Traffic Regulation Committee 14 October 2008 Agenda Item...

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Traffic Regulation Committee 14 October 2008

Agenda Item No.6

GLOUCESTERSHIRE COUNTY COUNCIL (LORRY MANAGEMENT AREAS WITHIN GLOUCESTERSHIRE)

(7.5 TONNE MGW RESTRICTION) ORDER 2008

1. Purpose of Report

To provide background information on the development of the Cotswold’s AONB Freight Management Strategy (CFMS) and to consider objections to the area wide Lorry Management Zone (LMZ) Order.

2. Recommendation

That the Gloucester County Council (Lorry Management Areas within Gloucestershire) (7.5 Tonnes MGW Restriction) Order 2008 (“the Order”) be made with the following amendments made in response to representations and objections received. The Order to include reference to access:

• To HGV operators licensed operational base;

• For horseboxes; and

• For forestry activities.

This is subject to any further modifications also proposed by the Traffic Regulation Committee. The Order and an explanation of the changes made from the Order are shown in Appendix A.

3. Resource Implications

The total cost for the development of the Strategy and implementation of an area wide LMZ will be close to £500,000. This figure includes both the capital cost of materials required to deliver the LMZ as well as the collection, collation and analysis of a substantive range of quantitative and qualitative data considered essential to the development of a robust Strategy. Implementation costs constitute in the order of £335,000 of this total cost. Further breakdown of this cost, together with further ongoing cost implications to ensure the ongoing momentum of the LMZ and the CFMS are set out as follows:

• Sign design - £25,000;

• Sign manufacture and implementation - £220,000;

• Communications (including general liaison, TRO consultation, strategy development, launch) - £65,000;

• Future monitoring, evaluation, coordination, reporting and engagement costs (reference Monitoring and Management Strategy provided as Appendix G):

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o Traffic data collection - £5,000 per year with additional £8,000 every 3-5 years

o Questionnaires re. Public/Operator perceptions - £1,000 per year; and o GCC coordination, reporting and engagement role – ½ day per week of

a Transport Planner (cost not included in these figures).

4. Statutory Authority

The Statutory Authority for Traffic Regulation Orders is contained within the Road Traffic Regulation Act 1984. Orders are progressed in accordance with the Local Authority’s Traffic Regulation Order (Procedure) (England and Wales) Regulations 1996. The Statutory Authority for signs and road markings are by virtue of the Traffic Signs and General Directions 2002.

5. Departmental Contacts Lawrence Elcocks, Network & Traffic Manager Telephone number 01452 425564 Email [email protected] Patrick Tiffney, Project Manager, Gloucester County Council. Telephone number – 01452 425639 Email - [email protected]

6. Background Papers None. 7. Report 7.1 Background Overview

Reducing the impacts of freight on the quality of life of Gloucestershire residents is identified as a priority in the Gloucestershire Local Transport Plan (LTP). Appendix H in the LTP sets out the requirement for area wide lorry restrictions in a number of areas. The first area to be considered is the Cotswold’s Area of Outstanding Natural Beauty (AONB) within the County. The Traffic Regulation Orders (TRO) and associated signs, which are the subject of this report, are required to enforce the first Lorry Management Zone (LMZ) for the Cotswolds AONB. To help lorry drivers and operators understand which routes are preferred for use by HGVs the County published an Advisory Freight Route Map in April 2005 (reference Appendix E). The evidence collected in the development of the LMZ shows that a significant proportion of HGVs on the A46, A4173, A435 and B4008 ignore or are not aware of the routing advice set out on the Advisory Freight Route Map. The map, which was drawn up by the Freight Quality Partnership (FQP) which includes representatives of the Freight Transport Association (FTA) and Road Haulage

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Association (RHA) who have both objected to this TRO, is the basis for the LMZ. The map shows that the routes within the zone and which will be subject to restriction – the A46, A4173 and A435 are for ‘access and diversion’ only. The A419, A417, A429, A436 and M5 are shown as routes for longer distance journeys. Freight industry representatives have acknowledged that congestion on the A419 to the west of Stroud and at the A417 Air Balloon roundabout is a significant factor in vehicles using the A46, A4173, B4008 and A435, in contravention of the Advisory Freight Map. The proposals contained within the LMZ have been modified to reduce their impacts on the freight industry compared to those policies which were included in the LTP, in particular the potential for night time curfews. This is discussed in further detail in Section 7.4 of this Report. The signing and enforcement will result in a forecast decrease of 47%, 37%, 37% and 27% on HGVs on the B4008, A4173, A46 and A435 respectively. These reductions will lead to modest, yet significant, environmental benefits on those routes. There will be a forecast 17% increase in HGVs on the A419 to the west of the B4008 and a 7% increase on the A419 between the A46 and B4008. HGV flows are also forecast to increase by 0.6% on the A417. Development of the Lorry Management Zone Atkins Consultants were commissioned by Gloucestershire County Council in September 2006 to assist in the development of the Lorry Management Zone. The commission comprised four phases:

• Phase 1: Stakeholder Identification – Establish freight operators, community contacts and network manager contacts;

• Phase 2: Stakeholder Consultation - Establish key issues for communities and hauliers, undertaking of audits of routes and signing, obtaining traffic, accident and classified traffic survey and origin-destination data;

• Phase 3: Detailed Analysis and Development of Strategy – Collation and analysis of all information and data to establish key facts to inform the development of the Strategy and specific objectives; and

• Phase 4: Lorry Management Zone – Design and implementation of the LMZ. The key facts to emerge from Phases 2 and 3 were presented to the FQP and comprised:

• HGV signing of restrictions and preferred routing is ambiguous;

• There is a generally poor understanding of the role and importance of freight for the community;

• A significant proportion of ‘through’ HGV journeys on A46, A435, A4173, B4008 could be made on a more suitable route;

• Air Balloon roundabout and A419 to west of Stroud are locations of significant congestion which affects HGV routing;

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• Awareness of the Advisory Freight Map is low; and

• Small number of SATNAV incidents give the freight industry a poor profile.

To provide direction to the development of the Cotswolds AONB Freight Management Strategy (CFMS), of which this first Lorry Management Zone forms an important part, a number of objectives were agreed in consultation with the FQP. These are set out overleaf.

• Identify and maintain freight routes that enable the movement of freight in a safe and economically efficient manner, and ensure widespread awareness of these routes by the freight industry;

• Reduce the impact of HGVs on the part of the road network that is used only for local access;

• Reduce the frequency and severity of incidents relating to mis-use of SATNAV;

• Ensure that people living, working in and visiting towns and villages are fully aware of the role of road freight; and

• Identify a series of actions to encourage the delivery of additional road capacity for freight on through routes, particularly the A419.

In the light of the identified problems and issues and the objectives defined in consultation with the FQP, the CFMS contains the following:

• Signing Strategy: Area based 7.5t weight limit restriction ‘Except for Loading’ on all routes that are not for ‘Local’ or longer distance use as specified on the Advisory Freight Map (NB ‘Local’ in this context refers to journeys that have either their destination or origin within Gloucestershire).

• Communications Strategy: A Strategy that will engage with Hauliers and the Local Communities during implementation and ongoing, providing an understanding of the role and function of freight and the routing options.

• Engineering Measures: GCC to identify and include schemes in their capital programme, subject to value for money assessment, which help freight and reduce it’s impacts (e.g. enhanced maintenance of A419 east of Stroud, between Ham Hill Lane and Brimscombe, and between Dark Lane and Marle Hill)

• Information: Redesign and promotion of Advisory Freight Route Map and the GCC Freight website;

• SATNAV: Liaison with Ordnance Survey and Regional Freight Forum to provide assistance in their development of Freight SATNAV; and

• Investment: Engage at a regional level to secure investment at the Air Balloon Roundabout.

The main outcomes from these Strategy elements, assuming full enforcement of the Signing Strategy, would comprise:

• Reductions in HGV flows producing significant environmental benefits over a substantive area: o A46 Painswick – 37%; o A435 Between Severn Springs and Stratton – 27%;

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o B4008 between J12 and A419 – 47%; and o A4173 Gloucester to Pitchcombe – 37%.

• Increases in HGV flows producing less significant environmental effects restricted to short sections of route: o A419 west of its junction with the B4008 – 17%; o A419 between its junction with the B4008 and A46 – 7%; and o A417 north of Stratton – 0.6%.

• Reduction in SATNAV incidents;

• Improved understanding of freight routes by haulage industry;

• Improved understanding of the role of freight in community; and

• Improved conditions for freight operation in the longer term. Subject to TRO approval, implementation of the signing to support this first Lorry Management Zone is programmed for completion in January 2009. Given the importance of enforcement in the realisation of the objectives of the Lorry Management Zone, assurance has been obtained from Gloucestershire Constabulary that enforcement of existing and future weight restrictions will be given a significantly higher priority and GCC is developing a robust Monitoring Strategy in order to guide and support this process.

7.2 Representations and Objections Representations

In total GCC has received 44 representations in relation to the Lorry Management Zone; 20 prior to the formal TRO advertising period and 24 during the TRO advertising period (11 August-2 September 2008); 11 were from Parish or District Councils, 17 from members of the public, 12 from Operators/Hauliers and 4 from the Road Haulage Association (RHA)/Freight Transport Association (FTA). Seven of the representations from members of the public were from one individual who also made two Freedom of Information (FOI) Requests within the TRO advertising period and submitted a list of nine further questions to the Project Team when attending one of the TRO Manned Events. Three Manned Events were hosted by the Project Team during the TRO advertising period, in Brockworth, Stroud and Cirencester. A total of 22 people attended these evening events; 4 Parish or District Councils representatives, 1 County Councillor, 8 Hauliers/Operators and 9 members of the public. In addition, representatives of the RHA and the FTA were present at all events and a representative from Moreton C Cullimore and Son Hauliers attended two events. Eleven of the representations received during the TRO advertising period constituted completed Feedback forms which were made available at the Manned Events. The majority of the representations received were requests for further information, in particular confirmation regarding access to/from an operational base, impact on an existing TRO in operation within the LMZ or raising concerns regarding associated enforcement. Any concerns or issues raised in these representations with regard to access and exemptions were addressed either by return, or through minor

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amendments to the Draft TRO, as detailed in Section 7.3. Eight of the 11 Feedback Forms received in response to the Manned Events stated favour for the scheme, two were unsure and only one was not in favour, although this member of the public (resident of Box) did not cite a reason. Objections Ten of the representations made have been lodged as formal objections to the TRO. All these objections are provided in Appendix B. Two of these were from the same member of the public who has also written several letters and submitted the FOI requests, as previously detailed. This has been considered as one objection. All formal objections have received confirmation of receipt as well as a full response to all issues as presented and these letters are provided in Appendix C. It is proposed that one of the objections, submitted by the Fleet team manager of Kuehne and Nagel Drinks Logistics, is directly addressed by the modifications to the Draft TRO (as detailed in the following Section 7.3) which clarifies legitimate access for loading and loading as well as to/from an operational base within the LMZ. Another of the objections was submitted by Max Engel Solicitors, on behalf of a client.. The letter stated that further detail regarding the specific nature of the objection could be expected within ten days of this stated objection, but no such clarification has been received to date. The remaining issues, as collated from the other seven objection letters (reference Appendix D), are set out in summary as follows, together with a brief response in each respect: 1. Apply an 18 tonnes restriction rather than 7.5 tonnes as this is the type of vehicle

that causes the greatest problems. Response – Increasing the restricted weight would mean that the reductions in HGV traffic would be some 10% rather than in the order of 30% forecast for a 7.5 tonnes restriction. This would significantly diminish the already modest benefits.

2. ‘A’ class roads are for long distance traffic and should therefore not be subject to

weight restrictions.

Response – There is no legislation or guidance that supports this view. The ‘A’ roads (A46, A4173 and A435) proposed to be subject to restriction are all identified in the Advisory Freight Map, as agreed with the RHA and FTA as routes for access and diversion only. A regional freight map, also agreed by the haulage community, supports the proposed restrictions as well. Furthermore Government Office for the South West have favoured weight restrictions over de-classification for ‘A’ roads in the past elsewhere in the County.

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3. Air Balloon Roundabout and A419 areas of congestion to be addressed before restrictions put in place.

Response – The impacts of the re-routed traffic from the A46, A4173, A435 and B4008 would have a very small impact on the existing levels of congestion at these locations. It is worth noting that the Highways Agency has not objected to the increased traffic on the A417.

4. Origin and Destination studies not carried out on all ‘A’ and ‘B’ routes subject to

weight restriction to reliably establish the extent of ‘through’ movements.

Response – Either origin and destination surveys (where vehicles are stopped and asked for their last and next stops) or registration number surveys (where registration numbers are matched to identify ‘through’ movements) have been carried out on the A46, A4713, A435 and B4008.

5. Scale of reduction of HGVs on A46 and A435 not sufficient to justify costs of

signing. Response – The reductions in HGVs will lead to some modest improvements in the quality of life of residents including a reduction in intrusion, improvements in tranquillity and improvements in safety and intimidation to non-motorised users. Other benefits would include lower mortality risk to fauna in areas of high biodiversity and a reduced level of urbanisation in the deeper areas of the AONB. On balance it is considered that the scale of the signing, restrictions and increases in HGV flows are proportional to the benefits forecast for the zone.

6. Additional administrative workload for hauliers operating legally.

Response – Hauliers who are operating legally within the zone may have to respond to members of the public and Trading Standards enquiries, justifying their presence in the restricted area. Whilst ‘public relations’ of this type are a requirement of many businesses, the County Council does acknowledge that this is a legitimate area of concern. As a result it is suggested that a Proforma could be developed and provided by the County Council for completion by the Operators in response to enquiries. The County Council also anticipates that raising the profile of the need for freight in the AONB to deliver essential goods and services would also reduce the potential for complaint.

7. Strategy will force HGVs to travel in more congested conditions with the result

that there will be impacts on CO2 emissions and air quality.

Response – Assessments undertaken to establish the air quality impacts, in line with Government guidance, have indicated there will be no significant impacts on air quality. An assessment of the increase in CO2 emissions has found that there will be a maximum increase of 0.5% in CO2 in the zone as a result of the restrictions. On balance this is considered acceptable given the reductions in HGV related impacts on the A46, A4173, B4008 and A435.

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8. Increase in sign clutter in AONB.

Response – A significant number of signs are being removed as part of the Signing Strategy. The net increase in signs, some 31, is considered proportional to the benefits. Neither Cotswold or Stroud District Councils or the AONB Board have objected to the proposals.

9. Restrictions will force vehicles onto routes with a poor safety record.

Response – The route to which this comment refers, the A417, is in the ownership of the Highways Agency who have been consulted on the proposals, and who have not registered an objection.

10. The inability of the police to easily enforce the restrictions for vehicles registered

outside the UK means that the restrictions will be ignored and are therefore not worth implementing.

Response – The proportion of foreign vehicles using, for example, the A419 and other routes within the proposed zone is very small; only one foreign registered vehicle was observed in the Origin and Destination surveys. It is acknowledged that there is a difficulty in enforcing the law for these vehicles, but that is an issue for central and European Governments.

11. The routes subject to restrictions will be required for diversion.

Response – The diversion routes are agreed with the Police and the local GCC Stakeholder Managers. HGVs can be diverted onto restricted routes by a Police Officer although the diversion routes identified for the A419 and A417 do not include use of those routes. The Strategy includes a Police liaison element to ensure that the Police know which routes are appropriate (as determined by their physical ability to carry freight vehicles) and which are not. Diversion must not be permitted to avoid congestion as a result of day to day operation of the network. Diversions in place, as agreed with the Police and local Gloucestershire County Council Stakeholder Managers , are set out as follows.

•••• A419 Closures: Between Cirencester and Stroud the diversion route is the A417/M5 and between Stroud and the M5 the diversion route is M5/A417;

•••• A417 Closures: Between Birdlip and Cirencester the diversion is A436/A40 to Northleach and then the A429 to Burford Road junction.

12. Lack of clarity as to criteria for success of Strategy.

Response – Criteria are as follows:

• Reduction in number of HGVs on the A46, A4173, A435 and B4008 by 37%, 37%, 27% and 47% respectively;

• Perception by residents, workers and visitors to towns and villages on these routes that numbers, size and impacts of freight vehicles are acceptable;

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• Perception by freight industry that there has been no detrimental impact on their business as an outcome of the implementation of the Zone.

13. Strategy objectives are poorly defined in the Statement of Reasons and no

credible evidence base is presented to justify the objectives. No evidence to show that the proposed restrictions will achieve objectives of the Strategy.

