Moorhouse Tile Works revised planning application.
Reference 2106/1036.
Westerham Town Council response to the Transport Commentary
of 21st October 2016.
Our response to this Transport Commentary repeats our previous concerns over the inconsistency of information between the application and website public statements of DPD, as well as the lack of robustness in the statistics.
The following points explain the shortcomings and the increased adverse impact upon Westerham and surrounding area.
As a result our objection is maintained.
- Enlargement of the population catchment. Page 7.
The applicant has provided previously a DPD map and relevant postcodes in respect of the area to be served from Moorhouse.
From Census data that area population is 865,000.
The page 7 postcode areas are a doubling of the population catchment to 1,731,000.
Analysis of the additional postcodes includes areas where DPD already have depots, Dartford, Crawley and Croydon.
We must assume these depots are at capacity or to be redeveloped as it does not seem logical to deliver to an area an hour away where there is already a local depot.
These depots account for 734,000 of the increased catchment.
The enlargement doubles the parcel delivery capacity and thereby the requirement for a commensurate increase in LGVs and traffic movements.
The east /west distribution which results is approximately 50/50 but the increased traffic volume entirely impacts upon Westerham as the conduit to the eastern catchment.
- Parcel numbers.
The expansion of the catchment enables industry ratios of parcels to population to entirely support the depot starting capacity of 25,000. This capacity is now acknowledged by the applicant and DPD as the base for growth over the five years, post build.
Depot growth rates of 16% per annum are being achieved together with another 30% over the Christmas period, (defined by DPD as their “fifty days of peak”).
- LGV numbers.
Using the page 9 average of 138-153 parcels per van and starting capacity of 25,000 parcels an initial fleet of 172 is required.
Anticipated growth in DPD’S fast expanding business and under utilisation of unloading and sorting equipment must also be allowed for.
Continuing 16% growth envisages LGV numbers in five years’ time of over 300.
- Junction safety.
The 100 LGV base, plus 50%, for safety modeling in the light of point 3 aboveis wholly inadequate.
Further the unrestricted single carriageway speed of the A25 results in peak 7-9am traffic passing every 3.6/3.8 seconds at an average speed in the order of 45mph.
We believe the junction proposals are unsafe at the LGV levels which now result from more realistic numbers, (see para 3).
- Site comparator Dagenham.
Using this site as a comparator is inappropriate. There is a population density of 187,000 within a supply radius of 2 miles.
Stoke has 250,000 within 3 miles and Cardiff 340,000 within 3 miles.
Moorhouse has only 20,000 population within a similar radius which means travel times to delivery areas are extended by comparison and parcels per van thereby reduced.
- Sorting equipment.
The pages 4 and 5 submission that the equipment is only designed to work four hours per day is disingenuous.
- Depot location.
The population density statistics demonstrate the highly inappropriate location and the resultant unreasonable traffic volumes through Westerham to service over 50% of the postcode destinations.
We fail to understand the attractiveness of this site given the availability of standard modeling software which would reveal
preferred locations further east.
- Van movements page 3.
The commentary states that vans return to plot 1 around 7 pm.
This is unlikely as shift supervision ceases at 7.30pm and the Stoke site movement analysis shows vans returning from 2pm onwards.
DPD are suggesting a working day of 13 hours including loading time of 1.5 hours for 100 van drivers.
Neither Stoke nor Dagenham work these extended hours.
Westerham Town Council.
9th November 2016.