:“1) Detailed Drawings No part of the development hereby permitted shall be commenced until a fully designed scheme has been submitted to and approved by the local planning authority (who shall consult with the Highways England on behalf of the Secretary of State for Transport.)” and “2) Scheme Implementation No part of the development hereby permitted shall be occupied until the completion of the improvements, …” and “3) Construction Traffic Management Plan No part of the development hereby permitted shall be commenced until a Traffic Management Plan (TMP) is submitted to and approved …“

�21 December 2018

As Annex A follows on from HE’s letters to CCC concerning the contra-flow, Annex A probably actually does apply to the contra-flow - unlike the bulk of CCC Decision Conditions and the s.106 Agreement, that barely refer to it.

3.4 Thanington residents’ concerns over PPL’s/PBA’s plans

In the meantime, Thanington Without Parish Council (TWPC), appalled at the inaccuracy of the PBA’s Design & Access, Transport Assessment and other documents accompanying PPL’s Application, had instructed Richard Buxton Solicitors in an attempt to re-visit the CCC Planning Committee’s decision to approve Application 15/01479. Railton TPS Ltd had produced a Report on the PBS’s traffic assessments that was highly critical.

In a letter to Richard Buxton dated 29 July 2016 (and copied to CCC on 19 August 2016) Bruce Bamber of Railton comments on a record of discussion at Planning Committee meeting of the contra-flow plan:“ …There is particular concern [expressed at the meeting] of the lack of any details about the proposed connection between the A2 London bound off-slip and the A28. …… The main access to the proposed development is via a roundabout on the A2 London bound off-slip and the signalised London bound off-slip/A28 junction. The London bound off-slip and the off-slip junction are subject to significant alteration to provide access to the proposed development. The off-slip is proposed to become 2-way between the A28 and the site access roundabout. No details of these alterations are provided in the supporting Transport Assessment and Transport Assessment Addendum or in the Committee Report and no details are presented by the Highway Authority representative at the Committee Meeting despite direct appeals at the Committee Meeting for this information to be provided. On the basis of the above it appears that the Committee was not in a position to determine the application since no detail was provided on the main access to the site and there was therefore no certainty that a safe and acceptable arrangement could be delivered. The Committee also appears to have been mislead by the Chair and the Highway Authority representative when it was stated that all matters were reserved, including access. This statement served to silence genuine concerns that were being expressed at the meeting that there has been insufficient information provided to demonstrate that the proposed access arrangements were acceptable.”

On 25 November 2016 residents met with representative of KCC at Thanington Local Resource Centre, having asked CCC to arrange this as a quid pro quo for TWPC not proceeding to judicial review. The meeting was distressing for residents, as was subsequent correspondence with CCC. For a full report of what happened at the meeting and subsequently, see section 5 of the document “Evidence of Contempt” on wincheapcampaigns.wordpress.com at the page Notification of Breach of Duty of Care.

Prior to this, some residents may have had confidence that KCC and CCC would pay attention to their concerns regarding safety and health, in order to be able to act in their best interests - or at least prevent harm to them. After this, they believed that their concerns were perceived merely as a nuisance and a hinderance to the Councils’ and HE’s determination to build a 4th slip road and comply with the house building requirements of Canterbury’s Local Plan.

3.5 Quinn Estates Ltd’s Application CA/17/00519

3 March 2017 Quinn’s Transport Assessment contains the following … “5.6 Highway Network … 5.6.3 The A2 Wincheap junction currently comprises 3 slip roads with the eastbound off slip not provided. The Thanington Park development has an obligation to provide the eastbound off slip prior to 450 units being built. In addition, the Thanington Park development will upgrade the London bound off slip.”

4th April 2017 Kent County Council Decision No 17/00025, Matthew Balfour, the Cabinet Member for Environment & Transport (A2/A28 4th slip road plan attached).

9 May 2017 As “stakeholders” members of the Wincheap Society Committee attended meetings called by both PPL and QEL. At this meeting with QEL, Gary Heard of PBA, responded to comments that the proposed additions to the slip road situated west of the northbound A2 into Thanington Park and accessed southwards from the A28 were physically unfeasible, as well as adversely affecting adjacent houses, by saying, “I’ve done the measurements, and it will work”.

�22 December 2018

21st June 2017 Canterbury District Local Plan cleared for Adoption. The introduction of additional housing sites (1150) at Thanington south of the A28, in Canterbury.

13th July 2017 Canterbury District Local Plan Adopted.

13 July 2017 Canterbury District Transport Strategy 2014-31 was adopted by CCC. It contains no mention whatsoever of the contra-flow system planned for the A2/A28 off-slip or of any other access to “Thanington Park”, or QEL’s Application for “Thanington Farm”.

3.6 Wincheap Society’s Reports

Between June 2017 and January 2018 the Wincheap Society, a residents’ association, produced reports, letters and comments on Applications relevant to the Thanington developments and the road works proposed for them. Apart from the extracts set out in Section 3 of the Appendix document, all of this correspondence is available in full on in the documents “Evidence of Contempt” and “After Notification” on the page Notification of Breach of Duty of Care on wincheapcampaigns.wordpress.com.