Response – The Statement of Reasons includes the following statement:

‘This Strategy seeks to balance the need to minimise the impact of freight movement upon local communities and environments through which they pass and in many cases service, whilst at the same time providing operators and hauliers with a safe and efficient route network.’ It is acknowledged that this is a summary of the objectives of the Strategy. Such a summary is appropriate for the Statement of Reasons document, particularly when consultation on the TRO included manned exhibitions intended to provide more detailed evidence and an opportunity to discuss the Strategy with representatives of the Project Team. The objectives of the Strategy were developed following an extensive data gathering process including public consultation and engagement with the FQP. These objectives, which were agreed with the Freight Quality Partnership and how these will be delivered by the Strategy, are set out as follows:

• Identify and maintain freight routes that enable the movement of freight in a safe and economically efficient manner, and ensure widespread awareness of these routes by the freight industry (Delivery: Re-publication of the freight map for the study area, reinforcing the ‘through’ routes for freight. This map will also be available on the County Council website and will be publicised at the launch stage of the Strategy. Consideration will be given to the translation of the map into a number of European languages);

• Reduce the impact of HGVs on the part of the road network that is used only for local access (Delivery: Through use of 7.5 tonnes weight restriction order applied across the area (with exemptions for loading, unloading and access to operational base) which will reduce the volume of HGVs by between 27% and 47%);

• Reduce the frequency and severity of incidents relating to mis-use of SATNAV (Delivery :Through the use of signing and enforcement);

• Ensure that people living, working in and visiting towns and villages are fully aware of the role of road freight (Delivery:Through the communications element of the Strategy which is part of the launch stage); and

• Identify a series of actions to encourage the delivery of additional road capacity for freight on through routes (Delivery:Through targeted improvements in the longer term. Work is underway to determine the feasibility of a modest increase in capacity on the A419.)

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14. The Order as drafted makes no allowance for access to operational bases within the zone.

Response –The Order has been updated to contain specific reference to address this issue.

15. There is a conflict of interest with Atkins being involved with both the design of

the Strategy and its implementation.

Response – There is no conflict of interest. It is common practice for consultants to undertake both strategy work and to implement those strategies for Highway Authorities in the UK.

16. Lack of Environmental Assessment.

Response – Environmental assessment of the project comprises two distinct elements, assessment of the Strategy and assessment of the signing/HGV diversion effects. The former has been addressed through the Strategic Environmental Assessment undertaken as part of the LTP appraisal process. With respect to the latter ‘scheme based’ assessment the County Council requested a screening opinion on the need for an assessment, which found that such an assessment is not required.

17. County Council should be addressing the backlog in changes to the Definitive

Map Modifications rather than the Cotswolds AONB Freight Strategy. Response – The County Council is addressing both the definitive Map Modifications and the Cotswold AONB Freight Strategy.

18. The Cotswolds AONB Freight Strategy, and the Lorry Management Zone

proposals, discriminate against those who live or work adjacent to, or travel on, the A419 to the west of Stroud, particularly those west of the B4008 junction where the percentage of HGVs in forecast to increase by 17%. Using statistics masks the real change.

Response – It is acknowledged that the percentage of HGVs will increase on certain sections of the A419. However HGVs will transfer to the A419 primarily from the B4008 (94 HGVs per day), which is currently subject to a 7.5 tonne weight limit, and which passes through the centre of Stonehouse which is particularly sensitive to HGV traffic. HGVs will also transfer from the A4173 (37 HGVs per day) and the A46 (33 HGVs per day). Both the A46 and the A4173 are identified as routes for access and diversion only (i.e. journeys with origins or destinations in the LMZ) whereas the A419 is identified as a route for ‘local’ journeys which in the context of the LTP is generally taken as longer journeys which either start or finish in the County and can be considered as ‘through’ journeys in the context of the LMZ. The environmental effects of HGVs are closely related to the percentage change in HGV flows. There is little scientific evidence to clearly identify the threshold for when the percentage change becomes particularly noticeable, although 30% can

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be taken as a useful indicator. In that context the LMZ will lead to a reduction of 47%, 37%, 37% and 27% in HGVs on the B4008, A46, A4173 and A435 respectively (a total length of approximately 45km). The LMZ will also lead to a 7% increase in HGVs on the A419 between the A46 and B4008 and a 17% increase between the B4008 and M5 (a length of approximately 8km). This clearly produces a net benefit in terms of an overall reduction in HGV% in the AONB. Furthermore, that increase is restricted to the A419; a route identified for longer distance journeys. To reduce the environmental impacts of existing HGVs, and those arising from the re-routing effects of the LMZ, the A419 has been identified in the CFMS as a route to receive additional investment. Major structural maintenance is due to start in February 2009 on the A419 East of Stroud between Ham Hill Lane and Brimscombe, also between Dark Lane and Marle Hill and further measures will be considered in the longer term. Statistics have not been used to mask real change but rather to enable comparative appraisal and account for daily, monthly and annual fluctuations in traffic flow. Central government guidance on a wide range of environmental impacts has been developed to acknowledge and measure real environmental impacts in a meaningful and effective way.

19. Air quality impacts leading to net worsening.

Response – An assessment of the air quality impacts of the signing and re-routing elements of the Strategy has been undertaken in line with DfT guidance and has found that there are no significant air quality impacts.

20. No mention is made of specialist surface treatments to reduce the noise impacts

of HGVs.

Response – The network improvement element of the Strategy was at a level of detail commensurate with the overall Strategy and so did not address the detail of carriageway surfacing. Whilst the precise details of the maintenance regime for the A419 are yet to be developed, and subject to a value for money appraisal, the use of the new generation of materials for road surface overlays which reduce the generation of road noise will be considered.

21. Different signage could be used to address SATNAV issues.

Response – As part of the data gathering process for the development of the Strategy an alternative sign configuration with a satellite navigation theme, as used in the Vale of Glamorgan, was considered (reference Appendix F). However, in the light of consultation with Officers in Gloucestershire County Council, and also following a review of the evidence for alternative signing, it was concluded that the sign was potentially confusing for HGV drivers as well as requiring a lengthy agreement process with the Department for Transport, with no guarantee of success.

Given that a key facet of the Strategy is clear signing and enforcement, particularly for vehicles registered outside the UK, the County Council will maintain an active interest in signing developments relating to managing HGV

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movements elsewhere in the UK with a view to incorporating such signs into the Strategy should the evidence support it. The County Council will also be following the DfT review of signing which has recently started, which promises to be the most significant review of signing over the past 40 years.

7.3 Amendments to the Draft Traffic Regulation Order A number of minor amendments are proposed to the LMZ Draft TRO as advertised. These are to address a total of three representations and objections and were set out in Section 2. In addition to these changes a number of (7) minor presentational changes are required to ensure the TRO is consistent with existing TROs already in place in the zone. 7.4 Discussion Given the nature of the objections and that all the objectors concerns cannot be alleviated through minor alterations to the LMZ TRO this scheme is referred to the TRO panel for its consideration. The responses to the objections, as set out in Section 7.2 of this report, have addressed many of the issues associated with the development and implementation of the Strategy. However, there are a number of other matters worthy of consideration by the TRO panel. These are set out as follows and then considered in turn.

• Consideration of Alternatives;

• Mitigation; and

• Monitoring and Management. Consideration of Alternatives The LTP contains a number of policy statements that were subject to review through the development of the Strategy. Of particular relevance is the use of a night time curfew to reduce the impacts of freight in settlements on the A46, A4173, A4173 and B4008. Whilst offering substantive benefits through the reduction of night time noise (due to the low numbers of HGVs travelling at that time in the AONB the impact of isolated vehicles is significant), the impacts on the freight industry and local business was considered to be particularly onerous. As a result that particular policy was abandoned. The LTP also contained a policy statement referring to the reduction in HGVs on all rural roads. The Strategy has addressed this issue and concluded that the fairest arrangement would be to restrict any increases in HGV traffic to those sections of the highway network that are allocated a role in the network hierarchy that is appropriate to longer distance (and higher volumes) of freight traffic. The routes forecast to experience an (insignificant) increase in HGV volumes are the A417 and A419, which are both identified in the LTP and Advisory Freight Map as having a more significant role than the A46, A4173, A435 or B4008 routes.

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An alternative to the area wide approach would be to use complete prohibitions at certain locations on the A46, B4008, A4173 and A435 to compel HGVs to keep the extent of their journeys in the Zone to an absolute minimum. Whilst this option was not considered in any detail, a preliminary assessment concluded that the impacts of such an arrangement on the freight industry would be unreasonable. It was therefore excluded from further consideration. Mitigation There is a requirement for mitigation of both existing and future impacts of HGVs and, furthermore, to mitigate existing levels of delay experienced by the freight industry which contribute to HGV routing patterns in contravention of the advisory routes shown in the Freight Map. The CFMS identified, for example, the need for improved maintenance to the A419 to reduce the environmental impacts of existing HGV movements. A number of potential interventions were identified including the resetting of noisy manhole covers. The County Council will also, as previously detailed, be undertaking major structural maintenance on the A419 east of Stroud between Ham Hill Lane and Brimscombe and also between Dark Lane and Marle Hill, in February 2009. The County Council has also commissioned a study, which is currently underway, to investigate the potential for short and medium term capacity improvements to the A419 to the west of Stroud to reduce existing levels of congestion. The A417 is a trunk route and is therefore in the ownership of the Highways Agency and not part of the County Network. However, it represents a key route within the proposed area wide LMZ and, as such, a detailed assessment of the impact of this restriction on both the safety and operation of this route, and all others within the area, has been undertaken as part of the Study. Whilst the level of service offered by the A417 within the vicinity of the Air Balloon roundabout is acknowledged to be below that which is normally associated with routes of that level in the hierarchy, there is an identified scheme to address the capacity issues at this location. Scheme delivery is dependant on funding being identified from the Regional Funding Allocation, although currently the improvements at this location are not identified as a priority in the RFA programme. Monitoring and Management Appendix G contains a draft Monitoring and Management Strategy for the CFMS. A particular point to note from this Strategy element is the need for ongoing officer time to coordinate enforcement, engagement and monitoring activities which is considered fundamental to ensure the ongoing development, momentum and overall success of both the LMZ and the wider Freight Management Strategy.

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7.5 Conclusions The LMZ and CFMS proposals are the product of some two years work by Atkins, the consultant commissioned by the County Council to develop this key strand of the LTP. The study has undertaken an in-depth analysis of all aspects of road freight within the proposed LMZ. The proposals have been developed through consultation with the Parishes and HGV Operators in the study area. The signing and enforcement strategy which will ensure that the objectives of the CFMS are met, has been designed to deliver modest benefits to those who suffer the impacts of HGVs on the A46, B4008, A4173 and A435 whilst keeping the impacts on the A419 and A417, and the inconvenience and additional costs to the freight industry, to a minimum. The Traffic Regulation Order, which will support the LMZ and which is the subject of this report, is firmly based upon the existing network hierarchy which was agreed with the freight industry in 2005. On balance, the Traffic Regulation Order, signing and enforcement measures set out in the CFMS are considered to provide a fair and reasonable approach to managing HGV movements in the AONB and are considered to offer the County Council good value for money.

Duncan Jordan - Executive Director: Environment

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Appendix A Copies of:

• Traffic Regulation Order

• Notice

• Statement of Reasons

• Plan Numbers

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Traffic Regulation Order

GLOUCESTERSHIRE COUNTY COUNCIL (LORRY MANAGEMENT AREAS WITHIN GLOUCESTERSHIRE)

(7.5 TONNE MGW RESTRICTION ) ORDER 2008

The Gloucestershire County Council (“the Council”) in exercise of its powers under Section 1(1), 2 (1), (2), (4) and 4 of the Road Traffic Regulations Act 1984 (“the Act”) and Parts II and IV of Schedule 9 to the Act and of all other enabling powers and after consultation with the Chief Officer of Police in accordance with Part III of that Schedule hereby make the following Order:- 1. This Order shall come into operation on the 2008 and may

be cited as the “Gloucestershire County Council (Lorry Management Zone within Gloucestershire) (7.5 Tonne MGW Restriction Except for Loading and Unloading) Order 2008”.

2. (i) In this Order –

“Goods Vehicle” has the same meaning as in the Road Vehicles (Construction and Use) Regulations 1986 as amended;

“Maximum Gross Weight” has the same meaning as in the Traffic Signs and Regulations and General Directions 2002;

“Agricultural Vehicle” has the same meaning as in the Road Vehicles (Construction and Use) Regulations 1986 as amended;

“Public Service Vehicle” has the same meaning as in Section 1 of the Public Passenger Vehicles Act 1981

“Mobile Library” means a vehicle owned by Gloucestershire County Council and adapted to be used as a Mobile Library.

3. Save as provided in Article 6 no person shall, except upon the direction or with the permission of a Police Constable in uniform or a Traffic Warden, use, cause or permit any Goods Vehicle exceeding 7.5 Tonnes Maximum Gross Weight to proceed at any time in those lengths of roads specified in Areas 1, 2 and 3 of Schedule 1 to this Order except for loading and unloading.

4. Save as provided in Article 6 no person shall, except upon the direction or

with the permission of a Police Constable in uniform or a Traffic Warden, use, cause or permit any Goods Vehicle exceeding 7.5 Tonnes Maximum Gross Weight to proceed at any time in those lengths of roads specified in Schedule 2 to this Order.

5. No person shall, except upon the direction or with the permission of a Police

Constable in uniform or a Traffic Warden, use, cause or permit any Goods Vehicle exceeding 3 Tonnes, laden or unladen, to proceed at any time in those lengths of roads specified in Schedule 3 to this Order.

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6. Nothing in Articles 3 and 4 shall make it unlawful to use, cause or permit any

vehicle exceeding 7.5 Tonnes Maximum Gross Weight to proceed in those lengths of roads referred therein (if applicable) to enable –

(a) the maintenance, improvement or reconstruction of any of the said

lengths of roads ; or (b) the laying, erection, alteration or repair in or in land adjacent to any of

the said lengths of road or any sewer, or any main, pipe or apparatus for the supply of gas, water, oil or electricity or of any communications apparatus as defined in the Telecommunications Act, 1984;

(c) the vehicle to be used for Fire and Rescue, Police or Ambulance

purposes; (d) the vehicle to be used in the service of a local authority in pursuance of

its powers or duties in connection with their activities at premises situated on or adjacent to the said road;

(e) the vehicle to be used for agricultural purposes within the restricted

Areas;

(f) the vehicle to be used as a Public Service Vehicle

(g) the vehicle to be used as a Mobile Library 7. Those Orders or parts of Orders referred to in Schedule 3 to this Order are

hereby revoked 8. The prohibitions and restrictions imposed by this Order shall be in addition

and not in derogation from any restriction or requirement imposed by any regulations made or having effect of this made under the Act or by under any other enactment.

TRO Report Final 18

SCHEDULE 1

7.5 Tonne Maximum Gross Vehicle Weight Prohibition (Except for Loading and Unloading)

Area 1 All roads within the shaded area, shown blue on the attached Area 1 plan except for the A419, A433 and the A46 shown in green. Area 2 All roads within the shaded area, shown blue on the attached Area 2 plan except for the M5, A417, A429, A419, and the B4641 shown in green. Area 3 All roads within the shaded area, shown blue on the attached Area 3 plan except for the A417, A429, A40 and the A436 shown in green.

SCHEDULE 2

7.5 Tonne Maximum Gross Weight Prohibition

That length of Class III road number 215 known as Winny Croft Lane within Gloucester City which extends from its junction with Sneedhams Road (unclassified) to the bridge over the M5 motorway That length of Class IV road number 209 known as Naas Lane within the Parish of Quedgeley which extends from its junction with Waterwells Drive to the bridge over the M5 motorway

The entire length of the Class III road number 217 known as Nuthill within the Parish of Upton St Leonards. That length of the Class III road number 380 known as Ermin Street within the Parish of Brockworth which extends from its junction with road number 45752 Abbotswood Road for a distance of 100 metres in an easterly direction.

TRO Report Final 19

SCHEDULE 3

3 Tonne Weight Prohibition That length of unclassified road number 41215 known as Wades Lane, partly in the Parish of Pitchcombe and partly in the Parish of Painswick which is carried by the bridge over the stream at Pitchcombe Mill.

SCHEDULE 4

17 Tonne Maximum Gross Weight restriction The entire length of the Class V road number 1513 within the Parish of Chalford which extends from its junction with the A419 and is carried over the Thames and Severn Canal.

