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A428 Black Cat to Caxton Gibbet Road Improvement scheme
Received 09 June 2021
From Carter Jonas LLP on behalf of Travelodge Hotels Ltd
“INTRODUCTION 1. We write on behalf of Travelodge Hotels Ltd (‘Travelodge’) making Relevant Representations to the A428 Black Cat to Caxton Gibbet Improvements Development Consent Order (the Scheme) being promoted by Highways England Ltd (the ‘Applicant’). 2. Travelodge are leaseholder of a hotel (the ‘Hotel’) on the existing Black Cat roundabout. The Hotel is a 40 bed budget hotel, located to the immediate north of the existing Black Cat roundabout. 3. The Hotel is well established and has been trading for approximately 19 years, from August 2000 in a well-connected location on the strategic road network. COMULSORY PURCHASE AND EXTINGUISHMENT 4. The Hotel will compulsorily acquire (Plots 1/29a 1/30a) and be demolished as part of the Scheme. The Applicant has said in their view it will be reasonably necessary to extinguish the Hotel. ROADSIDE SERVICES AND ROAD SAFETY 5. As well as a commercial enterprise the Hotel serves an important function in supporting the strategic road network. The Department for Transport policy on roadside services states: “The primary function of roadside facilities… is to support the safety and welfare of the road user.” 6. The provision of comprehensive services on this key junction serving two major routes (A1 and A428) provides a higher quality of roadside facilities, and more sustainable land use than a number of smaller services scattered along both routes. 7. Government policy and industry guidance emphasises the risks of driver fatigue in road accidents, and the benefits of regular breaks, consumption of caffeinated drinks and over-night stops in preventing accidents. 8. Government policy in DfT Circular 02/2013 ‘The strategic road network and the delivery of sustainable development’ (10th September 2013) states: “Motorway service areas and other roadside facilities perform an important road safety function by providing opportunities for the travelling public to stop and take a break in the course of their journey. Government advice is that motorists should stop and take a break of at least 15 minutes every two hours. Drivers of many commercial and public service vehicles are subject to a regime of statutory breaks and other working time restrictions and these facilities assist in compliance with such requirements.” IMPACT OF THE SCHEME 9. The Scheme would result in significantly increased traffic volumes on the east / west route. Following extinguishment of the Hotel there will be an 18 mile gap between services and over-night stays on this route. The intensification of traffic on the east/west route due to the Scheme would therefore be associated with a reduction in roadside services in a key location, which would be potentially detrimental to the welfare of drivers. 10. There are other services and a hotel on the A1 in this area for north and south bound travellers, however these do not offer such comprehensive provision of hotel, fuel and hot food options, and in some cases are only accessible from one side of the carriageway. Planned upgrades of the A1 are likely to extinguish more roadside services. 11. This risk underlines the importance of retaining a comprehensive hotel service offering at the Black Cat roundabout. This is a strategic location that will provide services to both the A1 and improved A428/A421 route more efficiently and sustainably, maximising the benefit to road users and with less impact on land use than smaller roadside provisions scattered along both routes. 12. A key objective of the Scheme (Environment Statement [ES] Chapter 2, 2.2.2) “Safety: Improve safety at junctions, side roads and private accesses by reducing traffic flows on the existing A428. Improve safety on the A1 by removing existing substandard side road junctions and private accesses onto the carriageway” 13. ES ‘Chapter 12: Population and Human Health’ concludes that the Scheme would have a beneficial impact upon road safety and is therefore assessed to have a positive health outcome. 14. We note however that the ES (specifically the Transport Assessment) appears to have no regard to the following when arriving at its conclusions on the Scheme’s impact on safety: - DfT policy on roadside facilities and road user safety - The provision of roadside facilities - The impact of the loss of services at Black Cat Roundabout (including the Hotel) CONCLUSION 15. Travelodge object to the compulsory purchase of the Hotel and extinguishment of the business and loss of jobs. They consider that the Applicant should provide for the provision of roadside services in this sustainable location as an integral part of the Scheme, in order to safeguard road safety in accordance with government policy. 16. The omission of consideration of this important policy factor (roadside facilities and road user safety) in the ES mean that the true adverse impacts of the Scheme have not been properly assessed. In the context of the increase in traffic associated with the Scheme and loss of roadside facilities such as the Hotel, the Scheme design is potentially inadequate. 17. In the absence of any tangible support to Travelodge to assist a re-location they consider the Applicant has not taken reasonable steps to avoid compulsory purchase and that there is therefore no compelling case in the public interest to justify the use of such powers.”