August 2017 “Access to Thanington Park: the Decisions See-Saw” - this Report was sent to HE, KCC and CCC attached to emails. These are the Wincheap Society’s queries regarding the contra-flow in section 3. Proposed access points to Thanington Park:

“Is there room for a third contra lane down this slip road? Surely not, unless the exit lanes are shifted to the left over the pathway and a grassed area, and probably over the front garden of the first house to the west. Will demolition of that house be needed? Is there room for three HGVs in parallel anywhere on the altered slip road?

Is there room for a second pedestrian island at the junction mouth, between the northbound and southbound lanes? There is not, so how are pedestrians crossing the bridge over the A2 on the south side to do so safely?

What additional traffic lights will be required at this junction, and on what sort of sequence? Traffic currently travelling east and west on the A28 often is held up for several minutes, and through several light changes, while long lorries attempt to turn right from this slip road. The existing system is difficult for any driver not acquainted with it to negotiate.

The slip road approaches the A28 at a 45-degree angle. Long vehicles turning right though 135 degrees into the east-bound A28 have at least the full width of that road in which to manoeuvre. How will such vehicles turning sharp left into that angle do so without danger of breaching the parapet? The new very long HGVs are 7 foot longer than the current norm. (Also, negotiating 90 degrees mid-slip road will be difficult enough.)

Where will the “environmental barrier to screen headlights of opposing flows of traffic between the slip road and main carriageway of the A2” be located? The eastern side of the slip road is a 80/90 degree drop to the A2 at this point. …”

Wincheap Society was still under the impression that HE would reject the plan at dangerous.“Comment With regard to the proposed alterations of the A2 northbound off-slip road it is difficult, given the terrain, to see that these will ever achieve acceptance by Highways England. In which case PPL will need to provide vehicle access to the development site by other routes.”

Following posting and distribution of the Thanington Park Access Report, members of the Wincheap Society Committee and Wincheap Ward Councillor Nick Eden-Green pressed the points made in it in letters and emails to KCC and CCC in the hope of securing informative and appropriate response. This correspondence is set out in Section 2 of the Appendix document. The Councils’ officers’ responses were either dismissive, or did not address the specific points raised.

For example, on 15th September 2017 the following extract is from a letter emailed by Councillor Eden-Green to Colin Finch KCC, (and Richard Moore and Austin Mackie of CCC):

“….The Planning Decision Notice granted on 13th July 2015 required detailed drawings of the proposed two way access slip road. Both residents and Mr. Bamber of Railton have examined the physical feasibility of this and do not see how it can actually be achieved on the ground. Clearly this may be proven or disproven by a detailed plan, but once more no such plan appears to exist.Schedule 3 paragraph 6 of the S106 Agreement dated 6th July 2016 refers to the number of houses that can be built at Thanington Park prior to the construction of the fourth slip road.

�23 December 2018

However, if any houses are built the two way access slip road must be constructed first. Given that there are no plans for this and that its feasibility is questioned should there be any reliance on a funding stream from housing development for the fourth slip road? Surely plans for the two way access road, including plans for the junction on to the A28 are the first priority.The two contradictory plans for the fourth slip road take no account of the two way access slip road, nor do there appear to be any plans for the overall A2/A28 junction as modified by these changes. A piecemeal approach clearly will not do. Where is the comprehensive plan, including traffic modelling?“

22 November 2017 Ruth Goudie and Austin Mackie, CCC, met with Nick Eden-Green and Gillian Bull of the Wincheap Society, following which Gillian Bull emailed to both CCC officers her comments on the meeting, including concerns regarding signage and HGV capacity of the “bell mouth” junction at the modified A2/A28 north bound slip road. This document is available on wincheapcampaings.wordpress.com.

24 November 2017 PPL’s Hybrid Application 17/02718 , Transport Assessment extracts and plan:.

Plan: the “bell-mouth” exit and entrance from and to the contra-flow. No notice whatsoever had been taken of residents’ or ward councillors’ comments regarding safety and feasibility.

“4.6 Proposed network changes …. 4.6.4 The primary access will be from the re-aligned A2 westbound off-slip road. This access is required at 75 dwellings (under the extant Thanington Park permission) and will comprise a signal controlled junction on the existing London bound off slip road. The existing slip road will be relocated further to the south east and lengthened to meet appropriate standards. A further access for general traffic will be provided to Cockering Road (in the vicinity of St Nicholas Road) which will access the initial 75 dwellings on the hybrid application area.”

�24 December 2018

1 January 2018 Wincheap Society’s detailed comments on, and objections to, PPL’s Hybrid Application sent to CCC for posting on the Application website. including apparent discrepancies concerning routing and signage. and enquiring why manoeuvrability of long lorries (LSTs and truck trains) were not considered. These comments were also posted on at “Contra-flow on A2 north bound A2 exit”.wincheapcampaigns.wordpress.com

The Wincheap Society were particularly worried to see that easily-identifiable factual inaccuracies in PBA’s documents that had been brought to CCC’s attention in 2015, re PPL’s initial Application, had survived and been reproduced without amendment in the Hybrid Application.