SCHEDULE 5

Revocations

Gloucestershire County Council (Cirencester Residential Zones) (Prohibition of Commercial Vehicles over 3 Tonnes) (No.2) Order 1980 Gloucestershire County Council (Cirencester Residential Zone) (Weight Restriction) (Metrication) Order 1989 Gloucestershire County Council (Lobleys Drive Abbeymead Gloucester) (7.5 tonne MGW Restriction except for Access) Order 2008

Gloucestershire County Council (7.5 Tonne Maximum Gross Weight Restriction) (Calmsden in the Parish of North Cerney) Order 2004 Gloucestershire County Council (Parishes of Coates, Kemble & Rodmarton) (7.5 Tonnes MGW Restriction) Order 1995 – all roads in the Schedule except Route 40981 between the A429 at Smerrills Barn and the A433 Gloucestershire County Council (Aston Down) (7.5 Tonne MGW Restriction) Order 2006 Gloucestershire County Council (Lanes between Cowcombe Hill & Aston Down) (Restriction) Order 1965 – Article 1(1) Gloucestershire County Council (Roads in the parishes of Cranham Upton St Leonards Painswick Chalford and Bisley with Lypiatt) (Weight Restriction) (Metrication) Order 1988 Gloucestershire County Council (Roads in the parishes of Cranham Upton St Leonards Painswick Chalford & Bisley with Lypiatt) (Restriction Order 1967

TRO Report Final 20

Gloucestershire County Council (Rooksmoor Lane Rodborough) (Weight Restriction) (Metrication) Order 1988 Gloucestershire County Council (Rooksmoor Lane Stroud Rural District) (Restriction) Order 1962 Gloucestershire County Council (Parish of Cainscross) (7.5 Tonnes MGW Restriction) Order 1994 Gloucestershire County Council (7.5 Tonne MGW Restriction and 50 mph Speed Limit) (B4008 Little Haresfield to Stonehouse, Stroud) Order 2005 - part 2 of the Schedule relating to the weight restriction. Gloucestershire County Council (Parish of Stonehouse – Stroud District) (Weight Restriction) Order 1982 Gloucestershire County Council (Inchbrook Bridge – Nailsworth) (Weight Restriction) Order 1968 Gloucestershire County Council (Parishes of Elkstone, Coberley, Cowley, Bagendon and Baunton) (7.5 Tonnes MGW Restriction) Order 1993 Gloucestershire County Council (Naas Lane and Upton Lane Brookthorpe) (7.5 Tonne Weight Restriction ) Order 1994

Gloucestershire County Council (Moorfield Road, Brockworth) (Weight Restriction) 1993 Gloucestershire County Council (Moorfield Road, Brockworth) (Weight Restriction) Order 1970 Gloucestershire County Council (Birdlip Hill) (Weight Restriction) (Metrication) Order 1987 Gloucestershire County Council (Birdlip Hill) (Weight Restriction) Order 1987 Gloucestershire County Council (Parishes of Calmsden Baunton and Daglingworth) (Weight Restriction) Order 1990 Gloucestershire County Council (Cotswold & Stroud Districts – Parishes of Avening & Nailsworth) (Temporary Weight Restriction – Road Number B4014) Order 2008 Gloucestershire County Council (Barrow Wake Birdlip) (7.5 tonne MGW Restriction) Order 2004 Schedule 2 of the Gloucestershire County Council (Brockworth Area) (General Traffic Regulation) Order 1999 relating to 7.5 tonnes gross vehicle weight prohibition on Ermin Street

TRO Report Final 21

Gloucestershire County Council (Chalford Stroud) (7.5 tonnes Maximum Gross Weight Prohibition) Order 2000 Gloucestershire County Council (Minchinhampton and Rodborough) (7.5 MGW Restriction) Order 2007

Given under the Common Seal of Gloucestershire County Council this day of Two Thousand and Eight THE COMMON SEAL of GLOUCESTERSHIRE COUNTY COUNCIL was hereunto affixed in the presence of :-

Director of Law and Administration

TRO Report Final 22

Notice

TRO Report Final 23

Statement of Reasons

GLOUCESTERSHIRE COUNTY COUNCIL (LORRY MANAGEMENT ZONE WITHIN GLOUCESTERSHIRE)

7.5 TONNE HGV ORDER 2008

Statement of Reasons Gloucestershire County Council is committed to the provision of an effective Freight Management Strategy. This Strategy seeks to balance the need to minimise the impact of freight movement upon local communities and environments through which they pass and in many cases service, whilst at the same time providing operators and hauliers with a safe and efficient route network. The problem of heavy goods vehicles (HGVs) using unsuitable roads is an increasing one, particularly now that satellite navigation is gaining in popularity. This can place a burden on the County Council to maintain roads that are being damaged unnecessarily by unsuitable vehicles as well as eroding the quality of life of the people who live adjacent to these roads.

The impact of HGV movements in the Cotswolds has been identified of most immediate concern, particularly given that this is a designated Area of Outstanding Natural Beauty (AONB), and so development of the County Strategy is initially focussing on this area. As this is a large area it has been divided into zones and a detailed review has been undertaken of freight related issues within the first of these zones. Zone One represents an area bounded by the M5 to the west, the A429 to the east, the A40/A436/A417 to the north and across Minchinhampton Common, running largely parallel with the A419 to the south. This zone was chosen as the first zone as it is fairly compact, has relatively low levels of industrial activity, is wholly contained within Gloucestershire, and has an easily defined road network with known problem areas.

The collection, collation and detailed analysis of a wide range of information regarding freight movements and an understanding of the issues both for operators and the local community in respect of these movements, has provided the evidential base upon which to review the existing Advisory Freight Route Network operating within this zone. A key outcome of this review process has been the identification of those routes that are considered most suitable for HGV’s to use; namely the A417, A419, A429, A436 and A40.

This Traffic Regulation Order (TRO) represents an innovative area wide approach to managing freight movements within Zone One. A 7.5 tonne weight restriction will be used to encourage HGV through traffic to use the designated routes. The County Council does not wish to hinder local businesses and those with a legitimate need to access sites within this area and therefore the TRO will include an exemption for the purposes of loading and unloading, and access to the registered operational base, within this restricted zone.

Under this TRO all existing weight restrictions in operation within this area will be drawn together under a single Consolidation Order. In so doing this will present the opportunity to rationalise signing within this environmentally sensitive area.

An extensive consultation process has been undertaken with the Parishes, Operators and other associated Stakeholders to inform the early development of the Strategy. This TRO Notification constitutes part of the wider consultation process to raise awareness of the restricted zone, the evolving Freight Strategy and the benefits of the implementation of the TRO. It is envisaged that through the successful development and delivery of a safe and efficient HGV route hierarchy, this area based approach could be extended to cover the whole of the Cotswolds AONB in Gloucestershire.

TRO Report Final 24

Plan Numbers – Area 1

TRO Report Final 25

Area 2

TRO Report Final 26

Area 3

TRO Report Final 27

Appendix B Copies of: Objections Received 1 Ian Gallagher (FTA) 2 Colin Mar-Gerrison (Hewden) 3 Mike Farmer (RHA) 4 Rex Horsman (Transrex) 5 Mark Quilliam (Kuehne + Nagel) 6 & 7 Mr Guy Adams (General Public) 8 Ken Hobden (QPA) 9 Roger Cullimore (Moreton C Cullimore & Son Ltd) 10 Max Engel Solicitors (On behalf of Mr. N. Bellone)

TRO Report Final 52

Appendix C Copies of: Responses to Formal Objections 1 Ian Gallagher (FTA) 2 Colin Mar-Gerrison (Hewden) 3 Mike Farmer (RHA) 4 Rex Horsman (Transrex) 5 Mark Quilliam (Kuehne + Nagel) 6 & 7 Mr Guy Adams (General Public) 8 Ken Hobden (QPA) 9 Roger Cullimore (Moreton C Cullimore & Son Ltd) 10 Max Engel Solicitors (On behalf of Mr. N. Bellone)

TRO Report Final 53

Your

Ref:

Our Ref: 5064355/TP/KK/79924

24 September 2008

Ext No:

Ian Gallagher

Policy Manager, Midlands Southwest & Wales

Freight Transport Association

Hermes House

20 Coventry Road

Cubbington

Leamington Spa

Warwickshire.

CV32 7JN

Dear Mr Gallagher

COTSWOLDS LORRY MANAGEMENT ZONE: 7.5 TONNE MGW RESTRICTION

ORDER 2008

Atkins has been commissioned by Gloucestershire County Council to develop and implement

a Freight Management Strategy for the Cotswolds AONB.

We have therefore been instructed by the County Council to address the points raised in your

letter of objection to the 7.5 Tonne MGW Restriction Order 2008 to provide you with a fuller

understanding of the Strategy to allay your concerns and give you the opportunity to

reconsider your objection.

In response to your letter dated 22 August 2008, where you lodged an objection on behalf of

the Freight Transport Association to the Cotswolds Area wide 7.5 tonne MGW Order, please

be advised that a TRO Committee has been organised for 10:00 am on 14 October 2008 in

the Council Chambers at the Shire Hall in Gloucester. As a formal objector you may well

have already been provided with the details of this Meeting, if not then these will be provided

in due course by the Council’s Democratic Services Unit.

In the meantime I would like to take this opportunity to respond to the issues raised in your

letter.

Environment and Social Impact

In your letter you perceive the potential vehicle reductions as an outcome of the Strategy to

be of negligible positive impact to the Cotswolds AONB. Whilst it is acknowledged, as you

cite, that the scale of transfer of ‘through’ traffic off the A46 and A435 is modest, roughly a

third of HGVs are forecast to transfer off these routes, there is evidence to suggest the

benefits will be tangible to those who live, work and visit these locations. The outcomes of

the public consultation process indicate the perception that HGV movements have a material

impact on people’s quality of life. A particular benefit will be an improvement in the visual

TRO Report Final 54

appearance of the area given the large size and intrusive nature of HGVs and their

incompatibility with high quality landscapes and townscapes. Similarly there will be a

reduction in levels of fear and intimidation from HGVs, particularly for pedestrians, cyclists

and equestrians. A 30% reduction in HGVs is likely to reduce these impacts, although not

perhaps by as much as some residents might wish. Part of the ongoing Strategy will be the

development of improved lines of communication and engagement between the County,

Local Communities and Operators/Hauliers. This is important to manage expectations,

develop a greater mutual understanding and ensure ongoing commitment to the Strategy.

Indirect longer term benefits could also include enhancing the amenity of townscapes

particularly where building frontages are adjacent to the carriageway and streets are narrow

with parking, reducing dust and vibration for residents, enhancing the perception of

townscapes and sense of place. Other benefits from reducing HGVs could include greater

promotion of walking/cycling to school and work, and in so doing seeking to further reduce

the urbanising effects of traffic within the AONB.

It is acknowledged, as you also point out in your letter, that the reductions in HGVs on the

A46 and A435 will only have a marginal impact on the investment required for carriageway

maintenance. However, the A419 has been identified as a route for additional investment to

improve the level of service for freight, subject to confirmation that the improvements offer

value for money. Similarly, measures will also be considered which will reduce the

environmental impacts of HGVs for those who live and work adjacent to the A419.

Air Quality/Additional Emissions In response to your concerns regarding air quality as an outcome of the Strategy, we have

carried out assessments of air quality, noise and CO2 emissions in line with the development

of the Strategy. The outcome of these assessments identified that the Strategy will result in a

maximum of a 0.5% increase in CO2 within the Study Area, and the impact on air quality and

noise will be similarly negligible.

Vehicle Data

We acknowledge your concern regarding the potential impact of the transfer of HGV flows

from the B4008 onto the section of the A419 to the west of Stroud. Initial traffic figures for

the B4008 did suggest that the level of use of the route by HGVs was higher than that

suggested by later figures. The figures for the route as presented in the TRO exhibition

material have been thoroughly reviewed and can be considered definitive. The Monitoring

Strategy will ensure that any data used to assess the performance of the route is robust and

reliable.

Safety and Operation

You raise a number of issues regarding the potential impact of the introduction of an Area

wide Lorry Management Zone on the safety and operation of the A417 and the A419.

A417

The County Council is strongly committed to maintaining the safety and operation of its

network. Whilst the A417 is part of the Highways Agency (HA) and not the County Network

it represents a key route within the proposed Cotswolds Area wide Lorry Management Zone

and, as such, a detailed assessment of the impact of this restriction on both the accident

record and capacity of this route, and all others within the area, has been undertaken as part

of the Study.

TRO Report Final 55

In terms of the current safety record for the A417, there have been 156 accidents reported on

the 24km section between Cirencester and the M5 J11a within the five year period (2001-

2005); 34 of these involved HGVs. Of these, 20 HGV accidents have occurred on the section

of the A417 between Crickley Hill and Nettleton Bottom. The majority of these accidents

occurred on the section between Little Witcombe and Birdlip (Crickley Hill); seven of which

have, as you have raised, resulted in more serious injury. Detailed analysis has not identified

any common contributory factors through this section, although all four accidents reported at

the Air Balloon Roundabout were the result of HGVs overturning whist negotiating the

circulatory carriageway.

Overall, the HGV accident rate on this route represents 0.147 HGV PIA/Million HGV km.

The forecast level of transfer of 34 HGV trips per day from the A435 would equate to an

additional 297,840 HGV km per year on the A417, which in turn would suggest a potential

increase in the accident rate of 0.04 accidents per year. On this basis the transfers could result

in one additional HGV accident every 25 years. Whilst any additional accident arising from

the Cotswolds AONB Freight Strategy is clearly an outcome to be avoided, an increase of

this order is of a sufficiently low level to be considered negligible. In this context it is worth

noting that the Highways Agency, who own the A417, have not objected to the forecast

transfer of HGVs from the A435. It is also worth noting that with the maximum monthly

variation of HGVs on the A417 being around 1,000 vehicles the change arising from transfer

of the A435 vehicles can also be considered negligible.

A419

An outcome of the consultation process regarding ‘problems and issues’ associated with

freight in the Study Area identified congestion on the A419 to the west of Stroud as being a

particular problem for the freight industry, and is likely to be one reason for HGVs using the

B4008 through and to the north of Stonehouse to access the M5, in breach of an existing

weight restriction. In the light of this consultation outcome, and in acknowledgement of the

existing levels of congestion which affect all road users including HGVs, the County Council

has commissioned a further study to more specifically examine the performance of all

junctions on this section of the A419.

The Freight Study has identified that the HGV transfers from the A46, B4008 and A4173, to

the western end of the A419 would amount to some 162 HGVs per day (an increase of 17%

HGVs or 0.7% total traffic) and would be likely to increase delay on this section of the

corridor by some 2.2% over existing in the morning peak period and by some 0.2% in the

evening peak. Delay during the rest of the day is likely to be below this level. In

acknowledgement of the level of delay on the corridor, which is clearly a source of frustration

to HGV drivers and reduces the productivity of the industry, the County Council is

considering how improvements identified as part of the Study can be included in the capital

programme.

Whilst the level of congestion on the corridor is regrettable, the increase in delay arising from

the Cotswolds AONB Freight Strategy HGV restrictions is considered to be sufficiently small

such that improvements on the corridor cannot be justified prior to the implementation of this

Strategy.

However, in response to requests from the Road Haulage Industry major structural

maintenance is due to start in February 2009 on the A419 East of Stroud between Ham Hill

Lane and Brimscombe, also between Dark Lane and Marle Hill.

TRO Report Final 56

Future Expansion of Business Premises within the Zone

The Cotswolds Freight Management Strategy may, in the longer term, have an impact on the

expansion of businesses generating significant numbers of HGVs, as you point out in your

letter. However, each application would be judged on its merits in line with the Planning

Policies.

Alternative Routes It is acknowledged that from time to time diversionary routes are required when, due to an

accident or other emergency, a route for ‘through’ traffic will be closed and that an

alternative route is required for the duration of that closure. In these circumstances the police

have the power to suspend road traffic regulations that restrict HGV movements. A

successful HGV Strategy in this context will contain a Signing Regime and Communications

Strategy that firmly and clearly manages day to day HGV movements whilst having the

flexibility to address more unusual conditions. In this respect a key issue is to ensure that the

police who suspend prevailing regulatory signing do so in the knowledge that the routes

HGVs use under those conditions are suitable for HGV use. To this end the Communications

Strategy includes a police liaison element, to ensure that the police are aware of which routes

are suitable and those that are not.

For closures of the A419 between Cirencester and Stroud the diversion route is the A417/M5,

for closures between Stroud and the M5 the diversion route is M5/A417.

