OBJECTION SUBMITTED ON BEHALF OF THE GATEACRE SOCIETY
2. FAILURE TO DEFINE THE OBJECTIVES OF THE SCHEME
Department for Transport guidance (Circular 01/2013 p3) is that "Speed limits should be evidence-led and self-explaining and seek to reinforce people's assessment of what is a safe speed to travel. They should encourage self-compliance. Speed limits should be seen by drivers as the maximum rather than a target speed. Traffic authorities set local speed limits in situations where local needs and conditions suggest a speed limit which is lower than the national speed limit".
Liverpool City Council's argument (SOR p1) is that a 20mph speed limit is necessary in Gateacre Park Drive "in order to reduce traffic speeds in the vicinity of the new supermarket ... improve safety in the vicinity of the new supermarket by reducing vehicle speeds and by aiding safe pedestrian access to the store".
The letter to residents from Amey, in February 2014, stated: "As part of the planning conditions for the new store, Aldi had to agree to fund a traffic calming scheme in the area".
LCC's Highways Department told us, in October 2013 (ESW p1): "It is for the Highway Authority to consider what is necessary under a s278 agreement. ... The developer did not provide a minimum accessibility standard assessment therefore Highways undertook a 'desktop assessment' and this revealed that there were barriers to pedestrians and cyclists. ... There is no copy of the desktop assessment to provide you with as this was only a desktop exercise".
If the proposal is indeed 'evidence-led', then we have yet to see the evidence. Our understanding is that a Section 278 Agreement is meant "to mitigate the impact of the development on the existing road network". We are puzzled as to why speed cushions in Gateacre Park Drive were seen to be desirable, rather than, for example, an HGV ban to prevent Aldi delivery vehicles using Grange Lane.
3. FAILURE TO PROVE THE NEED FOR THE SCHEME
LCC's Highways Department told us (ESW p7) that "Agreement was reached between the developer and the Highway Authority as to the extent of the measures necessary". In response to our request for a copy of the assessment of the need for traffic calming measures, they referred us to a document on the Council's Planning Explorer website. However, we discovered that this document - the Transport Statement produced in 2013 by Cameron Rose for Aldi Stores Ltd as part of planning application 13F/1272 - states (para.5.2.1):
"As the proposed development dramatically reduces the potential vehicular attraction of the site, it is now considered that the need for traffic calming of Gateacre Park Drive ... is not required".
Although reference is made, in the SOR, to 'barriers to pedestrians', no explanation has been given as to how the proposed measures will aid pedestrian movement. Although reference is made to 'safety' problems, no evidence of a high accident rate in the vicinity of the new Aldi store has been produced. And although it is stated (SOR p2) that "pedestrian movements across Gateacre Park Drive [are] likely to increase due to the construction of the new supermarket [and] any continued speeding would put crossing pedestrians at risk", it fails to add that the increase in vehicle turning movements in and out of the car park will itself act as a deterrent to 'speeding'.
No explanation has been given as to why Gateacre Park Drive is considered especially appropriate as a 20mph zone. Gateacre Park Drive was constructed in the 1960s as a through route. It is not a 'residential street' or a 'shopping street' in the usual sense. Its wide pavements and grass verges keep pedestrians well away from the passing traffic.
CONTINUED . . .