3.7 The Notification of Breach off Duty of Care

22/23 January 2018 Realising that none of the residents’ concerns over traffic issues and pollution arising from the Thanington/Wincheap development Applications were being given any attention at all, Four Wincheap and Thanington Residents’ Associations, and Wincheap Ward Councillor Charlotte MacCaul signed a Notification of Breach of Duty of Care, which was posted and emailed to HE, KCC and CCC. This document is available on www.winsoc,org.uk and wincheapcampaigns.wordpress.com.

HE’s and KCC’s responses can be summarised as essentially “No, we’re not in breach”; CCC, when prodded into replying, said that they thought that the others had done so. However, one of their PR officers made a statement to reporters from the Canterbury edition of the KM Gazette

“We take our responsibilities on traffic congestion and air quality very seriously and reject outright the suggestion that the signatories to the letter have been treated with contempt. We would be very keen to hear of specific examples where they believe this to be the case.”

The two-column Timetable of events in Section 1 of the Appendix document clearly shows that from 2014 to the present day, officers of the Councils and HE soldiered on with administering the Application and Consent procedures, regardless of anything said or done by residents and ward councillors. The officers have learnt to parlay the public consultation and the planning committee processes in such a way as to render them a hollow sham.

3.8 Highways England, CCC and HGVs on the contra-flow

The Wincheap Society’s attempts to get HE and the Councils to engage on this issue failed dismally. HE’s response would be laughable, if it were not over a matter of life and limb. On swept path analyses, see Part 4 of this Report.

14 March 2018 John Osborne, Wincheap Society, on behalf of the Notification signatories, writes and emails Paul Harwood HE (cc’d to KCC and CCC) re safety on the contra-flow.“ …However, regarding the London bound slip road, we do have grave concerns that neither Highways England, Kent County Council nor Canterbury City Council has been prepared to address over the past two years. Crucially, we seek a straight answer to one central question:How are vehicles longer than a domestic car to negotiate the left turn from the eastern A28 into the contra-flow?This is a sharp angle: 45 - 50 degrees. This left turn cannot be smoothed, as the similar angle turn from the A2 into Ten Perch Road has been, by bringing it forward into the car park. There’s a sheer drop onto the A2. Anything long turning left into the contra-flow will need to swing into the exit lanes. The “bell mouth” junction can only be widened by pushing out the pedestrian areas: on the west side right up against the unfortunate people who are living in the first house; on the east side by biting space off the already not very adequate pedestrian pavement.This question seems to fall into the category of “Emperor’s New Clothes”. It appears to us, who are “expert” in living in the area and using this stretch of the A28 daily, to be a simple matter of what is or is not physically feasible. You don’t need to be an expert to see that the proposed design is deeply problematic. But no one is prepared to answer it. None of the reports or audits produced by Pentland Properties Ltd”s agents address it. Furthermore, some such plans show vehicle access to the contra-flow by a 90 degree right turn for traffic coming from the west on the A28, whereas others show no such turning, but require traffic to negotiate the proposed “keyhole” layout of the 4th slip road, then turn 90-degrees right from Ten Perch Road onto the A28, and then left into the contra-flow. The alternative to this convoluted trip would be for drivers to turn into St Nicholas Road (as they surely will, and indeed are required to do in the early stages of Thanington Park construction): the very manoeuvre that the contra-flow was planned to avoid. ….|

�25 December 2018

29 March 2018 Paul Haywood HE emailed … his reply to John Osborne:“ …It is a routine part of our road design process to check that layouts can accommodate turning vehicles. Moreover, depending on the road layout, it is not necessarily the longest vehicle that will have problems. Therefore we carry out checks for a number of vehicles.We carry out these checks using vehicular 'swept path analysis' where we plot the extremities of the vehicle concerned for the whole of the turning movement.I attach the current relevant drawings for both the 4th slip (coast bound, left turn from A28 to Ten Perch Road) and the London bound off slip (A28 left in to the new link road down to the development access). Those numbered 39183 relate to the 4th slip, those numbered 37827 are for the site access/London bound slip. The drawings provided cover the swept paths for refuse, bus and articulated vehicles.I hope that these are sufficient to demonstrate that your concerns have been addressed in the design of the scheme.”

10 April 2018 John Osborne posted and emailed Paul Harwood HE:“ … I am astonished and disappointed by your email reply to my letter dated 14th March, on behalf of all the Notification signatories. Your response dated 29th March is Kafkaesque, in that it is perfectly circular:1. Pentland Properties Ltd’s agent, PBA’s inadequate swept path analysis drawings led us to question the feasibility of their contra-flow plan.2. In the expectation that Highways England’s engineers will have assessed the accuracy of the PBA drawings, we wrote to Highways England (and KCC Highways, and Canterbury Council) outlining our specific concerns - how are long vehicles to turn on a 45-degree angle; only shorter vehicle lengths shown on the PBA drawings (i.e. 1998 rigid lorry lengths, not the 1000+ very long vehicles now being “trialled”); no coordination with plans for the proposed 4th slip road; no clarity as to whether traffic from the west also is to turn into the contra-flow, etc. 3. In your reply you insist that everything is absolutely fine because there’s a swept path analysis that says so - and you attach the same PBA drawings that gave rise to our specific concerns. Your attachment in addition of the drawings for the 4th slip road indicates to us that you have not concentrated your attention on the salient question in our letter, which concerns the contra-flow plan. Additionally, we are very puzzled by your statement:“… it is not necessarily the longest vehicle that will have problems. Therefore we carry out checks for a number of vehicles.” Yes, we agree that there will be problems with vehicles that are shorter than the longest, but that does not in either case mitigate those problems. Your statement is otiose. It does not address our salient question. And, who are the “we” you refer to? If this means Highways England, acting as independent technical assessors and not just rubber-stamping PBA’s reports, will you please provide us with your assessment data and conclusions? If such documented information exists, we hope it may alleviate our fears that no one is monitoring the physical feasibility of what is being proposed by a developer for changes to the A2/A28 junctions.”