For closures of the A417 between Birdlip and Cirencester the alternative is A436/A40 to

Northleach, then the A429 to Burford Road junction

Advisory Freight Routes

The Regional Freight Map (RFM) was, as you point out in your letter, drawn up by the

Southwest Regional Freight Forum, in agreement with the Road Haulage Association (RHA),

the Freight Transport Association (FTA) and the Local Transport Authorities (LTAs) in the

southwest to identify the wider network of advisory routes for freight; differentiating between

routes for local, regional and national journeys. This is compatible with the role of the routes

as shown in the existing County Advisory Freight Route Map, with the absence of the A46,

A4173 and A435 in both instances highlighting that these routes were not considered

appropriate for long distance ‘through’ HGV movement.

The use and level of resolution of such hierarchical labels is acknowledged to be influenced

by the aims, objectives and scope of the organisation developing the hierarchy and allocating

roads to it. An important element of the process to develop the Cotswolds Freight

Management Strategy has therefore been to more specifically review the success of existing

mapping, signing and enforcement regimes in place within this area in delivering the

aspirations of the routing strategy included in the Gloucestershire LTP and articulated on the

Freight Map. This review found that the advice contained on the map is being widely ignored

and, on that basis, it was concluded that the existing approach to signing and enforcement

was inadequate and required substantive improvement.

The Strategy is not looking to make any significant change to the current status of any of the

routes within the proposed Lorry Management Zone, but instead to overcome any confusion

regarding interpretation of their classification and to provide a formal mechanism that

supports their appropriate use. To this end the Area wide 7.5 tonne weight restriction is

TRO Report Final 57

intended to encourage HGV through traffic to use designated routes; namely the A417, the

A436, the A40 and the A419. The County Council does not wish to hinder local businesses

and those with a legitimate need to access sites within this Area and, as such, those Operators

and Hauliers who have a legitimate requirement to load and unload within the zone, or to

travel to/from a registered operational base within the zone would be unaffected by this Area

wide Order, as you are aware.

Enforcement

In your letter you enquired as to the proposed nature of enforcement, in particular given

concerns regarding limited police resources. It is acknowledged that police resources are

limited and other activities are doubtless ascribed a higher level of prioritisation. As such, the

Monitoring Strategy being developed as part of this Freight Management Strategy seeks to

provide an effective mechanism through which to both establish the outcomes of the Area

wide restriction and to guide the deployment of enforcement activities mindful of the

pressures on police time. To this end there has, and will continue to be close collaboration

between the County Freight and Data Management functions, Trading Standards and the

Police to produce a robust Monitoring Strategy which can guide enforcement and identify

progress towards ultimate Strategy objectives.

We also acknowledge the comments that have been made through the course of the

development of this Strategy regarding the difficulty in enforcement of road traffic

regulations for vehicles which are registered outside the UK. Improving the enforcement of

road traffic regulations for vehicles registered outside the UK is a matter for the UK National

Government but we recognise that the communications element of this Strategy will need to

acknowledge language variations in the haulage community.

An outcome of engagement with Operators and Hauliers throughout the development of the

Strategy and the Lorry Management Zone has identified that there is a generally low level of

awareness of the County Advisory Freight Route Map. This Map has been in circulation for

over 10 years and, amongst other proposed actions to improve lines of communication and

awareness, the Freight Map will include translations of key sections of the map into a number

of European languages.

Weight Restriction Levels

In your letter you suggest that an increase in the threshold of the weight restriction to 18

tonnes might be more acceptable given your view that the public perceive multi-axle vehicles

to be more of a problem. Should the Strategy seek only to restrict the movements of HGVs in

excess of 18 tonnes the numbers of HGVs making through route movements on less

appropriate routes would be reduced by approximately 10%. On the basis that the

environmental benefits associated with a reduction of some 30% are modest in scale,

increasing the weight to 18 tonnes would significantly reduce those already modest benefits

to a level where the value for money of the project would be questionable.

I trust the above points of clarification help to allay your concerns and allow you to

reconsider your objection to the order.

Yours sincerely,

for and on behalf of

Atkins Highways and Transportation

TRO Report Final 58

Your

Ref:

Our Ref: 5064355/TP/KK/79922

24 September 2008

Ext No:

Colin Mar-Gerrison

Manager

Hewden

Battledown Works

King Alfred Way

Cheltenham

Gloucestershire.

GL52 6QP

Dear Mr Mar-Gerrison,


ORDER 2008







In response to your letter of 25 August 2008, where you lodged your objection to the

Cotswolds Area wide 7.5 tonne MGW Order, please be advised that a TRO Committee has

been organised for 10:00 am on 14 October 2008 in the Council Chambers at the Shire Hall

in Gloucester. As a formal objector you may well have already been provided with the details

of this Meeting, if not then these will be provided in due course by the Council’s Democratic

Services Unit.


letter.

In your letter you raise specific concerns regarding the restriction of use of the A46

(Brockworth-Stroud), A4173 (Brookthorpe-Pitchcombe) and the A435 (Severn Springs-

Cirencester) route to ‘access only’ status and the likely impact that this will have on journey

time, cost and the environment. It has been identified from existing traffic survey data

available and further surveys undertaken in support of this Study that a modest number of

HGVs will be required to use the A417 and A419 for through-movement instead of those

routes within the protected zone. However, in overall terms, the benefits of the strategy in

reducing the impacts of HGVs on those who live, work and otherwise visit the protected zone

TRO Report Final 59

outweigh the disbenefits, on the basis that the scale of reduction of HGVs on the A46, A4173

and A435 is considerably greater than the likely resultant increase on the A419 and A417.

We have also carried out an assessment of the increase in CO2 emissions forecast to arise

from the Strategy and this has indicated that the Strategy will result in a maximum of a 0.5%

increase in CO2 in the study area. An air quality and noise assessment of the Strategy has

also found that the impacts will be negligible.




over 10 years and, albeit Advisory, it designates each of the routes to which you refer as ‘for

access and diversionary use only’. The Strategy is not therefore looking to make any

significant change to the current status of routes within the zone, but instead to provide a

formal mechanism that supports their use. Those Operators and Hauliers who have a

legitimate requirement to load or unload within the zone, or to travel to/from an operational

base within the zone would be unaffected by the Area wide Order.

We appreciate that communication and engagement are an important part of both ensuring

wider awareness of the Freight Route Map by Operators/Hauliers and greater understanding

by the local communities of the important role that the Freight Industry plays within the local

economy. This would be addressed as part of an ongoing Communications and Engagement

Strategy should the order be made.



Yours sincerely,



TRO Report Final 60

Your

Ref:

Our Ref: 5064355/TP/KK/79925

24 September 2008

Ext No:

Michael Farmer

Regional Director Midlands & Western Region

Road Haulage Association Limited

Roadway House

Cribbs Causeway

Bristol.

BS10 7TU

Dear Mr Farmer


ORDER 2008








the Road Haulage Association to the Cotswolds Area wide 7.5 tonne MGW Order, please be

advised that a TRO Committee has been organised for 10:00 am on 14 October 2008 in the

Council Chambers at the Shire Hall in Gloucester. As a formal objector you may well have

already been provided with the details of this Meeting, if not then these will be provided in

due course by the Council’s Democratic Services Unit.


letter.

7.5 Tonnes



to be the key problem. We acknowledge your comment and, as you state, we have been asked

this question on a number of occasions throughout the course of the development of the

Strategy.

Should the Strategy seek only to restrict the movements of HGVs in excess of 18 tonnes the

numbers of HGVs making through route movements on less appropriate routes would be

reduced by approximately 10%. On the basis that the environmental benefits associated with

a reduction of some 30% are modest in scale, increasing the weight to 18 tonnes would

TRO Report Final 61

significantly reduce those already modest benefits to a level where the value for money of the

project would be questionable.

‘A’ Class Roads

In your letter you cite concerns regarding the restricted status of the A46, A435 and A4173 to

loading/unloading and access to/from an operational base only within the proposed Lorry

Management Zone.

Historically, ‘A’ class roads have catered for longer distance movements, particularly those

of HGVs. However, the introduction of the motorway system in the 1960s established an

additional tier in the national highway network which has provided significant additional

capacity for the long distance movement of freight. It is acknowledged that use of the

motorway network for commuting purposes has over time reduced the capacity of that

network to cater for freight. It does not follow however, that ‘A’ road capacity, particularly

through areas with high environmental value, should be retained to cater for that loss of

capacity. A relevant consideration is the need to manage demand for single occupancy light

vehicle commuting to release network capacity for freight movements. All Transport

Authorities in the UK have, to a greater or lesser extent, policies to address this within their

Transport Plans. A national road user charging scheme which would assist in reducing the

level of demand by non-freight traffic, and release capacity for freight, is currently on hold.




over 10 years and, albeit Advisory, it designates each of the routes to which you refer as ‘for



formal mechanism that supports their use. The introduction of an Area wide Lorry

Management Order intends to reinforce the use of the A46, A4173 and A435 routes for

‘loading/unloading’ and ‘access to/from an operational base’ within the zone only and to

reduce the perception that the routes have a diversionary role, except in exceptional

circumstances.

The Regional Freight Map (RFM), drawn up by the Southwest Regional Freight Forum and

agreed with the Road Haulage Association (RHA), the Freight Transport Association (FTA)

and Local Transport Authorities (LTAs), identifies the wider network of advisory routes for

freight. This Map excludes the A46, A435 and A4173, although it does include the A419

which is identified as a County route. Generally speaking a County route, in the context of

the RFM, is used primarily by vehicles undertaking a journey with one or both trip ends in

the County within which it is located. Clearly it was the view of the regional body, the freight

industry representatives and the LTAs that the A46, A4173 and A435 were not required for

‘through’ HGV movement. This is compatible with the role of these routes as shown in the

existing County Advisory Freight Route Map. The Regional Freight Map was included in the

draft Regional Spatial Strategy (RSS) although it has not been identified for inclusion in the

final RSS.

Congestion/Road Safety (Cited under ‘A’ Road and ‘Road Safety’ headings)


wide Lorry Management Zone on the safety and operation of the A417 and the A419. The

issues relating to these two routes are addressed separately in turn.

TRO Report Final 62

A417 The County Council is strongly committed to maintaining the safety and operation of its





of the Study.






have resulted in more serious injury. Detailed analysis has not identified any common

contributory factors through this section, although all four accidents reported at the Air

Balloon Roundabout were the result of HGVs overturning whist negotiating the circulatory

carriageway.

Overall, the HGV accident rate represents 0.147 HGV PIA/Million HGV km. The forecast

level of transfer of 34 HGV trips per day from the A435 would equate to an additional

297,840 HGV km per year on the A417, which in turn would suggest a potential increase in

the accident rate of 0.04 accidents per year. On this basis the transfers could result in one

additional HGV accident every 25 years. Whilst any additional accident arising from the

Cotswolds AONB Freight Strategy is clearly an outcome to be avoided, an increase of this

order is of a sufficiently low level to be considered negligible. In this context it is worth


transfer of HGVs from the A435.

It is also worth noting that with the maximum monthly variation of HGVs on the A417 being

around 1,000 vehicles the change arising from transfer of the A435 vehicles can also be

considered negligible.

A419
















TRO Report Final 63

considering how improvements identified as part of the study can be included in the capital

programme.




Strategy. However, in response to requests from the Road Haulage Industry major structural



Traffic Flow Studies

Origin and Destination Surveys are particularly useful in identifying which HGV journeys are

‘through’ journeys and could transfer to another route, and which are delivering locally and

need to continue to use the route. Origin and Destination surveys can be carried out in a

number of ways. To inform this Study two forms of Origin and Destination Survey

information has been used to provide an understanding of ‘through’ movements; Registration

Number Surveys and Questionnaire Surveys. The former were undertaken prior to the Study

on the B4008, A4173 and A435, whilst Questionnaire Surveys, which involved stopping and

questioning drivers as to their last and next stopping point, were undertaken in 2007 on the

A46 and A419. These Surveys provided information to inform the development of the

Strategy throughout the Study Area.

Whilst it is acknowledged that the scale of transfer of ‘through’ traffic off the A46 and A435

is modest, roughly a third of HGVs are forecast to transfer off these routes, there is evidence

to suggest the benefits will be tangible to those who live, work and visit these locations. The

outcomes of the public consultation process indicate the perception that HGV movements

have a material impact on people’s quality of life. A particular benefit will be an

improvement in the visual appearance of the area given the large size and intrusive nature of

HGVs and their incompatibility with high quality landscapes and townscapes. Similarly there

will be a reduction in levels of fear and intimidation from HGVs, particularly for pedestrians,

cyclists and equestrians. A 30% reduction in HGVs is likely to reduce these impacts,

although not perhaps by as much as some residents might wish. Part of the ongoing Strategy

will be the development of improved lines of communication and engagement between the

County, Local Communities and Operators/Hauliers. This is important to manage

expectations, develop a greater mutual understanding and ensure ongoing commitment to the

Strategy.







You also cite a potential increased administrative burden on the part of Operators/Hauliers as

a result of the implementation of an Area wide Lorry Management Zone. It is acknowledged

that the majority of HGVs will be operating legally in the area. To offset the potential

outcome of members of the public contacting Operators engaged in legitimate activities,

ongoing communications with Parishes in the area is, as previously outlined, intended to raise

the profile of the Freight Industry and the benefits and necessities their activities provide. The

TRO Report Final 64

County Council could also provide proformas for use by Operators to respond to queries

raised by the public which would reduce an additional administrative burden on Hauliers.

Environment

In your letter you raise environmental concerns about the transfer of HGVs from one route to

another. It has been identified from the existing traffic survey data available and further

surveys undertaken in support of this Study that a modest number of HGVs would be

required to use the A417 and A419 rather than the routes through the protected zone.

However, in overall terms, the benefits of the Strategy in reducing the impacts of HGVs on

those who live, work and otherwise visit the protected zone outweigh the disbenefits, on the

basis that the scale of reduction of HGVs on the A46, A4173 and A435 is considerably

greater than the resultant increase on the A419 and A417. We have also carried out an

assessment of the increase in CO2 emissions forecast to arise from the Strategy and this has

indicated that the Strategy will result in a maximum of a 0.5% increase in CO2 in the Study

Area. Air quality and noise assessments have also found that the impacts of the Strategy will

be negligible.

You also cite potential sign clutter as a concern in your letter. The Strategy has been designed

to keep the increase in signing to a minimum. The Strategy will currently involve the removal

of 165 signs and the installation of 196, leading to a net increase of 31 signs. Given that

these signs will be located in existing verges which already contain some level of signing, the

impact of the signing on the landscapes and townscapes of the AONB is considered

proportional to the problem and the forecast outcomes.

Enforcement


concerns regarding limited police resources and difficulties regarding the enforcement of

those Operators/Hauliers who are registered outside the UK.

It is acknowledged that police resources are limited and other activities are doubtless ascribed

a higher level of prioritisation. As such, the Monitoring Strategy being developed as part of

this Freight Management Strategy seeks to provide an effective mechanism through which to

both establish the outcome of the Area wide restriction and to guide the deployment of

enforcement activities mindful of the pressures on police time. To this end there has, and will

continue to be close collaboration between the County Freight and Data Management

functions, Trading Standards and the Police to produce a robust monitoring strategy which

can guide enforcement and identify progress towards ultimate strategy objectives.

Whilst we acknowledge that enforcement of road traffic regulations for vehicles which are

registered outside the UK is more difficult to achieve than those whose operating base is in

the UK, we do not consider that this is a valid reason for not implementing the regulatory

signing element of the Strategy, although the communications element of the Strategy will

need to acknowledge language variations in the haulage community. To this end the Freight

Map will include translations of key sections of the map into a number of European

languages. Improving the enforcement of road traffic regulations for vehicles registered

outside the UK is a matter for the UK National Government.

Alternative Routes

In addressing the issue of diversionary routes there is a clear requirement to differentiate

between valid reasons for diversion and those which are not. In this context a significant

TRO Report Final 65

influence in the development of the Cotswolds AONB Freight Strategy is the belief that a

significant proportion of HGVs using the A46, A435 and B4008 and routes across

Minchinhampton Common do so to avoid congestion on the routes for ‘through’ traffic. In

other words taking a short cut, or ‘rat-running’. Whilst the County Council’s aim is to

improve the productivity of the road haulage industry, this aim clearly requires a careful

balance with the environmental, social and community impacts of HGV traffic. Managing the

demand for use by HGVs on the routes identified by satellite navigation equipment and those

routes used as short cuts by the local haulage community are also important considerations.

It is acknowledged that from time to time diversionary routes are required when, due to an









Strategy includes a police liaison element, as previously outlined, to ensure that the police are

aware of which routes are suitable and those that are not.

