Further Responses


Objectors to the scheme have made further responses, to issues that arose during the Examination.


These are some of the responses:


From Alan James:

·      The plans of the proposed link between Halton Road and Shefferlands roundabout have only just been released. The design fails to meet the mandatory standards in 3 ways, which makes it technically unacceptable:

Ø The gradient is 9%, but the absolute maximum allowed is 8%.

Ø There is not enough “flattening out” at both ends.

Ø The visibility splay at Halton Road is inadequate.          

AJ comments on Halton Road link at Shefferlands.pdf


·      Otter surveys have been inadequate. Natural England would be acting illegally if it granted a licence to destroy the bat roost at Croskell’s Farm (P&R site)

·      Halton traffic flow “remodelling”, really a revised forecast, which reduces the forecast increase in traffic on Church Brow from 74% to 44%, is full of anomalies, and invalid.

·      Induced traffic will be much higher than LCC admits.

·      Changes to Junction 34 are departures from standard which HA have not adequately explained.

·      DfT evidence shows that young people are using cars less, contributing to the trend known as “Peak Car”.

 AJ comments on responses 24 July.doc

·      Case law that an option cannot be rejected on the grounds that it would require an “appropriate assessment”.

AJ Thames Water Inquiry information.pdf


From John Whitelegg:  

·      CO2 emissions from road transport in Lancaster declined by 9.5% from 2005 to 2009. This indicates that road traffic levels also went down, which undermines the case for the road.

JW A note on CO2 emissions.doc


·      Induced traffic (“liberating suppressed demand”) will be higher than LCC admits, greatly reducing the forecast time-saving benefits of the new road.

JW A note on induced traffic.doc


On otters:

·      From Halton Residents, presenting clear evidence of the presence of many otters, which LCC has failed to survey.

otters response from M Jacob Sept 12.doc

·      From Andrew Gardner (Envirotech), confirming the presence of otters, and LCC’s failure to carry out a proper survey.

Otters letter from A Gardner Sept 12.pdf

·      From TSLM, pointing out that it would be illegal to permit the scheme to continue based on an inadequate survey of a species protected by European law.

Otter Surveys TSLM comments on LCCHD10.doc


On traffic:

From Prof. Phil Goodwin

·      Traffic has grown much less than expected, or not at all. This is a local, national and international trend, and research indicates that it will continue.

·      If forecast traffic growth rates are lower, so are the estimated benefits of a scheme. A small reduction in traffic growth results in a bigger reduction in benefits, and an even bigger reduction in the Benefit to Cost Ratio (BCR).

·      LCC were asked to run a traffic model assuming low growth. They failed to do so, but their figures indicate that if they had, it would produce a Benefit to Cost Ratio (BCR) of only 2 or 3.

·      Low or no growth (“Peak Car”) is due to many factors: new technology, better public transport, and young people starting to drive later. It began well before the current downturn. It should be taken into account when justifying a new road.

p goodwin.doc


From NW Transport Roundtable (NWTAR) and Campaign for Better Transport (CBT):          

·      The Examiner asked LCC to run a model of low growth or no growth in traffic, but they have not done so.

·      They do not really address the possibility of “Peak Car” – that we may have reached saturation in car use.

·      This severely undermines the robustness of the transport and economic case for the road.

nw tar.DOC