10 April 2018 John Osborne wrote and emailed Richard Moore CCC:“ … With reference to your email date 29th March, in which you state: ‘I note this morning that Paul Harwood from Highways England has responded on this issue and copied you in on his reply, so I trust this has addressed the queries raised in your letter.’ If you had read Mr Harwood’s response, rather than just noting it had been sent, it would have been cleat to you that he did not address our concerns in any way. I enclose a copy of my letter of today’s date to Mr Harwood, protesting the inadequacy of his response. The terms of my letter to you and Austin Mackie dated 20th March still apply, and I would appreciate a responsible and appropriate answer to it.”

23 April 2018 A Mackie CCC emailed John Osborne:“ … Before I speak to the respective applicants, can I check that where you refer to ' tracking for the longer lorries being trialled', you are referring the trial which the DfT started in 2012, in which up to 1,800 vehicles would be trialled for a 10 year period with longer than standard trailers (LST), ie, the standard trailer length of 13.6m could be increased to either 14.6m or 15.65m. Many thanks.”

3 May 2018 Gillian Bull on behalf of John Osborne emailed Austin Mackie CCC, cc’d to Colin Finch KCC:“ … we were surprised at the details re LSTs you set out in your email of 23rd April as they are inaccurate. Our comments on PPL’s “Hybrid” Application CA//17/02718, an extract of which are reproduced below, were sent to you earlier this year. It contains the correct details of LSTs - both measurements and the increase in numbers in the trial to 2800. Perhaps you did not read this when we submitted it?

3.9 The missing safety audits

HE’s requirement of a non-motorised user context report and a road safety audit in respect of the contra-flow was noted above at point 3.2, letter of 3 August 2015. The Wincheap Society and

�26 December 2018

Councillor Eden-Green have continued to enquire after these, and at the date of this Report are still doing so. Our understanding is that these reports would have to be presented to and accepted by HE a part of fulfilment of Condition 8 of CCC’s Decision.

In May and October 2017 such reports had been produced by PPL’s agents in respect of the 4th slip road, made available to the Wincheap Society after some prompting, and reviewed by us. The reviews had been sent to CCC and posted on wincheapcampaigns.wordpress.com. Both reviews were found to be highly unsatisfactory, but they had at least been done.

11 September 2017 Email correspondence between the Wincheap Society and KCC Highways contained the following statement from KCC:“Designs for changes to the London bound A2-off slip and site accesses have secured Stage 1 Safety Audit approval from both the County Council and Highways England. This approval confirms that the design has been accepted by both KCC and HE and included an assessment of vehicle tracking as part of the process. Both KCC and HE will now complete the more detailed Stage 2 safety audits in order for the developer to commence construction.“

15 September 2017 Another email from KCC a few days later: Designs for changes to the London bound A2-off slip and site accesses have secured Stage 1 Safety Audit approval from both the County Council and Highways England. This approval confirms that the design has been accepted by both KCC and HE and included an assessment of vehicle tracking as part of the process. Both KCC and HE will now complete the more detailed Stage 2 safety audits in order for the developer to commence construction.

26 September 2017 Wincheap Society emailed Matthew Balfour KCC: “ …Thank you for your emailed response on 15th September to ours of 5th September. Access to “Thanington Park” ….Firstly, you state that “Designs for changes to the London bound A2-off slip and site accesses have secured Stage 1 Safety Audit approval from both the County Council and Highways England.” Please supply copies of this design and the respective approvals to the Wincheap Society, and also to our Ward Councillors, Nick Eden-Green and Charlotte MacCaul and our KCC Councillors Michael Northey and Ida Linfield (if this has not been done already).“11 October 2017 A document comprising road plans was sent by KCC to the Wincheap Society attached to an email. No text or information concerning the actual approvals or the included assessment of vehicle tracking were provided. It is entitled as “Stage 1 Safety Audit” for the A2/A28 north bound slip road contra-flow.   Essentially, it is not a safety audit - just a set of road plans, without text.  The Wincheap Society’s report on these plans is available on the Contra-flow page of wincheapcampaigns.wordpress.com.

We were astonished to discover, in late 2018, correspondence between HE and CCC in January 2018 (see below) showing that the two reports had not yet been prepared. However, further correspondence between HE and CCC in June and July 2018 refers to Condition 8 as being ready to be discharged. Does this mean that the two reports have been completed and approved by HE?