Cost

The total cost for the development of the Strategy and implementation of an Area wide

Freight Management Zone will, as you understand, be close to £500,000. This figure includes

both the capital cost of materials required to deliver the Area wide Freight Management Zone

as well as the collection, collation and analysis of a substantive range of quantitative and

qualitative data considered essential to the development of a robust Strategy which seeks to

balance the needs of all who live in and pass through the area. The re-allocation of in the

order of 30% of HGVs to designated routes is accepted as statistically significant and will

have a tangible impact on the quality of life of those living within this area, as previously

explained.

Measurement of Success

The key criteria that will be applied to measure the outcomes of the Strategy with regard to

the implementation of the Area wide Lorry Management Zone include a combination of

quantitative and qualitative criteria, including:

• Reduction in the numbers of HGVs on the B4008, A4173, A46 and A435, by 47%,

37%, 37% and 27% respectively;

• General view held by those who live and work in the enforcement zone that the

impact of HGVs has been reduced; and that the

• Freight Industry is of the view that the Strategy has not significantly detrimentally

affected their activities.





TRO Report Final 66

Your

Ref:

Our Ref: 5064355/TP/KK/79926

24 September 2008

Ext No:

Rex Horsman

Transrex (Haulage Contractor)

7 Blacksmith Lane

Churchdown

Gloucester.

GL3 2EU

Dear Mr Horsman


ORDER 2008







In response to your letter dated 28 August 2008, where you stated your objection to the





Services Unit.


letter.

7.5 Tonnes



to be the key problem. We acknowledge your comment and, as you state, we have been asked

this question on a number of occasions throughout the course of the development of the

Strategy.

Should the Strategy seek only to restrict the movements of HGVs in excess of 18 tonnes the

numbers of HGVs making through route movements on less appropriate routes would be

reduced by approximately 10%. On the basis that the environmental benefits associated with

a reduction of some 30% are modest in scale, increasing the weight to 18 tonnes would

TRO Report Final 67

significantly reduce those already modest benefits to a level where the value for money of the

project would be questionable.

‘A’ Class Roads

In your letter you cite concerns regarding the restricted status of the A46, A435 and A4173 to

loading/unloading and access to/from an operational base only within the proposed Lorry

Management Zone.

Historically, ‘A’ class roads have catered for longer distance movements, particularly those

of HGVs. However, the introduction of the motorway system in the 1960s established an

additional tier in the national highway network which has provided significant additional



network to cater for freight. It does not follow however, that ‘A’ road capacity, particularly

through areas with high environmental value, should be retained to cater for that loss of

capacity. A relevant consideration is the need to manage demand for single occupancy light

vehicle commuting to release network capacity for freight movements. All Transport

Authorities in the UK have, to a greater or lesser extent, policies to address this within their

Transport Plans. A national road user charging scheme which would assist in reducing the

level of demand by non-freight traffic, and release capacity for freight, is currently on hold.




over 10 years now and, albeit Advisory, it designates each of the routes to which you refer as

‘for access and diversionary use only’. The Strategy is not therefore looking to make any


formal mechanism that supports their use. The introduction of an Area wide Lorry




circumstances.


agreed with the Road Haulage Association (RHA), the Freight Transport Association (FTA)

and Local Transport Authorities (LTAs), identifies the wider network of advisory routes for

freight. This Map excludes the A46, A435 and A4173, although it does include the A419

which is identified as a County route. Generally speaking a County route, in the context of

the RFM, is used primarily by vehicles undertaking a journey with one or both trip ends in

the County within which it is located. Clearly it was the view of the regional body, the freight

industry representatives and the LTAs that the A46, A4173 and A435 were not required for

‘through’ HGV movement. This is compatible with the role of these routes as shown in the

existing County Advisory Freight Route Map. The Regional Freight Map was included in the

draft Regional Spatial Strategy (RSS) although it has not been identified for inclusion in the

final RSS.

Congestion/Road Safety (Cited under ‘A’ Road and ‘Road Safety’ headings)

You raise a number of issues with regards to the potential impact of the introduction of an

Area wide Lorry Management Zone on the safety and operation of the A417 and the A419.

The issues relating to these two routes are addressed separately in turn.

TRO Report Final 68






of the Study.









carriageway.













A419
















TRO Report Final 69


programme.




Strategy.

However, in response to requests from the Road Haulage Industry major structural



Traffic Flow Studies

Origin and Destination Surveys are particularly useful in identifying which HGV journeys are

‘through’ journeys and could transfer to another route, and which are delivering locally and

need to continue to use the route. Origin and Destination surveys can be carried out in a

number of ways. To inform this Study two forms of Origin and Destination Survey





A46 and A419. These Surveys provided information to inform the development of the


Whilst it is acknowledged that the scale of transfer of ‘through’ traffic off the A46 and A435

is modest, roughly a third of HGVs are forecast to transfer off these routes, there is evidence

to suggest the benefits will be tangible to those who live, work and visit these locations. The

outcomes of the public consultation process indicate the perception that HGV movements

have a material impact on people’s quality of life. A particular benefit will be an

improvement in the visual appearance of the area given the large size and intrusive nature of

HGVs and their incompatibility with high quality landscapes and townscapes. Similarly there

will be a reduction in levels of fear and intimidation from HGVs, particularly for pedestrians,

cyclists and equestrians. A 30% reduction in HGVs is likely to reduce these impacts,

although not perhaps by as much as some residents might wish. Part of the ongoing Strategy

will be the development of improved lines of communication and engagement between the

County, Local Communities and Operators/Hauliers. This is important to manage

expectations, develop a greater mutual understanding and ensure ongoing commitment to the

Strategy.











TRO Report Final 70

ongoing communications with Parishes in the area is, as previously outlined, intended to raise

the profile of the Freight Industry and the benefits and necessities their activities provide. The

County Council could also provide proformas for use by Operators to respond to queries

raised by the public which would reduce an additional administrative burden on Hauliers.

Environment

In your letter you raise environmental concerns about the transfer of HGVs from one route to

another. It has been identified from the existing traffic survey data available and further

surveys undertaken in support of this Study that a modest number of HGVs would be

required to use the A417 and A419 rather than the routes through the protected zone.

However, in overall terms, the benefits of the Strategy in reducing the impacts of HGVs on

those who live, work and otherwise visit the protected zone outweigh the disbenefits, on the

basis that the scale of reduction of HGVs on the A46, A4173 and A435 is considerably

greater than the resultant increase on the A419 and A417. We have also carried out an

assessment of the increase in CO2 emissions forecast to arise from the Strategy and this has

indicated that the Strategy will result in a maximum of a 0.5% increase in CO2 in the Study

Area. Air quality and noise assessments have also found that the impacts of the Strategy will

be negligible.

You also cite potential sign clutter as a concern in your letter. The Strategy has been designed

to keep the increase in signing to a minimum. The Strategy will currently involve the removal

of 165 signs and the installation of 196, leading to a net increase of 31 signs. Given that

these signs will be located in existing verges which already contain some level of signing, the

impact of the signing on the landscapes and townscapes of the AONB is considered

proportional to the problem and the forecast outcomes.

Enforcement


concerns regarding limited police resources and difficulties regarding the enforcement of

those Operators/Hauliers who are registered outside the UK.

It is acknowledged that police resources are limited and other activities are doubtless ascribed

a higher level of prioritisation. As such, the Monitoring Strategy being developed as part of

this Freight Management Strategy seeks to provide an effective mechanism through which to

both establish the outcome of the Area wide restriction and to guide the deployment of

enforcement activities mindful of the pressures on police time. To this end there has, and will

continue to be close collaboration between the County Freight and Data Management

functions, Trading Standards and the Police to produce a robust monitoring strategy which

can guide enforcement and identify progress towards ultimate strategy objectives.

Whilst we acknowledge that enforcement of road traffic regulations for vehicles which are

registered outside the UK is more difficult to achieve than those whose operating base is in

the UK, we do not consider that this is a valid reason for not implementing the regulatory

signing element of the Strategy, although the communications element of the Strategy will

need to acknowledge language variations in the haulage community. To this end the Freight

Map will include translations of key sections of the map into a number of European

languages. Improving the enforcement of road traffic regulations for vehicles registered

outside the UK is a matter for the UK National Government.

TRO Report Final 71

Alternative Routes

In addressing the issue of diversionary routes there is a clear requirement to differentiate

between valid reasons for diversion and those which are not. In this context a significant

influence in the development of the Cotswolds AONB Freight Strategy is the belief that a

significant proportion of HGVs using the A46, A435 and B4008 and routes across

Minchinhampton Common do so to avoid congestion on the routes for ‘through’ traffic. In

other words taking a short cut, or ‘rat-running’. Whilst the County Council’s aim is to

improve the productivity of the road haulage industry, this aim clearly requires a careful

balance with the environmental, social and community impacts of HGV traffic. Managing the

demand for use by HGVs on the routes identified by satellite navigation equipment and those

routes used as short cuts by the local haulage community are also important considerations.

It is acknowledged that from time to time diversionary routes are required when, due to an









Strategy includes a police liaison element, as previously outlined, to ensure that the police are

aware of which routes are suitable and those that are not.

Cost


Freight Management Zone will, as you understand, be close to £500,000. This figure includes

both the capital cost of materials required to deliver the Area wide Freight Management Zone

as well as the collection, collation and analysis of a substantive range of quantitative and

qualitative data considered essential to the development of a robust Strategy which seeks to

balance the needs of all who live in and pass through the area. The re-allocation of in the

order of 30% of HGVs to designated routes is accepted as statistically significant and will

have a tangible impact on the quality of life of those living within this area, as previously

explained.


The key criteria that will be applied to measure the outcomes of the Strategy with regard to

the implementation of the Area wide Lorry Management Zone include a combination of

quantitative and qualitative criteria, including:









Yours sincerely,

for and on behalf of Atkins Highways and Transportation

TRO Report Final 72

Your

Ref:

Our Ref: 5064355/TP/KK/79921

24 September 2008

Ext No:

Mark Quilliam

Fleet Team Manager

Kuehne & Nagel Drinks Logistics

Poplar Way East

Avonmouth.

BS11 0YH

Dear Mr Quilliam


ORDER 2008







In response to your letter dated 28 August 2008, where you lodged your objection to the





Services Unit. In the meantime I would like to take this opportunity to respond to the issues

raised in your letter.

You may or not be aware that there is a County Freight Map. An outcome of engagement

with Operators and Hauliers throughout the development of the Strategy and the Lorry

Management Zone has identified that there is a generally low level of awareness of this

Advisory Freight Route Map. The Map has been in circulation for over 10 years and, albeit

Advisory, it designates routes for HGV use within a four tier hierarchy; roads for long

distance journeys, for local journeys, for access and diversionary use only and for access

only. The Strategy is not looking to make any significant change to the current status of any

of the routes within the proposed Lorry Management Zone, but instead to overcome any

confusion regarding interpretation of their classification and to provide a formal mechanism

that supports their appropriate use. To this end the Area wide 7.5 tonne weight restriction is

intended to encourage HGV through traffic to use designated routes; namely the A417, the

A436, the A40 and the A419. The County Council does not wish to hinder local businesses

TRO Report Final 73

and those with a legitimate need to access sites within this Area, including yourself, and

therefore those Operators and Hauliers who have a legitimate requirement to load and unload

within the zone, or to travel to/from a registered operational base within the zone would be

unaffected by this Area wide Order, as you are aware.

Whilst it is acknowledged that the scale of transfer of ‘through’ traffic off the A46, the A435

and the A4173 is modest, roughly a third of HGVs are forecast to transfer off these routes,

there is evidence to suggest the benefits will be tangible to those who live, work and visit

these locations. The outcomes of the public consultation process indicate the perception that

HGV movements have a material impact on people’s quality of life. A particular benefit will

be an improvement in the visual appearance of the area given the large size and intrusive

nature of HGVs and their incompatibility with high quality landscapes and townscapes.

Similarly there will be a reduction in levels of fear and intimidation from HGVs, particularly

for pedestrians, cyclists and equestrians. A 30% reduction in HGVs is likely to reduce these

impacts although not perhaps, as you state, by as much as some residents might wish.

Therefore, part of the ongoing Strategy will be the development of improved lines of

communication and engagement between the County, Local Communities and

Operators/Hauliers. This is important to manage expectations, develop a greater mutual

understanding and ensure ongoing commitment to the Strategy.





ongoing communications with Parishes in the area is, as outlined, intended to raise the profile

of the Freight Industry and the benefits and necessities their activities provide. The County

Council could also provide proformas for use by Operators to respond to queries raised by the

public which would reduce an additional administrative burden on Hauliers.



Yours sincerely,



TRO Report Final 74

Your

Ref:

Our Ref: 5064355/TP/KK/79923

24 September 2008

Ext No:

Guy Adams

Deben House

Park Road

Stroud

Gloucestershire.

GL5 2JF

Dear Mr Adams


ORDER 2008







In response to your letter dated 29 August 2008, and the follow up letter dated 1 September

2008 where you lodged an objection to the Cotswolds Area wide 7.5 tonne MGW Order,

please be advised that a TRO Committee has been organised for 10:00 am on 14 October

2008 in the Council Chambers at the Shire Hall in Gloucester. As a formal objector you may

well have already been provided with the details of this meeting if not then these will be

provided in due course by the Council’s Democratic Services Unit.

Please find below responses to each of the points raised in your letter.

1. It is common practice for consultants to undertake both strategy work and to implement

those strategies for Highway Authorities in the UK.

2. The County Council undertook a Strategic Environmental Assessment (SEA) as part of the

environmental assessment of the Local Transport Plan. This SEA implicitly addresses the

impact of the Cotswolds AONB Freight Management Strategy. To establish the need for a

scheme specific Environmental Impact Assessment the County Council has recently

commissioned a screening opinion on the need for such an assessment. This assessment has

confirmed that such an Environmental Assessment is not required.

3. The County Council is not diverting resources to the Lorry Management Zone (LMZ). The

LMZ is being funded from Capital resources provided through the Local Transport Capital

TRO Report Final 75

Settlement in accordance with the agreed Local Transport Plan. The Definitive Map

Modifications Orders are funded from Gloucestershire County Councils own resources.

4. The modest re-routing of freight forming the basis of the Strategy is predicated on making

better use of the A419 and removing ‘through’ freight movements from the deeper rural areas

of the AONB. The scale of the transfers combined with existing levels of HGVs on the A419

will result in no appreciable or significant increase in environmental impacts on that route.

Statistics are not used to mask real change but rather to enable comparative appraisal and

account for daily, monthly and annual fluctuations in traffic flow. Central Government

guidance on the appraisal of a wide range of environmental impacts has been developed to

acknowledge and measure real environmental impacts in a meaningful and effective way.

We have undertaken an assessment of the air quality impacts in accordance with Government

guidance and have found that there are no significant air quality impacts.

5. We have reviewed the approaches used in other counties and concluded that the proposals

contained in the Cotswolds AONB Freight Strategy are appropriate for the study area. Whilst

it is acknowledged that the levels of ‘through’ traffic on some of the more minor routes in the

zone are probably very low, the volumes of ‘through’ traffic on the A and B routes are

significant. As a consequence the area wide approach does offer the best value for money

and the best balance in terms of enforcement and sign clutter. Such an approach avoids a

piecemeal response and ensures a consistent and easily understood message is received by the

haulage industry.

6. The network improvement element of the Strategy was at a level of detail commensurate

with the overall strategy and so did not address the detail of carriageway surfacing. Whilst

the precise details of the maintenance regime for the A419 are yet to be developed and

subject to a value for money appraisal, the use of the new generation of material for road

surface overlays which reduce the generation of road noise will be considered.

7. As part of the Data Gathering process for the development of the Freight Strategy an

alternative sign configuration with a satellite navigation theme, as used in the Vale of

Glamorgan, was considered. In the light of consultation with officers in the County Council,

and also following a review of the evidence for alternative signing, it was concluded that the

sign was potentially confusing to HGV drivers as well as requiring a lengthy agreement

process with the Department for Transport, with no guarantee of success. Given that a key

facet of the Strategy is clear signing and enforcement, particularly for vehicles registered

outside the UK, the County Council will maintain an active interest in signing developments

relating to managing HGV movements elsewhere in the UK with a view to incorporating

such signs into the Strategy, should the evidence support it.

8. Our assessments of the negative noise and air quality impacts of the scheme show that the

impacts on those living and working adjacent to the A419 would be negligible. It is worth

noting that the maximum increase in total traffic flows on the A419 is forecast to be less than

1%. The environmental effects of this increase will not be perceptible.

