“Dear Sirs Metrowest DCO We are instructed by ETM Ltd, Manheim Auctions Limited and Flynn Ltd of Ashton Vale Business Park, a site adversely affected by the proposed DCO. The Site comprises an industrial estate with a variety of business users but ETM and Manheim Auctions in particular require appropriate road access to continue operating their respective businesses. ETM is a waste recycling company with up to 250 vehicle movements a day and Manheim Auctions in a car auction operation with similar high levels of vehicular movements. The DOC process proposes inserting regular train journeys across the only vehicular access to the estate creating an untenable situation for these existing occupiers. We have made submissions within the process for over three years and it was acknowledged at an earlier stage that these impacts would arise – at that stage the proposers entered into discussions to compulsory purchase land in order to create a new vehicular access to the rear of the estate. However, without discussion or explanation, the proposers determined not to continue this approach and have instead reverting to stating the highway data demonstrates the impact will not be significantly adverse. Our transport consultant engaged earlier in the process with significant comment on the paucity of and basis for the highway assessments created by the proposers and the errors therein. We now make the following formal comments on the continued errors in the proposal that have not been addressed. We object strongly to the proposal on a highways impact basis and will wish to address the inquiry. Submission Further to the comments submitted by cTc on behalf of the businesses resident within the Ashton Vale Business Park, the concerns over the validity of the traffic data used to compile the Linsig and VISSIM models are acknowledged by ch2m on behalf of the scheme promoters. In an attempt to address the concerns raised, the expected response would comprise a repeat of the traffic surveys on which the traffic models were compiled and which had been a primary source of criticism, followed by a “re-run” of the models themselves using the newly acquired survey data. This does not appear to have happened and the latest submissions appear to provide little more than a “sticking plaster” approach to the problems evident with the models, which continue to rely on unreliable survey data. The Do Nothing models do not reflect traffic conditions experienced by occupiers of Ashton Vale Industrial Estate and the reports submitted acknowledge significant variation in traffic conditions on the estate from day to day. The 2017 surveys on which the models continue to be based were undertaken on a day on which Manheim Auctions were inactive, hence wholly underestimate the traffic conditions. The modelling team have attempted to justify this by means of ATC surveys which do not present sufficiently detailed information to enable any acceptable validation of the model, which does not allow for the commercial activities of one of the estates largest and busiest occupiers. The impact of increased closures of the level crossing is illustrated in technical tables in the ch2m note, with raw numbers presented and little explanation or analyses of those numbers given, save to suggest that the impact of the increased frequency of closure is easily mitigated by the proposed minor improvement works. However, on investigating the values within the summarised model output it becomes clear that the proposals could potentially result in very substantial lost time available for traffic exiting Ashton Vale Industrial Estate. From cTc’s preliminary review, even allowing for the proposed mitigation, the capacity for traffic exiting the Ashton Vale Industrial Estate is reduced by at least 30% and potentially more than 50%. It is acknowledged that the congestion may take more than one signal cycle to clear and cycle times of the order of 160 seconds are mentioned in the report. Assuming “more than one” means at least two, this comprises 320 seconds or more. Adding to that the signal closure of 105 seconds results in significantly increased congestion for at least 425 seconds, or a little over 7 minutes. The report identifies potentially up to 5 closures per hour, or one every 12 minutes in the unlikely best-case scenario that they are equally spaced, meaning, on average 7 minutes of substantially increased congestion will be following by 6 minutes of relatively free flowing conditions (as current). Such an impact will result in Ashton Vale Industrial Estate becoming unusable by its current occupiers for the business activities presently carried out there. The proposers are aware of but have ignored the occupiers concerns.”