11 January 2018 K Bown HE emailed A Mackie, CCC requesting from PPL a Stage 1 Safety Audit and a Walking/Cycling Assessment for the contra-flow.

30 January 2018 D Bowie HE emails M Boots CCC again inquiring after a Stage 1 Safety Audit and a Walking/Cycling Assessment for the contra-flow.

8 March 2018 17/02911 Delegated Report re construction access: CCC: Approved. …“… St Nicholas Road can only be used for the first phase of the sites construction. The CMP does outline that most of the site traffic will be required to use the new A2 slip, once opened, however to facilitate the works for the A2 slip improvements and to build, up to, the first 75 dwellings (as stated in condition 8 of the approved outline permission) access will be needed using the most direct route from the A28 which is via St Nicholas Road. This is outlined in the CMP, although the maximum number of dwellings was not stated.”

20 June 2018 Jamie Finch, Pentland Homes Ltd emails M Boots, CCC RE: Thanington Park - Phase 1 Reserved Matters, that KCC ready to approve 15/01479 Condition 8.

20th July 2018 CCC Decision Notice re 17/02912 A Mackie, to J Finch, Pentland Homes 15/01479 Conditions 8 and 9 Approved only re “Wincheap Farm Underpass”.

�27 December 2018

24 July 2018 CCC Officer’s Report 17/02912 HE and KCC both ready to discharge Conditions 08 and 09 of 17/01479.

28 November 2918 Councillor Nick Eden-Green emailed A Mackie CCC asking for the Stage 1 Safety Audit and a Walking/Cycling Assessment for the contra-flow.

5 December 2018 A Mackie CCC to Nick-Eden-Green “ ,,,,I will ask Pentland directly if they have the documents that you seek.”

At the date of this document, December 2018, neither an independent Stage 2 Road Safety Audit or a Walking, Cycling & Horse-Riding Assessment & Review for the contra-flow system has been seen by the Wincheap Society.

�28 December 2018

Part 4. Swept path analyses’ relationship to physical reality at the A28 plus information on LSTs (longer semi-trailers)

4.1 Issues with swept path analyses

1. They do not show any of the longer vehicles now in use on UK roads.

2. They do not show any “worst case scenarios” but assume that drivers will steer their (properly loaded) vehicles in a straight path, as envisaged by the swept path software.

3. They comprise designing and testing the designs at a desk. In the real world the laws of physics are less accommodating than those of the digital environment.

4. Highways England, in particular, and Kent County Council Highways and Transport Department appear to accept them as sufficient evidence of safe design and to have no alternative modelling technique.

Point 1 is addressed illustrated in sections 4.2 and 4.3.

Point 2 Designers of systems for ships, planes and trains are required by regulators to provide best and worst case scenarios as a matter of course. But not roads, apparently. Why would Highways England and Kent County Council, in a county with one of the highest road “accident” occurrences, be so cavalier concerning such requirements at the new road design stage? The M2, A2 and Brenley corner in particular are now among the nation’s bad road myths (London Review of Books, 6 December 2018 Patrick Wright “Short Cuts: The Moral of Brenley Corner”)

Worst case scenarios are reported daily on the M2, M20 and M26. Drivers do not practise lane discipline, or comply with speed limits, or refrain from drink or drugs, or load their lorries securely. Why, having inherited a manifestly dangerous road system, is Highways England permitting the creation of a new accident black spot at the bellmouth junction?

On 29 November 2018, on a flat, lightly curved exit road at junction 5 of the M2 a poorly maintained and loaded lorry tipped over and shed its cargo of beer. The driver may or may not have been in the correct lane, but in this instance the load fell onto a fairly level surface.

�29 December 2018

Any vehicle either deviating from its lane or shedding its load to the left on the proposed south bound lane at the 45 degree bellmouth junction, or further down, the contra-flow will fall or drop its load onto the A2.

Highways England’s letters and Annex A concerning Pentland’s developer’s designs for the contra-flow specify sight lines, speed limits, and signal placements and height. Nothing on the feasibility of vehicles longer than cars negotiating a hairpin bend, or the safety of pedestrians standing at that bend.

Point 3 People who walk along the A28 and drive on the A2 and A28 react strongly when shown or told of plans for the contra-flow. The consensus is that these plans are so remote from reality that they must have been created by someone who has never actually visited the place. They have never experienced the traffic roar from the A2, the noise of traffic moving on the A28 or waiting at the series of traffic lights, the polluting dirt and fumes, or the need for giving unbroken attention when negotiating the traffic light system and series of turns if driving, or to adjacent traffic and the pedestrian light systems if walking. All this is made worse in bad weather,

The inadequacy of designing and testing done at a desk is being considered as one of the contributing factors to the Grenfell Tower horror. If Highways England and Kent County Council have actually carried out surveys and measurements at the A2/A28 intersections, we have yet to have news of them. These swept path analyses alone are insufficient for public safety purposes.