9. The A419 is defined as a route for local journeys in the County Council Advisory Freight

Route Map which is a component of the LTP. It is important to note that the Cotswolds

Freight Strategy simply reinforces the existing roles of the A46, A4173, B4008, A435 and

A419. The County Council Advisory Freight Route Map shows that the A46, A4173, B4008

and A435 have a lesser role than the A419 in that they are for ‘access and diversion’ only,

whereas the A419 is a route for ‘local’ journeys i.e. with, potentially both journey destination

TRO Report Final 76

and origin outside the Freight Management Zone, but inside the County. The Cotswolds

AONB Freight Strategy reinforces these roles and formalises their signing and enforcement.

The signing and enforcement elements would not be required if the haulage industry followed

the advisory routes as set out in the Advisory Freight Map.

It is also important to understand the changing levels of use of the individual sections

throughout the length of the A419, with regards to origins and destinations of journeys and

how these would change with the Strategy in place. The origin and destination surveys

undertaken in May 2007 on eastbound traffic on the A419 to the east of Stroud revealed that

64% of HGVs interviewed were making a journey where either the destination or origin was

in the study area (i.e. between the M5 and Northleach), 22% were making a journey where

both the origin and destination were in the study area and 14% were making a journey where

both origin and destination were outside the study area. This mix of local and longer distance

journeys, where some 86% of journeys has at least one trip end in the study area but also a

proportion of longer distance movements, is typical of routes in the ownership of the Local,

rather than National, Highway Authority.

In terms of HGV routing the LTP defines routes for access and diversion, routes for local

journeys, and routes for longer distance journeys. The aims and objectives of the Cotswold

Freight Strategy do not contradict the allocation of the A419 as a route for local journeys as

the modest increases in HGVs transferring onto the A419 from the A46, A4173 and B4008

are, in the great proportion, ‘local’ by that definition. There is certainly no intention or

expectation that the A419 will carry significant additional long distance traffic as part of the

Cotswolds AONB Freight Strategy, or any other strategy.


Freight Management Zone will be close to £500,000. This figure includes both the capital

cost of materials required to deliver the Area wide Freight Management Zone as well as the

substantive collection, collation and analysis of a wide range of quantitative and qualitative

data considered essential to the development of a robust strategy which seeks to balance the

needs of all who live and work in the area with the needs of the freight industry. The re-

allocation of some 30% of HGVs is considered to be statistically significant and will have a

tangible impact on the quality of life of those living within this area.

10. As stated previously, a TRO Committee has been organised for 10:00 am on 14 October

2008 in the Council Chambers at the Shire Hall in Gloucester. An invitation will be provided

in due course by the Council’s Democratic Services Unit.



With reference to your questions presented at the recent consultation meeting on the 20

August please also find a response attached.

Yours sincerely,



TRO Report Final 77

Cotswolds AONB Freight Strategy

Consultation Response to Mr G Adams.

17 September 2008

This document responds to questions hand delivered by Mr Adams at the TRO Event on 20

August 2008.

Question 1

I would like you to explain what the difference between a resident on the A46 in Painswick

and a resident on the A419 or other proposed definitive freight route is? I would point out

that because of the single file traffic through Painswick that the noise generated is lower than

on a dual lane 40 MPH (or higher comparative route. I would also point out that the

expectation of HGV traffic for comparative residents would be the same – they are all A

roads. One HGV removed from Painswick is one more for the planned alternatives. (just one

– if it is during the night, unladen metal trailer IS noticeable). If GCC plans on treating

similar members of the public differently then what compensation scheme in planned for

those who are disadvantaged?

Response

The study assumed no difference between residents of Painswick and any other town or

settlement in the study area.

The noise generated on a dual carriageway may well be greater than on a single carriageway.

The issue in this context is the relative impact of a change in HGV numbers. The Strategy

relies for its success, in part, on the fact that a signing strategy that results in a modest

reduction in HGVs on a moderately trafficked route, such as the A46, will, for the same

number of vehicles, result in an insignificant impact on a more heavily trafficked route. This

approach supports the aim of the Strategy which is to direct HGVs away from the more rural

parts of the AONB to improve its tranquillity.

The re-routing of vehicles will also mean that Gloucestershire County Council can focus its

investment on specific freight routes, and therefore deliver improved value for money for its

residents and businesses.

Residents on different ‘A’ roads clearly do not expect the same impact. Each resident’s

expectation depends on a number of factors including the historic role of each route, the

volume and type of vehicles using the route and the individual’s characteristics and

experience.

The Cotswolds Freight Management Strategy reinforces the existing roles of the A46, A4173,

B4008, A435 and A419, as set out on the County Council’s Advisory Freight Map. This

shows that the A46, A4173, B4008 and A435 have a lesser role than the A419. The A46,

A4173 and A435 are designated as routes for ‘access and diversion’, whereas the A419 is

allocated for ‘local’ routes with, potentially either the journey destination or origin, or both,

being outside the Management Zone but within the County.

TRO Report Final 78

For those routes forecast to experience a significant increase in HGV traffic the Strategy

contains a number of compensatory activities, subject to the availability of funds, including

the resetting of noisy manholes, and an improved maintenance regime.

Question 2

Why are GCC not adopting an approach similar to Cornwall (which is certainly an attractive

County similar to Gloucestershire)? TRO’s are only considered for excessive HGV use (sect

9.2) – I do not see how 90 (or whatever the figure is) HGV’s per day in Painswick could be

excessive.

Response

There are no clear guidelines as to what constitutes an ‘excessive’ volume of freight traffic in

terms of breaching environmental thresholds. On that basis it is for each Highway Authority

to identify which routes are carrying ‘excessive’ volumes of HGVs based upon local

circumstances and expectations. The Gloucestershire County Council Local Transport Plan

(LTP) is the document containing policies relating to freight transport and which routes

should be targeted for reductions in HGV traffic.

Research undertaken for the Cotswolds AONB Freight Study identified Painswick as a

location where, relatively speaking, the environmental sensitivity was particularly high given

the volume of HGVs using the A46.

A key determinant in the success of the Strategy is the extent to which it is understood by the

haulage industry is enforceable, and is enforced. In that respect the proposals for the

Cotswolds AONB are for an area wide scheme with a set of clearly defined routes for

‘through’ freight traffic supported by a clear signing strategy. Agreement has been reached

with the local constabulary to enforce the signing strategy. It is important to note that the

Strategy reinforces the existing roles of routes, as set out in the County Council Advisory

Freight Route Map.

Question 3

How much is this plan going to cost with Atkins Fees, Signage, TRO’s etc? When GCC is

failing it’s statutory requirements, for example to process definitive map modification orders

(127 outstanding with 1.5 people to process at a rate of a handful a year) how can it be

justified in spending these sums? I suggest that this money would be better spent on GCC

fulfilling it’s statutory obligations and on improving the surface of sections of the A roads in

the designated zone that would benefit all.

TRO Report Final 79

Response

The implementation of the plan, including the costs of strategy development, design and

construction will cost approximately £500,000. The County Council’s priorities for

investment, and the justification for them, are set out in the LTP.

The Strategy does contain recommendations regarding the maintenance of the routes

designated for ‘through’ traffic although the scale of investment in maintenance of these

routes will be subject to available funds.

Question 4

The HGV flow map shows the majority of routes have very low flows – 0,2,3,4 etc per day.

Of these a percentage might be through, so how can you justify the cost and clutter of signage

for such few vehicles?

Response

The routes targeted in the Strategy are primarily the A46, B4008, A4173, and the A435. Our

research indicates that the A46, A4173 and A435 routes have some 30-40 HGVs per day

which can be classed as ‘through’ movements and for which an alternative route is available,

whilst for the B4008 this is nearer 100 vehicles. Removing these ‘through’ movements

would lead to a modest reduction in certain environmental impacts on these routes and would

result in tangible environmental benefits, particularly in the settlements on the routes. In

overall terms these modest reductions would benefit the tranquillity of the AONB. The other

routes to which you refer have been included for two reasons; partly as a result of creating an

enforcement zone to give a clear message to the haulage industry and to enable effective

enforcement, and partly to address the infrequent but high profile impacts of so-called

SATNAV incidents which tend to occur adjacent to the A417. The level of signing has been

kept to an absolute minimum and is proportional to the visually sensitive nature of the

environment and the numbers of HGVs involved.

Question 5

Why are there no recommendations for specialist surface treatments as reference by the local

transport plan (LTP) for ’06 – ’11 for ‘reducing the negative impact of lorries’? These

measures are highlighted as being one of the most cost effective and rapid measures.

Response

The detailed development of the asset maintenance strategy for the A419 and other freight

routes will address which particular form of surfacing is appropriate for the routes. This will

certainly involve the consideration of the new generation of materials now used in road

surface overlays which reduce the generation of road surface noise.

TRO Report Final 80

Question 6

Can you explain why one of the lorries was photographed twice for the parish consultation –

this would imply it was a delivery lorry and not a ‘through route’ problem one. I suggest this

is contrary to the ‘evidence’ based policy.

Response

In the absence of clarity as to which photograph you are referring, it is not possible to

respond to this point with complete certainty. However, to my recollection, we did not show

photographs as part of the parish consultation to solely demonstrate the impacts of ‘through’

freight traffic, but rather to demonstrate that we understood the impacts of freight vehicles,

whether undertaking a ‘through’ or delivery movement. In any event there was absolutely no

intent to mislead, deliberately or otherwise.

Question 7

The stuck lorry image is also confusing – it appears to be a gas delivery lorry (and below

7.5t) and would not be removed by the lorry management area. If this was a sat nav issue

then approaches like those proposed by the Welsh Assembly for simple signage on such

routes would be a more direct and effective solution.

Response

I acknowledge the ‘stuck’ gas delivery lorry could be confusing as it was not a normal case of

HGV misrouting and as a result it was not included in later consultation material. It was

included originally as it was considered to be a particularly powerful visual image

demonstrating the impacts of freight vehicles taking inappropriate routes in the AONB. You

might like to note that this vehicle required removal by a heavy tow truck which resulted in

significant damage to the verge and adjacent wall.

The use of the SATNAV signs, as have been trialled in Wales, has no record of success and

the signs would, in any event, be unlikely to be accepted by the DfT, as is required of all

permanent signs. Whilst we support the use of innovative enforcement techniques they must

have some realistic chance of success otherwise we would be in danger of not offering value

for money. If you have any evidence to support this claim that these signs are a more direct

and effective solution then we would be very interested to receive it.

Question 8

In the LTP ’06-’11, figure 3.2 shows all of the A419 as a route for ‘local journeys’ which is

counter to the designation in the lorry management strategy. Please explain how the

designation of the route has changed?

Response

The LTP definition refers to the ‘local’ role of the route in facilitating freight journeys in the

County. We labelled it as strategic to help hauliers and other consultees understand its role in

the context of the Cotswolds AONB Freight Strategy – the word strategic is generally taken

to mean a route for ‘through’ traffic, although it is also used to refer to the trunk road

TRO Report Final 81

network. Labelling the route as strategic will not result in traffic diverting from national or

regional strategic routes from outside the study area onto it. Another sought outcome from

labelling it as strategic in the context of the study is to identify it as a route to receive

enhanced asset management, subject to available funding, to both reduce the environmental

dis-benefits experienced by those who live or work adjacent to it, and to raise the level of

service of the route to make it more usable for hauliers.

The A419 is defined as a route for local journeys in the County Council Advisory Freight

Route Map which is a component of the LTP. It is important to note that the Cotswolds

Freight Strategy simply reinforces the existing roles of the A46, A4173, B4008, A435 and

A419. The County Council Advisory Freight Route Map shows that the A46, A4173, B4008

and A435 have a lesser role than the A419 in that they are for access and diversion only,

whereas the A419 is a route for ‘local’ journeys i.e. with, potentially both journey destination

and origin outside the Freight Management Zone, but inside the County. The Cotswolds

AONB Freight Strategy reinforces these roles and formalises their signing and enforcement.

The signing and enforcement elements would not be required if the haulage industry followed

the advisory routes set out in the Advisory Freight Map.

The Origin and Destination surveys undertaken in May 2007 on eastbound traffic on the

A419 to the east of Stroud revealed that 64% of HGVs interviewed were making a journey

where either the destination or origin was in the study area (i.e. between the M5 and

Northleach), 22% were making a journey where both the origin and destination were in the

study area and 14% were making a journey where both origin and destination were outside

the study area. This mix of local and longer distance journeys, where some 86% of journeys

has at least one trip end in the study area, is typical of routes in the ownership of the Local,

rather than National, Highway Authority.

The LTP defines routes for access and diversion, routes for local journeys and routes for

longer distance journeys. The aims and objectives of the Cotswolds AONB Freight Strategy

do not contradict the allocation of the A419 as a route for local journeys as the modest

increases in HGVs transferring onto the A419 from the A46, A4173 and B4008 are primarily

‘local’ by that definition. There is certainly no intention or expectation that the A419 will

carry significant additional long distance traffic as part of the Cotswolds AONB Freight

Strategy, or any other strategy.

The Regional Freight Map (RFM), which was drawn up by the Southwest Regional Freight

Forum which comprised the Freight Transport Association, Road Haulage Association and

Local Transport Authorities (LTAs), identifies advisory routes for freight and excludes the

A46, A435 and A4173 by virtue of their lesser role in providing routes for freight, although it

does include the A419 which is identified as a County route. Generally speaking a County

route, in the context of the RFM, is used primarily by vehicles undertaking a journey with

one or both trip ends in the County within which it is located. Clearly it was the view of the

regional body, the freight industry representatives and the LTAs that the A46, A4173 and

A435 were not required for ‘through’ HGV movement. This is compatible with the role of

these routes as shown in the existing County Council Advisory Freight Map.

The Regional Freight Map was included in the draft Regional Spatial Strategy (RSS)

although it has not been identified for inclusion in the final RSS.

TRO Report Final 82

Question 9

The LTP states in relation to air quality ‘it is essential to ensure the problem is not simply

shifted elsewhere. It also states that the air quality objectives are ‘to improve the air quality

throughout the County’. How can the lorry management strategy meet this goal for residents

near the routes that will bear the increased HGV flow?

Response

In responding to this question it is important to note that the air quality implications of the

Strategy have been defined as negligible following an assessment of the air quality effects.

This assessment has shown that on the A419, to the west of its junction with the A46 NO2

and PM10 levels are forecast to increase by between 3% and 6%, whilst on the B4008 NO2

levels will fall by some 14% and PM10 levels by some 11%, on the A46 the reductions will

be 7% and 5% respectively and on the A435 10% and 8% respectively.

Whilst air quality is acknowledged as a key environmental issue for the LTP this has to be

balanced against other considerations. In the context of the Freight Strategy there are a

number of other impacts from freight, which offset the very modest fall in air quality on the

A419. Of these the reductions in visual impacts in the more rural areas of the AONB are

particularly important. There are also particular community benefits to pedestrians, cyclists

and equestrians in the AONB.

TRO Report Final 83

Your

Ref:

Our Ref: 5064355/TP/KK/79919

24 September 2008

Ext No:

Ken Hobden

Director of Planning

Quarry Products Association Limited

Gillingham House

38-44 Gillingham Street

London. SW1V 1HU

Dear Mr Hobden


ORDER 2008








the Quarry Products Association Limited to the Cotswolds Area wide 7.5 tonne MGW

Order, please be advised that a TRO Committee has been organised for 10:00 am on 14

October 2008 in the Council Chambers at the Shire Hall in Gloucester. As a formal objector

you may well have already been provided with the details of this Meeting, if not then these

will be provided in due course by the Council’s Democratic Services Unit.


letter.

Strategy and Objectives In your letter you outline the opinion that “the Strategy is poorly defined in the Statement of

Reasons”, and that “there is no evidence to show that the TRO will achieve the objectives of

the Strategy.”

The Statement of Reasons includes the following statement:

‘This Strategy seeks to balance the need to minimise the impact of freight movement upon

local communities and environments through which they pass and in many cases service,

TRO Report Final 84

whilst at the same time providing operators and hauliers with a safe and efficient route

network.’

It is acknowledged that this is a summary of the objectives of the Strategy. Such a summary

is appropriate for the Statement of Reasons document, particularly when consultation on the

TRO includes manned exhibitions intended to provide more detailed evidence and an

opportunity to discuss the Strategy with representatives of the Project Team.

