Redacted - Modus Response - 50 Charlotte Street Helensburgh(37214213.4)
Argyll and Bute Council · 27 August 2024
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Registered address: 5 South Gyle Crescent Lane Edinburgh EH12 9EG T: 07816902730 E: duncan@modustransportsolutions.co.uk W :www.modustransportsolutions.co.uk Modus Response - 50 Charlotte Street Helensburgh(37214213.2) Page | 1 Argyll and Bute Council Development Management Kilmory Castle Lochgilphead Argyll PA31 8RT 8th July 2024 F.A.O - Kirsty Sweeney 50 Charlotte Street, Helensburgh Modus Transport Solutions Ltd has been appointed by Dawn Anderson to review the Roads response provided by Argyll and Bute Council in relation to the proposed alterations to widen the driveway entrance at 50 Charlotte Street, Helensburgh. We have reviewed the Roads response provided and would question the validity of the points set out in the response. In my 33 years of working in the traffic and transport planning industry, I have never come across the Highway Code being used, or suggested to be used, as a Design Standard for highway design projects. I, therefore, find it very unusual that this is referenced within the response on several occasions. All road users are considered within the recognised Design Standards such as the Design Manual for Roads and Bridges (DMRB), Designing Streets, the National Roads Development Guide and indeed Argyll and Bute Council’s - Roads and Infrastructure Services Roads Development Technical Guidance. The Roads Department has classified Charlotte Street as a “main rural secondary distributor road”. This is not a recognised classification within DMRB, Designing Street, National Roads Development Guide or Argyll and Bute Council’s - Roads and Infrastructure Services Roads Development Technical Guidance. I would question this classification for a number of reasons. Charlotte Street is located in the eastern residential area of Helensburgh. Its location is not rural and, in fact, its location is purely residential. Charlotte Steet is a residential road with direct frontage access to driveways, parking areas and on-street parking along its length, it is not a distributor road. There is no road signage, advance direction signage or otherwise, to Charlotte Street from either the A818 or the A814 suggesting it is a distributor road. The Council have suggested visibility splay requirements of 42m x 2.4m for a 30mph speed limit. I would question whether the 85th % speeds on Charlotte Street are at a level of 30mph and would respectfully
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50 Charlotte Street, Helensburgh Proposed Dirveway Alterations Modus Response - 50 Charlotte Street Helensburgh(37214213.2) Page | 2 suggest that they are more likely to be in the region of 20mph or less given the geometry of the road. Indeed, I understand that this has already been demonstrated to the Council utilising very recent speed survey findings commissioned for planning application 22/00017/PP at East Rossdhu Drive, located only metres from Ms Anderson’s property, which evidenced that 85th % speeds at the corner of East Rossdhu Drive/Charlotte Street are 17-18mph. This would equate to sightlines of 25m x 2.4m. This could be determined by a further speed survey if required. A vehicle exiting the proposed driveway area can clearly see a vehicle approaching from either the right or the left when doing so in a forward gear. To suggest that there is a significant Health and Safety concern for such a manoeuvre is frankly ridiculous. One only needs to drive along the full length of Charlotte Street from the A818 to the A814 to observe similar driveways and parking areas. It is recommended that the LRB should attend a site visit to clarify this situation for themselves. Argyll and Bute make continued reference to vulnerable road users and the significant Health and Safety issues on Charlotte Street. There have been no reported injury accidents on this section of Charlotte Street in the past 24 years (reference CrashMap UK data) and therefore I find it hard to believe that resurfacing of this driveway to include a modest extension for pedestrian access/egress will cause some sort of dramatic road safety issue. A standard double garage driveway is typically 5-6m in width. While a bi-directional carriageway may indeed be 5.5m wide, as stated by the Council, this does not take into account car doors requiring to be opened. Indeed, two standard car parking spaces side by side would be 5m wide. The applicant is simply allowing for an additional area for pedestrians, hence the 6m. The Council’s 3.6m is a minimum standard, not a maximum, and the Applicant wants to apply for more than the minimum standard. The Council suggest that a width of 6.0m would represent a potential for the intensification of vehicle parking at a location that does not achieve minimum visibility requirements or offer vehicle turning to facilitate vehicles entering and leaving in a forward gear. Once again this claim makes no sense. Are the Council now suggesting that all vehicles accessing a driveway have to leave in a forward gear? Is it now being suggested by the Council that all residents are required to reverse onto their driveway from the road to enable them to leave in a forward gear? This can easily be achieved from the proposed driveway if this is indeed a requirement. The proposals are for an improved driveway access with additional space for pedestrians with very low levels of vehicle activity over the course of a day and at low speeds at this location. This will certainly not create the dramatic road safety issues the Council is alluding to.
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50 Charlotte Street, Helensburgh Proposed Dirveway Alterations Modus Response - 50 Charlotte Street Helensburgh(37214213.2) Page | 3 It is the professional opinion of Modus Transport Solutions Ltd that the proposals at 50 Charlotte Street, Helensburgh meet the appropriate design standards and do not create a significant health and safety concern. Yours sincerely, On behalf of Modus Transport Solutions Duncan Birrell Director