Point 4 Residents of Wincheap and Thanington, their residents’ associations and their ward councillors have pointed out to Highways England and Kent County Council the inadequacy and inaccuracy of the developers’ road plans (see Part 3). Highways England’s response could be considered laughable, were it not for the context of road safety. When residents referred to plans including the swept path analyses to illustrate their concerns, particularly for LSTs, Highways England responded thus:

“ ….It is a routine part of our road design process to check that layouts can accommodate turning vehicles. Moreover, depending on the road layout, it is not necessarily the longest vehicle that will have problems. [This puzzled us: we had never implied that shorter vehicles would have no problems.] Therefore we carry out checks for a number of vehicles. [See section 4.2 re types of vehicle omitted.]

“We carry out these checks using vehicular 'swept path analysis' where we plot the extremities of the vehicle concerned for the whole of the turning movement. [We knew that is what the developers’ agents used, and

�30 December 2018

had questioned that use. We were, and are, unaware of any analyses used by Highways England to test or supplement the developers’ agents’ swept path analyses.]

“I attach the current relevant drawings for both the 4th slip (coast bound, left turn from A28 to Ten Perch Road) and the London bound off slip (A28 left in to the new link road down to the development access). [We had already sent these or referred to them our correspondence.] Those numbered 39183 relate to the 4th slip, those numbered 37827 are for the site access/London bound slip. The drawings provided cover the swept paths for refuse, bus and articulated vehicles. [See section 4.2.]

“I hope that these are sufficient to demonstrate that your concerns have been addressed in the design of the scheme.” [No, they were not sufficient. But we were now aware that Highways England had accepted the developers’ agents’ plans as Holy Writ, at the sacrifice of public safety.]

The plans for this, and indeed all the proposed A2/A28 junction changes, are unusual and controversial. Thus they merit particularly careful examination.  Given the facts above, we would suggest that any new road scheme should be future proofed to accommodate all vehicles. At the least, a comprehensive and independent swept path study incorporating worst case scenarios be undertaken prior to proceeding further.

4.2 The swept path analyses of the bellmouth junction

Scattered about various developers’ documents presented with their Applications are “swept path analyses” for various sizes of commercial vehicles. These are used by the developers’ agents who prepare reports on traffic and roads to demonstrate that such vehicles will be able to use the roads affected by or to be built in the course of development. These diagrams are required by the relevant highway authorities, including where applicable Highways England.

The illustrations of swept paths that are included in the documents appear to be “stills” from short videos generated from software programmes in general use in the road design and construction industry, For the each of the Applications concerning the A2/A28 junctions the developers’ agents have produced four sets of swept path analyses for four types of vehicles, with maximum overall lengths, as follows:

1. Articulated vehicle: 16.5 metres, kerb to kern turning radius 6.8 metres.

2. Refuse vehicle: 11.347 metres.

3. Single deck bus: 11.98 metres

4. FTA Design HG Rigid Vehicle (1998) : 10 metres, kerb to kerb turning radius 11 metres.

The maximum lengths chosen in these illustrations for articulated and rigid vehicles are puzzling, The current legal maximums in the UK are:

One truck: 12 metres;

Truck + trailer: 16.5 metres;

Road trains: 18.75 metres.

Longer semi-trailers (LSTs) now being trialled: 18.55 metres (60 ft).

These are extracts showing the bell mouth junction, from the diagrams Peter Brett Associates produced for the new contra-flow system.

The common characteristic of these flow diagram is that none of them show a vehicle actually on an angled turn, though that surely would have been available from the video.

Only the articulated vehicle swept path shows a vehicle o a slight curve, but this is insufficient for reassurance that a vehicle of this length can safely negotiate a 90 degree turning, let alone the 45 degree left turn from the A28 into the contra-flow.

�31 December 2018

Single-deck bus 11.98 metres Refuse vehicle 11.347 metres.

HG Rigid vehicle (1968) 10 metres, kerb to kerb turning radius 11 metres.

Articulated vehicle 16.5 metres, kerb to kerb turning radius 6.8 metres.

�32 December 2018

4.3 Longer semi-trailers (LSTs): press coverage and DfT releases.

This is an LST: 18.55 metres long, with a “kick out” or “tail swing” after the last back wheel that is two metres longer than on a 16.5 metre lorry.

“Hedgehog” of Private Eye picked up on the dubious benefits of these vehicles at an early stage:. Highways England appears to be unaware of the following press coverage and DfT reports.

Road Rage: Trucking up. Private Eye 1292, 22 July 2011 Extracts:

… Longer lorry trailers, if approved, will turn up anywhere, including places their drivers have rarely or never navigated before. Lorries are already involved in most fatal cycling accidents in London, with left turns the most common factor.

The proposed 18.75-metre articulated trucks, … with new trailers (ie exceeding cab units,) …would be 15.65 metres, more than 2m longer than the current maximum, so either the tail would swing out further at corners or the centre of the lorry would swing in more, or both (depending on where the trailer’s wheels are positioned). Cyclists, motorises and pedestrians waiting to cross a road could be in for a nasty, or fatal, surprise.

Councils, meanwhile, will spend public cash to mend assets like signs, kerns and traffic islands that are battered by longer trailers … The government accepts that new kit could be more dangerous that existing kit - unthinkable if a new plane or train were being proposed. But it brushes the problem aside by saying that the number of lorry accidents “is expected to fall” because longer trailers would results in fewer lorry “movements”. ‘Hedgehog’

And continues to keep an eye on them,

Road Rage: LST trips Private Eye 1436, 27 January 2017 Extracts:

The government seems determined to ensure that a “trial” of longer lorries will pave the way for even bigger vehicles to pound our roads.