Furthermore, our analysis and interpretation of the detailed data collected has shown that a

third of HGVs are forecast to transfer off unsuitable routes. This level of transfer is used as

evidence to suggest the benefits will be tangible to those who live, work and visit the areas

affected by the TRO. The outcomes of the public consultation process confirm the perception

that HGV movements have a material impact on people’s quality of life. A particular benefit

will be an improvement in the visual appearance of the area given the large size and intrusive

nature of HGVs and their incompatibility with high quality landscapes and townscapes.

Similarly there will be a reduction in levels of fear and intimidation from HGVs, particularly

for pedestrians, cyclists and equestrians. A 30% reduction in HGVs is likely to reduce these

impacts, although not perhaps by as much as some residents might wish. Part of the ongoing

Strategy will be the development of improved lines of communication and engagement

between the County, Local Communities and Operators/Hauliers. This is important to

manage expectations, develop a greater mutual understanding and ensure ongoing

commitment to the Strategy.







Impact of HGV Transfers on Existing Operation/Safety of Designated Routes


wide Lorry Management Zone on the safety and operation of the designated routes. In

response, these routes are discussed separately in more detail below.






of the Study.








TRO Report Final 85


carriageway.













A419









The Cotswolds AONB Freight Study has identified that the HGV transfers from the A46,

B4008 and A4173 to the western end of the A419 would amount to some 162 HGVs per day

(an increase of 17% HGVs or 0.7% total traffic) and would be likely to increase delay on this

section of the corridor by some 2.2% over existing in the morning peak period and by some

0.2% in the evening peak. Delay during the rest of the day is likely to be below this level. In




programme.




Strategy. However, in response to requests from the Road Haulage Industry major structural



Proposed Restriction of HGV Movements on A435, A4173 and A46

In your letter you cite concerns regarding the proposed restricted status of the A46, A435 and

A4173. Historically, ‘A’ class roads have catered for longer distance movements, particularly

those of HGVs. However, the introduction of the motorway system in the 1960s established

an additional tier in the national highway network which has provided significant additional



TRO Report Final 86

network to cater for freight. It does not follow however, that ‘A’ road capacity, especially

through areas with particularly high environmental value, should be retained to cater for that

loss of capacity. A relevant consideration is the need to manage demand for single

occupancy light vehicle commuting to release network capacity for freight movements. All

Transport Authorities in the UK have, to a greater or lesser extent, policies to address this

within their Transport Plans. A national road user charging scheme which would assist in

reducing the level of demand by non-freight traffic, and release capacity for freight, is

currently on hold.

You may or may not be aware that there is a County Freight Route Map. This Map has been

in circulation for over 10 years and, albeit Advisory, it designates each of the routes to which

you refer as ‘for access and diversionary use only’. The Strategy is not therefore looking to

make any significant change to the current status of routes within the zone, but instead to

provide a formal mechanism that supports their use. The introduction of an Area wide Lorry

Management Order intends to reinforce the use of the A46, A4173 and A435 as routes for



circumstances.

In turn, the Regional Freight Map (RFM), drawn up by the Southwest Regional Freight

Forum and agreed with the Road Haulage Association (RHA), the Freight Transport

Association (FTA) and Local Transport Authorities (LTAs), identifies the wider network of

advisory routes for freight. This Map excludes the A46, A435 and A4173, although it does

include the A419 which is identified as a County route. Generally speaking a County route, in

the context of the RFM, is used primarily by vehicles undertaking a journey with one or both

trip ends in the County within which it is located. Clearly it was the view of the regional

body, the freight industry representatives and the LTAs that the A46, A4173 and A435 were

not required for ‘through’ HGV movement. This is compatible with the role of these routes as

shown in the existing County Advisory Freight Route Map. The Regional Freight Map was

included in the draft Regional Spatial Strategy (RSS) although it has not been identified for

inclusion in the final RSS.


Strategy and the Lorry Management Zone identified that there is a generally low level of

awareness of the County Freight Route Map. We appreciate that communication and

engagement are an important part of both ensuring wider awareness of the Freight Route Map

by Operators/Hauliers and greater understanding by the local communities of the important

role that the Freight Industry plays within the local economy. This would be addressed as part

of an ongoing Communications and Engagement Strategy should the Order be made.

Access to Operational Premises within the TRO Zone

In your letter you raise the issue that Article 3 of the Draft Order gives no exemption other

than for loading and unloading. We can clarify that those with a legitimate need to access

sites within this Area, including yourself, and therefore those Operators and Hauliers who

have a legitimate requirement to load and unload within the zone, or to travel to/from a

registered operational base within the zone would be unaffected by this Area wide Order. The

TRO will be amended to include travel to and from a registered operational base within the

zone.

Through Route Movements will be Disadvantaged

TRO Report Final 87

The County Council does not wish to hinder local businesses that operate within or outside of

the TRO area. As already clarified those with a legitimate need to access sites within the

TRO Area are permitted to do so. It is acknowledged that a small proportion of vehicles who

may be seeking to take a short cut through the Zone will be required to travel further,

however, on balance, this modest inconvenience is outweighed by the benefits to those who

live or work adjacent to, or otherwise use the A46, A4173 or A435.

Emissions/Air Quality In response to your concerns regarding carbon emissions, in line with the development of the

Strategy we have carried out assessments of likely impact on air quality, noise and CO2

emissions. The outcome of these assessments identified that the Strategy will result in a

maximum of a 0.5% increase in CO2 within the Study Area, and the impact on air quality and

noise will be similarly negligible. These figures have been calculated through assessing the

impact of the HGVs rerouted onto the A419 and A417 routes.


In your letter you raise concern as to whether the restrictions will achieve the objectives of

the Strategy. As well as the benefits outlined under the ‘Strategy and Objectives’ above, there

are a number of key criteria that will be applied to measure the outcomes of the Strategy.

Measurement of the benefits of implementation of the Area wide Lorry Management Zone

include a combination of quantitative and qualitative criteria, as set out overleaf.







Quieter HGVs and less Extraction

We acknowledge your comments that HGVs are now quieter and that extraction activity is

reducing in the AONB. However, the consultation outcomes identifying the problems caused

by HGVs were obtained relatively recently in 2007, which clearly included the noise impacts

of existing vehicles.

Identification of a Problem

In your letter you raise concerns that you believe no significant problems have been identified

in the AONB related to HGV movements and, as such, the Strategy and the Lorry

Management Zone are considered to be unjustified.

The Strategy has been developed through a comprehensive qualitative consultation process

with both the Haulage Industry and the Local Communities via their Parish Councils. The

Strategy has also sought detailed quantitative evidence through a number of survey

techniques. Origin and Destination Surveys are particularly useful in identifying which HGV

journeys are ‘through’ journeys and could transfer to another route, and which are delivering

locally and need to continue to use the route. Origin and Destination surveys can be carried

out in a number of ways. To inform this Study two forms of Origin and Destination Survey




TRO Report Final 88


A46 and A419. These Surveys have provided information to inform the development of the


Cost


Freight Management Zone will be close to £500,000. This figure includes both the capital

cost of materials required to deliver the Area wide Freight Management Zone as well as the

collection, collation and analysis of a substantive range of quantitative and qualitative data

considered essential to the development of a robust Strategy which seeks to balance the needs

of all who live and work in the area and the needs of the freight industry. The re-allocation of

30% of HGVs to designated routes is accepted as statistically significant and will have a

tangible impact on the quality of life of those living and working within this area.

Proposals Run Counter to Climate Change Objectives It is acknowledged that there will be a very small increase in CO2 emissions as a result of the

Cotswolds AONB freight strategy. However, this very small increase in CO2 emissions

(around 0.5%) will be offset by tangible reductions in HGVs on the A46, B4008, A4173 and

A435.

Draft Order Published without Prior Referral to FQP

The FQP met on 28 March 2008 at Bentham Country Club to put forward the objectives of

the Strategy. In addition to this meeting all Hauliers, Stakeholders and Parishes were

informed of the Draft TRO by post in advance of public advertisement of the Order.

The objectives of the Strategy were developed following an extensive data gathering process

including Parish and Operator/Haulier consultation. The objectives, and how they will be

delivered by the Strategy, as agreed with the Freight Quality Partnership, are set out as

follows:

• Identify and maintain freight routes that enable the movement of freight in a safe and

economically efficient manner, and ensure widespread awareness of these routes by

the freight industry (Delivery: Re-publication of the freight map for the study area,

reinforcing the ‘through’ routes for freight. This map will also be available on the

County Council website and will be publicised at the launch stage of the Strategy.

Consideration will be given to the translation of the map into a number of European

languages);

• Reduce the impact of HGVs on the part of the road network that is used only for local

access (Delivery: Through use of 7.5 tonnes weight restriction order applied across

the area (with exemptions for loading, unloading and access to operational base)

which will reduce the volume of HGVs by between 25 and 47%);

• Reduce the frequency and severity of incidents relating to mis-use of SATNAV

(Delivery :Through the use of signing and enforcement);

• Ensure that people living, working in and visiting towns and villages are fully aware

of the role of road freight (Delivery: Through the communications element of the

Strategy which is part of the launch stage); and

• Identify a series of actions to encourage the delivery of additional road capacity for

freight on through routes (Delivery: Through targeted improvements in the longer

term)

TRO Report Final 89



Yours sincerely,



TRO Report Final 90

Your

Ref:

Our Ref: 5064355/TP/KK/79927

24 September 2008

Ext No:

Roger Cullimore

Moreton C Cullimore & Son Ltd

47 London Road

Stroud

Gloucestershire.

GL5 2AU

Dear Mr Cullimore


ORDER 2008







In response to your letter dated 5 September 2008, where you lodged an objection to the





Services Unit.


letter. I reply to each of the points raised in your letter using your original notations.

3. The County Council does not wish to hinder local businesses and those with a legitimate

need to access sites within this Area, including yourself, and therefore those Operators and

Hauliers who have a legitimate requirement to load and unload within the zone, or to travel

to/from a registered operational base within the zone, would be unaffected by this Area wide

Order.

4. In your letter you cite concerns regarding the restricted status of the A46, A435 and A4173

to loading/unloading and access to/from an operational base only within the proposed Lorry

Management Zone. Historically, ‘A’ class roads have catered for longer distance movements,

particularly those of HGVs. However, the introduction of the motorway system in the 1960

and 70s established an additional tier in the national highway network which has provided

TRO Report Final 91

significant additional capacity for the long distance movement of freight. It is acknowledged

that use of the motorway network for commuting purposes has, over time, reduced the

capacity of that network to cater for freight. It does not follow however, that ‘A’ road

capacity, especially through areas with a particularly high environmental value, should be

retained to cater for that loss of capacity. A relevant consideration is the need to manage

demand for single occupancy light vehicle commuting to release network capacity for freight

movements. In that respect all Transport Authorities in the UK have, to a greater or lesser

extent, policies to address this within their Transport Plans. A national road user charging

scheme which would assist in reducing the level of demand by non-freight traffic, and release

capacity for freight, is currently on hold.




over 10 years and, albeit advisory, it designates each of the routes to which you refer as ‘for



formal mechanism that manages their use. The introduction of an Area wide Lorry




circumstances.


agreed with the Road Haulage Association (RHA) Freight Transport Association (FTA) and

Local Transport Authorities (LTAs), identifies the wider network of advisory routes for

freight. This Map excludes the A46, A435 and A4173 and routes across Minchinhampton

Common, although it does include the A419 which is identified as a County route. Generally

speaking a County route, in the context of the RFM, is used primarily by vehicles

undertaking a journey with one or both trip ends in the County within which it is located.

County routes were allocated for journeys ‘local’ to the area. Clearly it was the view of the

regional body, the freight industry representatives and the LTAs that the A46, A4173, A435

and routes across Minchinhampton Common are not required for ‘through’ HGV movement.

This is compatible with the role of these routes as shown in the existing County Advisory

Freight Route Map. The Regional Freight Map was included in the draft Regional Spatial

Strategy (RSS) although it has not been identified for inclusion in the final RSS.

5. We note that you have raised a number of issues with regard to the operational

performance of the network, particularly the level of service offered to HGVs. We are

acutely aware of these issues, particularly at St Mary’s Corner, which were first raised in the

public consultation events last year. The Cotswolds AONB Freight Strategy does identify the

need for a longer term strand of investments to improve certain sections of the network,

particularly the A419. In response to requests from the Road Haulage Industry major

structural maintenance is due to start in February 2009 on the A419 East of Stroud between

Ham Hill Lane and Brimscombe, also between Dark Lane and Marle Hill.





TRO Report Final 92













programme.

In relation to your comments raised on Minchinhampton, our analysis suggests a significant

proportion of HGVs using the A46, A435 and B4008 and routes across Minchinhampton

Common do so to avoid congestion on the routes for ‘through’ traffic. In other words taking a

short cut, or ‘rat-running’. Whilst the County Council’s aim is to improve the productivity of

the road haulage industry, this aim clearly requires a careful balance with the environmental,

social and community impacts of HGV traffic. Managing the demand for use by HGVs on the

routes identified by satellite navigation equipment is also an important consideration.

Given the poor quality of the routes across Minchinhampton Hill and the particular

environmental sensitivity of the Common we do not consider these routes are suitable for use

as ‘through’ routes by HGVs in excess of 7.5 MGW.

6. A monitoring strategy is being developed as part of this Freight Management Strategy both

to establish the outcome of the Area wide restriction and to guide the deployment of

enforcement activities. This Strategy element is mindful of limited police resources. To this

end there is close collaboration between the County Freight and data management functions,

Trading Standards and the Police to produce a robust monitoring strategy which can guide

enforcement and identify progress towards the Freight Strategy objectives. Whilst we

acknowledge that enforcement of road traffic regulations for vehicles which are registered

outside the UK is more difficult to achieve than those whose operating base is in the UK, we

do not consider that this is a valid reason for not implementing the regulatory signing element

of the strategy, although the communications element of the strategy will need to

acknowledge language variations in the haulage community. To this end the freight map will

include translations of key sections of the map into a number of European languages.

As part of the Data Gathering process for the development of the freight strategy an

alternative sign configuration with a satellite navigation theme as used in the Vale of

Glamorgan was also considered. In the light of consultation with officers in Gloucestershire

County Council, and also following a review of the evidence for alternative signing, it was

concluded that the sign was potentially confusing to HGV drivers as well as requiring a

lengthy agreement process with the Department for Transport, with no guarantee of success.

A key facet of the Strategy is clear signing and enforcement, particularly for vehicles

registered outside the UK, however the County Council will maintain an active interest in

signing developments relating to managing HGV movements elsewhere in the UK with a

view to incorporating such signs into the Strategy, should the evidence support it in time.

TRO Report Final 93

7. You raise a number of issues relating to the operation of the A417, cited in points six and

seven of your letter. The County Council is strongly committed to maintaining the safety and

operation of its network. Whilst the A417 is part of the Highways Agency (HA) and not the

County Network it represents a key route within the proposed Cotswolds Area wide Lorry

Management Zone and, as such, a detailed assessment of the impact of this restriction on both

the accident record and capacity of this route, and all others within the area, has been

undertaken as part of the Study.

In terms of road safety, here have been 156 accidents reported on the 24km section of the

A417 between Cirencester and the M5 J11a within the five year period 2001-2005; 34 of

these involved HGVs. Of these, 20 HGV accidents have occurred on the section of the A417

between Crickley Hill and Nettleton Bottom. The majority of these accidents occurred on the

section between Little Witcombe and Birdlip (Crickley Hill); seven of which have resulted in

more serious injury. Detailed analysis has not identified any common contributory factors

through this section, although all four accidents reported at the Air Balloon Roundabout were

the result of HGVs overturning whist negotiating the circulatory carriageway.









transfer of HGVs from the A435. It is also worth noting that, with the maximum monthly

variation of HGVs on the A417 being around 1,000 vehicles, the change arising from transfer

of the A435 vehicles can also be considered negligible.

8. We acknowledge that there are modest increases in fuel use and vehicle mileage associated

with the HGV re-routings within the Cotswolds AONB Freight Strategy. However, these

disadvantages are outweighed by the benefits of the HGV re-routing on the quality of life of

those living within the Freight Management Zone. .



Yours sincerely,



TRO Report Final 94

Your

Ref:

Our Ref: 5064355/TP/KK/79920

24 September 2008

Ext No:

Duncan Needham

Max Engel Solicitors

8 Hazelwood Road

Northampton.

NN1 1LP

Dear Mr Needham,


ORDER 2008




letter of objection, on behalf of your Client, to the 7.5 Tonne MGW Restriction Order 2008 to

provide you with a fuller understanding of the Strategy to allay your concerns and give you

the opportunity to reconsider your objection.

