PLANNING COMMENT FOR APPLICATION REF:  5/2025/1875

Steven Good

64 Osprey Drive - Representation Part 2 of 2 
St Albans
AL4 0LU

Object to Proposal

This is Part 2 of 2 and should be read alongside my Part 1 submission submitted today.

3.	Concerns about the local highway network

3.1 Transport concerns

My concern is whether the Transport Assessment (TA) and Residential Travel Plan (RTP) provide a robust basis for concluding the proposal would have an acceptable residual impact on the local highway network. Parts of the transport case rely on walking and cycling measures and a strategic east west connection towards Oakwood Drive. The Council should not treat the assumed benefits of that link as committed mitigation unless (i) it is secured through an enforceable mechanism with identified funding and a delivery programme, and/or (ii) the applicant provides quantified sensitivity testing for a realistic scenario where the link is delayed or not delivered.

3.2 Junction 9 as the local constraint

The Sandpit Lane, Marshalswick Lane and Beechwood Avenue junction is the critical local bottleneck. TA Table 48 (Junction 9) reports that in the 2030 Base + Development AM peak scenario Practical Reserve Capacity (PRC) is -37.8%. In the 2030 Base + Development “Do Something” scenario, AM peak PRC remains negative at -26.0%. I request the officer report addresses whether this indicates a severe residual highway impact, and whether the assumed mode shift and mitigation package is realistic and robust, particularly if the Oaklands Grange to Oakwood Drive connection is delayed or not delivered. The TA indicates that impacts at Junction 9 are intended to be addressed through sustainable transport measures facilitating modal shift, which increases the importance of securing the key measures relied upon. 

Have planners considered why there could not be a second vehicular exit to South Drive and Hatfield Road, as reported in the TA to operate within theoretical capacity? A route could run along the proposed public right of way to the west side of the college buildings from the south of Oaklands Blossom. The TA indicates Junction 6 (South Drive and Hatfield Road) operates within theoretical capacity, with RFC values below 0.5.

3.3 Missing east west sustainable connection towards Oakwood Drive

The TA states there is currently no dedicated sustainable transport route from the proposed development through Oaklands Grange, across the playing field to Verulam School and onward towards Oakwood Drive. This is material because the deliverability and attractiveness of the walking and cycling network underpins the assumed mode share and the RTP approach. If the assessment relies on this connection as part of the walking and cycling improvements package, the Council should treat it as mitigation only where delivery is secured (enforceable mechanism, funding and programme), and/or where quantified sensitivity testing is provided for a realistic delayed or non delivery scenario.

3.4 Scenario 2 reliance in the RTP

The RTP states its target modal split is based on Scenario 2 in the TA, and Scenario 2 relies on the Travel Plan plus a comprehensive package of walking and cycling improvements. The officer report should explicitly test whether the measures relied upon to support the anticipated mode shift include a direct, attractive and deliverable route towards Oakwood Drive and other key destinations and, if so, whether that element is secured or sensitivity tested. Absent that, the Council cannot treat the modelled mitigated outcomes as robust for decision making. 

3.5 Evidence base and dependency

Highway Authority consultation material in the TA appendices records that the east west cycling corridor and a connection towards Oakwood Drive are intended to be delivered via a path through the Verulam School playing fields; that a route to Oakwood Primary School is being investigated; and that delivery is subject to securing the connection. The same material records Oaklands Grange has a section 106 contribution towards a cycle and pedestrian facility between that development and Oakwood Drive, but this is unlikely to cover the full cost, and this development should also contribute as it will benefit from and rely on that link. The Design and Access Statement (p57) shows the pedestrian and cycle link in the connectivity strategy. The RTP shows Oaklands Grange to Oakwood Drive as a Proposed Pedestrian Route in Figure 3 (purple dashed) but a contribution to completing this is not shown in RTP 2.5.2 (infrastructure to be provided) nor RTP 2.7.2 (identified mitigation measures).

3.6 If approval is recommended: enforceable securing mechanism

Failure to deliver has been an issue observed with the Oaklands Grange development and prior commitments. If approval is recommended, I request a condition and/or section 106 obligation that secures delivery and full funding of the Oakwood Drive connection, including whether this is secured through planning obligation and/or condition, the trigger points, funding amounts, and a delivery timetable.