The “longer semi-trailers” (LSTs) are about seven feet longer that the previous maximum. At short bends, such as T-junctions, the extra overhang behind the rear axle swings far out in the opposite direction from the movement of the cab. There are worrying implications for the safety of other road users, and indeed pedestrians on pavements (Eye 1292), yet the “trial” isn’t addressing the most fundamental question: are LST’s safe on typical A-roads and streets? …

The latest annual report on the trial admits: “We do not currently have detailed data on LST journeys by road type nor for urban or rural environments.” Just two firms mainly serving retail sites provided detailed data - and their LSTs had far more “incidents” per million kilometres than their “regular” articulated trunks did in 2014 and 2015.

�33 December 2018

Despite the longer trucks being focussed - atypically - on motorways and other major roads, the report reveals that in 2015 a pedestrian on the pavement was “hit by the tail end of an LST as it was making a turning manoeuvre in an urban location.” The report says that the truck was on an unusual route to test the driver’s skills, and “the event is not strongly representative of normal LST operations.” So that’s all right then. ‘Hedgehog”

Department of Transport Update January 2017The government has agreed to increase the number of LSTs by an additional 1,000 and to extend the trial by 5 years. This increase will take the number of LSTs from 1,800 to approximately 2,800 over the next 12 months.

Transport Network 30 January 2017 Extracts:“The Department for Transport (DfT) said the trial, which involves approximately 1,800 specially approved trucks, has cut up to 90,000 journeys, leading to cleaner air and reduced congestion.The trial began in 2012 and ministers are consulting on whether to increase the number of vehicles in the trial, as well as extending it.

The trial uses lorries that are up to 15% longer than standard 13.60 metre vehicles, but still meet the existing manoeuvrability requirements and maximum weight limit of 44 tonnes for 6-axle vehicles. Officials said the new lorries are safer and have been involved in around 70% fewer collisions and casualties, per kilometre, compared to the average for standard articulated lorries.

However, the Campaign for Better Transport warned that the vehicles pose a significant road safety risk and should be restricted in towns and cities.

Philippa Edmunds, Freight on Rail manager, said: ‘The Government is continuing to ignore the danger posed by these longer lorries on urban roads. Our concern is that these longer trucks will become the new standard trucks operating on all roads, regardless of the dangers to other road users.

‘We want to see the Government limit their use to designated local authority routes within urban areas to reduce the risks to other road users, protect pavements and property from damage, and reduce the current financial burden of repairs that currently falls on local authorities and taxpayers.’

“Evaluation of the Longer Semi-Trailer Trial: Annual Report 2016A report for the Department for Transport September 2017 Risk Solutions ….

�34 December 2018

Trial outcomes 3: Property damageAnalysis of LST incident rates vs tail-swing measurement• The trial data includes 161 damage only incidents (2012-2016) in which the fact the trailer was an LST was noted as

being, or possibly being, part of the cause. There is limited information on the extent of damage.

• In 2016 we have been able to match the trial data to the trailer ‘model report’ data held by VCA. This allowed us to look for any relationship between the different kick-out (tail-swing) measurements and (damage) incident rates, within the LST fleet.

• Our analysis found no simple relationship between LST kick-out and the overall rate of injury and damage incidents on either trunking or ‘delivery’ routes.

• However, we have recommended that DfT consider studying the rationale behind the adoption of the (many) different trailer designs, including the geometry, axle choice and hence tail-swing measurements. This might provide some insights to inform design guidance in any future expansion of the trial or general roll-out of LSTs (R 2016-4)

Comparison of LST incident rates to other trailers in operator fleet data• A small study suggests that increased risk of property damage collisions compared with standard trailers in the same

operator’s fleet, may occur in some situations. The sample is too small to generalise to the whole LST fleet.

• Because of the small sample, and the choice of operators based on a prior assessment of their likely (higher) incident risk, these results cannot be scaled up to the whole fleet.

• Based on the observations in this small sample, we have recommended further work in this area, with a particular focus on issues of drivers’ awareness when operating LSTs (and other less ‘standard’ trailer types) and route familiarity / frequency. (R 2016-5)

Future focus on damage incident data• Based on the two studies described above, we have recommended that if DfT goes ahead with a revised data

collection framework, the design should collect more substantive damage incident date from all operators. (R 2016-6)

Wider Impact• The results from the data collected on the trial can only reflect the position within the trial fleet and under trial

conditions. Now that we have a substantial trial dataset we recommend that during 2017-19, DfT should plan to conduct initial ‘scaling up’ analysis – applying the data gathered so far on the trial to a theoretical scenario where LSTs were widely available at some point in the future. The would also require work to translate the journey saving results into measures of emissions reduction. (R 2016-7)

• We have also recommended that DfT start conducting evidence based conversations between DfT, the haulage industry and other interested parties such as Local Authorities and civil society groups, regarding what guidance or regulation might be required to maintain the positive results seen on the trial under post-trial conditions. (R 2016-8)

• By making these last two recommendations, Risk Solutions is not stating that the trial data is now ‘complete’ and we are not making a recommendation at this point that LSTs be made part of standard equipment. The recommendations are simply suggesting the exploratory work that could now be started, based on the evidence gathered so far.”