In response to your letter dated 5 September 2008, where you lodged an objection to the

Cotswolds Area wide 7.5 tonne MGW Order on behalf of your Client Mr Bellone, please be

advised that a TRO Committee has been organised for 10:00 am on 14 October 2008 in the

Council Chambers at the Shire Hall in Gloucester. In acting on behalf of a formal objector

you may well have already been provided with the details of this Meeting, if not then these

will be provided in due course by the Council’s Democratic Services Unit.

Although we are still awaiting further clarification as to the specific nature of your Client’s

objection, I thought it might be useful to provide a little further clarification regarding

common misconceptions relating to the Area wide Lorry Management Zone and what it

means to those who have a registered base within this zone.

Your Client may or may not be aware that there is a County Freight Route Map. This Map

has been in circulation for over 10 years and, albeit Advisory, it designates routes for HGV

use within a four tier hierarchy; Roads for long distance journeys, for local journeys, for

access and diversionary use only and for access only. The Strategy is not looking to make any

significant change to the current status of any of the routes within the proposed Lorry

Management Zone, but instead to overcome any confusion regarding interpretation of their

classification, and to provide a formal mechanism that supports their appropriate use. To this

end the 7.5 tonne weight restriction is intended to encourage HGV through traffic to use

designated routes; namely the A417, the A436, the A40 and the A419. The County Council

TRO Report Final 95

does not wish to hinder local businesses and those with a legitimate need to access sites

within this Area and therefore those Operators and Hauliers who have a legitimate

requirement to load and unload within the zone, or to travel to/from a registered operational

base within the zone would be unaffected by this Area wide Order.

I trust the above points of clarification help to allay Mr Bellone’s concerns and allow him to

reconsider his objection to the order.

Yours sincerely,



TRO Report Final 96

Appendix D

Objection Resolved/No Further Details Provided:

Name Address Comment

5 Mark Quilliam on behalf of Kuehne and Nagel

KN Drinks Logistics, Poplar Way East, Avonmouth, BS11 0YH

Mark Quilliam representing Kuehne and Nagel Drinks Logistics, is directly addressed by the modifications to the Draft TRO (as detailed in the following Section 7.3) which clarifies legitimate access for loading and loading as well as to/from an operational base within the LMZ.

10 Max Engel Solicitors on behalf of

Mr N Bellone

Mr N Bellone Manor Farm Bagendon GL7 7DX

The letter stated that further detail regarding the specific nature of the objection could be expected within ten days of this stated objection, but no such clarification has been received to date.

Objections Remaining:

Name Address Comment

1 Ian Gallagher (FTA) FTA, Midlands West and Wales, Hermes House, 20 Coventry Road, Cubbington, Leamington Spa, Warwickshire, CV32 7JN

Representing their regional members

2 Colin Mar-Gerrison (Hewden)

Hewden, Battledown Works, King Alfred Way, Cheltenham, Glos, GL52 6QP

3 Mike Farmer (RHA)

Midlands and Western Region, Roadway House, Cribbs Causeway, Bristol, BS10 7TU

Representing their regional members

4 Rex Horsman (Transrex)

7 Blacksmith Lane, Churchdown, Glos, GL3 2EU

The objection was a duplicate of the RHA letter.

6&7 Mr Guy Adams Deben House, Park Road, Stroud, Glos GL5 2JF

Two letters provided by this member of the public have been treated as one objection. A response to questions hand delivered to one of the TRO manned events was also included in the response.

8 Ken Hobden (QPA) Gillingham House, 38-44 Gillingham Street, London SW1V 1HU

9 Roger Cullimore (Moreton C Cullimore & Son Ltd)

47, London Road, Stroud GL5 2AU

TRO Report Final 97

Appendix E Extract from Advisory Freight Map

TRO Report Final 98

Appendix F Example of Signing in the Vale of Glamorgan

SatNav Signing Example – Vale of Glamorgan

TRO Report Final 99

Appendix G Draft Monitoring and Management Strategy

Project: Cotswold Freight Management Strategy

Subject: Ongoing Management, Monitoring & Communications Strategy

Date: October 2008 Written: KK

Ref: MonitoringandManagementStrategy.doc Reviewed and Authorised: JC

Introduction

To ensure the continued momentum and success of the Freight Management Strategy

consideration will need to be given to ongoing activities required in order to achieve this,

together with their associated revenue costs. This Note sets out the scope and more

significant elements of the key ongoing activities that would be required within three broad

functions; namely Monitoring, Management and Communications.

Monitoring

The development and application of an effective Evaluation and Monitoring Strategy for the

first Lorry Management Zone (LMZ) within the Cotswolds AONB is a fundamental ongoing

function. With the design and implementation of this signing element of the Strategy likely to

cost in the order of £500,000 there is a clear requirement that the performance of this

Strategy is assessed to establish the extent to which it is delivering it’s objectives and in turn,

establish the scope for extension of the zone to the wider Cotswolds area, or the application

of a similar area based approach to other parts of the county.

The development of the Strategy has revealed that its cost effective delivery and ongoing

success will depend heavily on a coordinated approach by the County Council across a

number of departments within the Council and Gloucester Highways as well as a number of

other key Stakeholders including the Police, the Parishes, the FQP, the AONB and

engagement with both the Operators/Hauliers and the local communities.

This Note sets out the scope for coordination and engagement across all internal and

external Stakeholders in order to inform and guide the development of the Strategy. Where

possible, to ensure best value for the County, the activities as identified in this draft

Monitoring Strategy should form part of the County Council’s current ongoing data collection,

management and reporting processes. Every effort should also be taken to ensure that any

data collection activities additional to those currently undertaken should be designed to

ensure that the scale of data collection is just enough to establish a robust understanding of

prevailing conditions. This Scope is set out on the basis of both of these key principles.

Key Performance Indicators

Key Performance Indicators (KPIs) which could be applied to understand the outcomes of

the first LMZ and progress towards delivery of the Strategic objectives include:

TRO Report Final 100

• Number of HGVs on A46, A4173, A435 and B4008;

• Proportion of ‘through’ traffic on these routes;

• Perception by residents, workers and visitors to towns and villages on these routes that numbers, size and impacts of freight vehicles are acceptable;

• Perception by freight industry that there has been no detrimental impact on their business as an outcome of the implementation of the Zone.

In addition to the use of quantitative traffic survey and qualitative consultation techniques to

gain the necessary intelligence to monitor performance against KPIs there are further data

sources that would also assist in both the specific evaluation of the LMZ as well as provide

further guidance in the subsequent development of the wider Freight Strategy. These

include:

• Scale and extent of enforcement action: - Number of attempted and successful prosecutions for weight limit violations brought by the police; - Numbers of non-UK registered HGVs stopped for weight limit violations by police; - Number of successful and attempted civil actions brought by Gloucestershire County Council Trading Standards for HGV weight limit violation;

• Views of Area Stakeholder Managers and other GCC/GH staff;

• Number of calls to Trading Standards;

• Number of calls to County Council and/or visits to Freight website;

• Number of reported SATNAV incidents obtained from Parishes and the local media;

• Awareness of Advisory Freight Map; and

• Activities and events to raise the profile of freight within the LMZ; such as evening meetings, awareness campaigns (using the local media, leaflet distribution, mobile signing, use of Freight Information Points).

A broad outline of proposed approaches to attain key qualitative and quantitative data to

determine performance of the LMZ in relation to the KPIs as presented in this Note are set

out in the following sections, together with outline costs to undertake these functions. Further

actions, and associated costs and resources, required to gather additional data to inform

both progress with the LMZ as well as the ongoing development of the Strategy (as set out

in Paragraph 2.2.2) are detailed within the following Management and Communications

sections of this Scoping Note.

Traffic Data

Whilst the success of the LMZ will depend heavily on the perception of the change in HGV

volumes on routes within this zone, there is nevertheless a requirement to collect traffic data

to provide an evidential base which identifies the ‘real’ change in HGV numbers. To this end,

manual classified counts (MCC) should be undertaken on the key routes (namely the B4008,

A46, A4173, A435 and two locations to the east/west on the A419) to establish a ‘baseline’

prior to implementation of the LMZ.

Following implementation of the LMZ it is proposed that further surveys are undertaken on

an ongoing periodic basis at the same locations on these routes against which progress

towards strategic objectives can be effectively monitored. The proposed approach is outlined

as follows:


• Annual Surveys: - 12 hour manual classified count (MCC) data on a minimum of one (neutral)

day – to accurately differentiate HGV traffic (7.5t/>18t) from other vehicles; and

- Automatic traffic count (ATC) data capable of reliably differentiating HGV traffic from other vehicles, for a minimum of one week before and after the MCC.

• Three Yearly Surveys: - 12 hour manual (or electronic) registration number surveys to identify if HGV

traffic is breaching the proposed weight restriction. The ‘preferred’ Option would be to also undertake the registration surveys on an annual

basis but, mindful of likely financial constraints, a three yearly basis has been presented as

what is considered to be an acceptable compromise to supplement the information attained

from the annual surveys.

It is acknowledged that there are numerous permanent ATC sites throughout the county, and

within the LMZ, however it is not possible to programme these to accurately capture and/or

differentiate between HGV movements. Therefore, for the purpose of this Scoping Note ATC

data capture would be for a minimum two week period on the routes, as previously detailed,

using tube detectors with an ‘FHWA’ setting. This does not provide the level of accuracy to

differentiate between 7.5tonne and >18tonne vehicles but will more accurately classify all

those vehicles of >7.5 tonne. This information can then be used to better understand the

context of the Manual counts and provide a basis for validation.

The cost to undertake the 12hour manual surveys at six locations within the LMZ (the

B4008, A46, A4173, A435 and two locations to the east/west on the A419) is likely to be in

the order of £3.5k per annum. The cost of the ATCs over a two week period (prior to and

following the manual counts) would be in the order of £1,600. The cost to undertake 12hour

O-D surveys on these routes would be approximately £8k every three years.

Investment by the County in increasingly more sophisticated data recording equipment can

only serve to better inform this Strategy over time and the practical application of such

technologies will be incorporated within this Monitoring Strategy as/where this may become

available. The use of electronic data collection techniques is also likely to provide significant

cost savings to those presented within this draft Strategy.

Attitudinal Surveys

i. Local Community and Visitors within the LMZ

The requirement for these surveys is to establish the opinion of residents, workers and

visitors to the LMZ as to the impact of HGV traffic within this area on their quality of life.

These surveys will need to identify a series of questions to elicit a realistic view. It is

suggested that the survey will seek to identify any change that has occurred in the

perception of the impacts of HGV traffic from that captured from the previous consultation

work undertaken in 2007 as part of the development of the Strategy.

Given the lack of clear guidance as to the linkages between HGV flows and environmental,

social and community impacts it may be worth considering setting out some of the more

significant impacts in the questionnaire and determining people’s experience of those

particular impacts. Such impacts could include:


• Visual/townscape;

• Tranquillity;

• Fear and intimidation, particularly for pedestrians, cyclists and equestrians; and

• Noise, dust and vibration.

Whilst feedback is welcomed on an ongoing basis, and encouraged through telephone

communications and a dedicated website, it is proposed that this more ‘anecdotal’ feedback

would be supplemented by the outcomes of a more formal survey approach. There may well

already be a questionnaire based investigation used to establish public attitudes to transport

issues, for example as part of previous Local Transport Plan consultation and, as such,

consideration should be given to use of existing data collection processes before considering

the use of additional data collection. However, this Scoping Note presents the proposal for

an annual survey with the production/random distribution of up to 200 questionnaires

throughout the zone (letter-drop/availability at key locations). The number of completed

questionnaires will be critical in establishing a reliable and statistically representative sample

and so to this end, and mindful of associated cost implications to produce/distribute hard

copies, it is proposed that the questionnaire would also be made available on the website,

providing an open invitation for on-line completion. Costs associated with development,

production and distribution in this respect would be based upon up to 200 completed

questionnaires and is likely to be in the order of £500.

ii. Operators/Hauliers within the LMZ

One of the more significant outcomes of the early engagement with the Freight Industry,

through workshops and FQP liaison, as well as subsequent TRO consultation was the view

that this Strategy will add significant additional cost and administrative burden to the sector.

A particular concern was that Hauliers operating legally in the zone would be the target of

public concern and activities, such as telephone calls and letters of complaint and that

Trading Standards would also make increased enquiries of Hauliers as part of the Lorry

Watch process.

One of the aims of the Monitoring Strategy would be to establish, with as much certainty as

possible, the actual impact on productivity of the industry of these activities. To this end, it is

proposed that a brief proforma be developed to record the number and type of enquiries

within the LMZ following implementation of the zone.

Feedback is welcomed on an ongoing basis, in the same way as for any others living or

working in the zone, or passing through, as previously detailed. This again would be

encouraged through telephone communications and the dedicated website. A formal survey

approach is also recommended. A questionnaire could be made available to those operating

within or passing through the LMZ to establish the view of the haulage community as to the

impacts of the Strategy. This questionnaire would need to identify a number of particular

areas of concern, such as:

• Scale of re-routing to conform to restrictions;

• Additional administrative burden responding to queries from members of the public and Trading Standards; and

• Improved levels of service offered by the highway network following investment by GCC in A419.


Again, this Scoping Note presents the proposal for an annual survey with the

production/random distribution of up to 200 questionnaires throughout the zone (letter-

drop/availability at key locations) and flexibility for on-line completion via the County

dedicated Freight website. Costs associated with development, production and distribution in

this respect would be based upon up to 200 completed questionnaires and is likely to be in

the order of £500.

Data Reporting

The main cost for the County Council in assembling, managing and reporting the outcomes

of the qualitative and quantitative data, as set out in this section, will be the Officer time. A

likely requirement to manage the data collection and reporting activities associated with the

LMZ, would be in the order of 25 man days per annum (approximately half a day a week) of

a ‘Transport Planner’ grade, at a cost of approximately £3.5k.

Management

In addition to the data reporting functions specific to monitoring the LMZ the appointment of

an internal ‘Freight’ champion will be fundamental to ensure the ongoing development,

momentum and overall success of both the LMZ and the wider Freight Management

Strategy. Key ‘essential’ activities associated with this role would include:

• Fielding day to day enquiries and issues with regards to the LMZ and wider Freight Strategy (via telephone, letter, email and web-based contact).

• Maintenance of the website – possibly updated with monthly news (e.g. Community/Operator relationships, SatNav latest, Lorry Watch activities, network improvements, progress with subsequent stages of the ‘roll out’ to the wider Cotswolds AONB).

• Management of the Freight Information Points – ensure these are well maintained and have up to date information.

• Ongoing monitoring of the performance of the Freight Network, in respect to KPIs (as set out in Section Two) and periodic reporting (which is likely to encompass internal/external reporting and also input to the GCC Annual Lorry Monitoring Report).

• Internal cross-department liaison with other internal Officers – including Area Highway Managers, Asset Management, Road Safety, Data Management.

• External liaison with key Stakeholders – e.g. Parishes, FQP, AONB – possibly as an ongoing Agenda Item on their periodic meeting schedules.

• Periodic liaison with Trading Standards, Lorry Watch and the Police to develop and apply an effective ‘intelligence based’ route monitoring/targeted enforcement programme.

• Assist in the organisation of local Community/Operator Forums – to encourage the management of freight issues at a local level.

• Monitor developments with SatNav and relevance/application for the County.

• Progression with potential Gateway Signing on all entries to the AONB, on completion of the full Freight Management Strategy for this area.

Communications

In addition to the management functions considered fundamental to ensure the ongoing

development, momentum and overall success of both the LMZ and the wider Freight

Management Strategy a GCC ‘Freight’ champion would also need to undertake a

‘Communications’ role in order to maintain the profile of the Freight Management Strategy.


The more specific scope of the role would need to be considered in line with available cost

and resource but, key ‘desirable’ functions would include:

• Operation of an Internal Stakeholder Group, to meet on a potentially quarterly/half yearly/annual basis to better coordinate activities and ensure ongoing momentum of the Strategy.

• FQP/FTA/RHA/AONB/Parish Liaison – attendance at periodic meetings to communicate status of the Strategy and gain any associated feedback.

• Organisation/production/application of publicity material/awareness campaigns on a periodic basis

• Operation of a Cotswolds AONB External Stakeholder ‘Area wide’ Forum to encourage improved engagement between Freight Operators/Key Stakeholders on a periodic basis (supported by a network of locally based Working Groups meeting on a more regular basis).

It is recommended that one Officer could undertake the ongoing Freight ‘champion’ role and

that in the order of two days a week would be required to undertake both the Management

and Communications functions (at a potential total annual cost in the order of £12k).

Traffic Regulation Committee 14 October 2008 Agenda Item...

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