….

Reported in The Loadstar, 22 September 2017:

Philippa Edmunds, Freight on Rail manager, said: “Despite what the DfT claims, longer semi-trailers are not the answer to reducing collisions, congestion or pollution, and are actually more dangerous than standard HGVs on urban and town centre roads because of their 7ft tail swing and extended blind spot. Risk Solutions should be analysing the usage and loading patterns of existing lorries to find out what will happen in real life if these longer semi-trailers are allowed in general circulation.

“There is no question that longer semi-trailers save operators money, but this is because these bigger trucks result in lorries paying even less of the costs they impose on the economy and society, with the taxpayer picking up the bill in terms of more road crashes, road damage, congestion and pollution, and this is simply unacceptable.”

From the Department of Transport’s website September 2018“The trial applies only to roads in Great Britain. Operators wanting to go to Northern Ireland in a longer semi-trailer must obtain an additional VSO from the Department of the Environment Northern Ireland (DOENI). Email vehicle.standards@doeni.gov.uk for details.

�35 December 2018

The longer semi-trailers do not comply with standards in force in other European member states so cannot be used for international traffic in mainland Europe.”

In the most recent Report for DfT the concerns raised by Private Eye, Transport Network and Loadstar are skirted around. Extracts:

“Evaluation of the Longer Semi-Trailer Trial: Annual Report 2017 Summary:A report for the Department for Transport September 2018 Risk Solutions ….

“The trial started in 2012/13 with just a few hundred trailers in the national fleet. At the end of 2017, 1,939 LSTs were on the road and submitting data. [Out of 2,073 registered: i.e. 74% of the 2,800 trial target number.]

Nature of routesThe trial data tells us the start and end of each journey, but not the route travelled. We noted last year that route data would help us understand the extent of LST operations carried out on smaller roads (where there may be higher angle turns (4) and more vulnerable road users) and to localise key emissions results. (4. High angle turns are where HGVs may pose a particular threat to other road users, pedestrians and infrastructure, due to tail-swing. Tail swing is the amount by which the rear of the vehicle swings out as it negotiates a corner and it is often larger for LSTs than standard trailers.) ….

The operations on Minor or Other roads are usually smaller roads at the start or end of a trip. However, the figure shows the Urban / Non-urban split is a fairly ‘blunt’ division; it includes many large A roads that are clearly suitable for HGVs as they go around the edge of towns. ….

Trial safety and damage performanceThe trial results show that LSTs can be operated safely even when used on routes involving some minor roads.Numbers of safety incidents – collisions and casualtiesDuring the five years from 2012 to 2017 there have been 22 road traffic collisions involving HGVs pulling an LST. These have resulted in 10 serious and 21 slight injuries. For many of these, analysis of the events suggests that the type of trailer being pulled was not a factor.Collision and casualty ratesA key question for the trial is whether the LSTs cause more injury collisions than the standard length semi-trailers. There are two parts to this.Q1 How many extra injury collisions would have occurred if the same goods had been moved using standard trailers, requiring more journeys?There will have been a direct safety benefit of around 7% reduction in collisions, equivalent to around 5 collisions and 7 casualties, saved during the period of the trial due to the reduction in the number of journeys.� Q2 Do LSTs have a higher incident rate than the trailers they replace?36This question is about whether the LSTs are having more incidents per kilometre that they DO travel. It is independent of Q1. The LST incident rate on the trial is around 1/3rd of the standard trailer rate when measured nationally AND also when calculated only for the 2.0% of LST operations that are on Minor Roads (both figures confirmed at 95% statistical confidence level).

So LSTs are safe?There is no reason why LSTs should be inherently safer than standard trailers, but on the trial, their incident rate is lower than for other trailers. There are a number of reasons why this might be the case:• The conditions of participating in the trial require that operators provide special driver training for any staff using LSTs• Operators often report paying additional attention to route selection, route assessment, driver selection and driver familiarity with both the LST and the routes• The focus brought by having to submit data on every LST journey probably reinforces their ‘special’ nature, even when, for some operators, they have now been in service for 6 years• The LSTs represent a significant investment that operators do not want to see damaged. …

In last year’s report we looked to see if there is any correlation of damage events with specific trailer design elements, in particular the kick-out, which is itself related to the choice of steering design (self or command steer).Although only very weak statistical correlations to any design feature were found in work undertaken in 2016, we still believe this is an important area that DfT will need to take into account when considering any wider roll-out of LSTs. This is because they will need to decide whether the same range of design features permitted on the trial should continue to be allowed, or perhaps, whether operational restrictions would be applied to certain designs.

We anticipate the rationale for adopting certain designs of trailers to be one of the topics discussed in the industry and stakeholder engagement in Autumn 2018. During the coming year, the focus of the trial will be:1. Induction of new Trailers: Ongoing induction of the extra 1,000 trailers into the trial, which may involve 70 or more new operators. …”

�36 December 2018