Stop Press – the signs are up.
When the new Chief Executive takes the helm of the HBC management organisation in April, he’s going to have a few challenges to confront. His elected opposite number might also have a few lessons to learn following the May elections. High on the agenda of both leaders should be increasing the analytical skills and level of numeracy within their teams and reinforcing their understanding of the importance of numbers in the contractual documents that they approve.
In my working life, had I produced a contractual deliverable as riddled with errors as the 32 New Lane ‘Operational Management Plan’, I would have found myself on an unsatisfactory performance report within hours. The same would have applied had I reviewed such a document from an external supplier and failed to signal its glaringly obvious shortcomings.
Right from the outset, the quality of the transport documentation produced by Vectos in support of the 32 New Lane planning applications was shown by the public to be abysmal. However, while the errors, omissions and obfuscation were obvious to those who did their due diligence, reviewing the documents and writing comments through the HBC ‘Public Access’ planning portal, they were seemingly ignored by the officers of both local authorities.
We are left to conclude that either the available level of analytical skill is unacceptably low, or that these normally well-qualified officers had been set more pressing objectives and priorities.
In either case, the public has a right to straight answers to some fundamental questions.
The two 32 New Lane (Amazon) planning applications may be extreme examples, but they are by no means the only planning applications where the overall impact of traffic is ignored. Havant Borough Council’s Planning Services team and Hampshire County Council’s Highways department rarely, if ever, consider the ‘bigger picture’ of traffic generation. More often than not, the provision of transport documentation with planning applications seems to be treated simply as a ‘box-ticking’ exercise. It’s rather like having an auditor check that the numbers presented in a spreadsheet add up, but failing to check that all the relevant accounts have been included in the spreadsheet, resulting in a report which lacks context and meaning.
The local authorities’ failure to consider the wider impact of traffic from a planning application in the context of up-to-date traffic data, nearby works-in-progress and other planning applications sharing the same road network is a recipe for gridlock. A further failing concerns the validation of planning applications for which the transport documentation provided uses out-of-date traffic data models or deliberately exploits ‘previously approved maximum traffic generation’ for the site in question. The approval of the new Lidl near the ASDA roundabout is an example of the first failing and, of course, Amazon provides ample evidence of the second. For the last few years of its occupation, the traffic generated by Pfizer at 32 New Lane had been a fraction of the long outdated maximum permitted total traffic movements for the site.
As far as Amazon is concerned, however, this is all now ‘water under the bridge’. We can expect its three gates to open for traffic next month leaving everyone else with the damage limitation exercise of how to properly monitor and manage the real and inevitable growth of traffic which will be generated by the site.
This is not just a problem which affects ‘a bunch of NIMBYs’ who live in the residential streets surrounding the site. It’s going to impact the rest of the town, including the employees and customers of around fifty other businesses located on this employment site, all of whom will now have to compete for access with the traffic generated by Amazon.
The accountability for this situation lies fairly and squarely with Havant Borough Council. Amazon’s first choice site for its ‘Havant Delivery Station’ was Dunsbury Park, but Havant Borough Council appears to have made a deliberate decision to bet on ‘the Freeport outsider’ over an ‘odds-on racing certainty’. A company like Amazon would never have viewed the New Lane site as commercially viable, a view voiced long before the first planning application was even raised in 2021. HBC, however, obviously knew better. How the council persuaded Amazon’s agents to develop the 32 New Lane site is a mystery given Amazon’s constant ongoing business evolution and the fact that the consequent unmeasured traffic growth would inevitably be throttled by the local road network.
Now that TSL have finally put up signage which clearly demonstrates that Amazon are planning to route HGVs, DSP vans and Flex drivers from the south of the site, just how is that traffic going to be monitored and controlled?
Havant Borough Council and Hampshire County Council have left themselves reliant on Amazon to ‘self-report’ their traffic movements for just two hours of the day over just eight weeks of the year, with monitoring defined by a flimsy, error-riddled and already obsolete 12 page document, the “Operational Management Plan” (OMP).
This is the definitive document which sets out the daily traffic volumes which the business at 32 New Lane is permitted to generate and sets out the rules against which the traffic will be monitored and managed. It’s an easy read, click the image to open a copy, though you might find it helpful to have a calculator to hand.
At Paragraph 2.2, the document states, “Having an OMP in place provides the LPA with the comfort needed to understand the traffic impact and management strategy associated with any operator at this site.” Whether the local planning authorities (LPAs) in this case, Havant Borough Council and Hampshire County Council, are ‘comfortable’ with the content and its fitness for purpose remains to be revealed. The question has been asked but remains unacknowledged.
Let’s take a look at the document
The first point to note is that much of the text is simply copied from transport documentation which accompanied what we now understand to be the Amazon planning applications (APP/21/00200 and APP/21/01244).
How well does it map to the Amazon business model?
The short answer is, not at all.
The detail referenced in the Operational Management Plan is directly derived from the anonymised transport model presented in the planning applications, in which all deliveries would be carried out by a fleet of branded vans, wholly owned by the occupier and kept onsite overnight.
Under the Amazon operational model, deliveries are not made in vans wholly owned by the company, but by third-party delivery businesses termed ‘Amazon Delivery Service Partners’ using their own vans, and self-employed, gig-economy ‘Amazon Flex’ workers using their private vehicles.
The total number of vehicle movements in the document attributed to cars comprises only those belonging to warehouse shift workers and delivery van drivers arriving for and departing from their shifts. The underlying data has previously been demonstrated to be incomplete, with traffic movements associated with the late night shift handover movement missing from the data. Of even greater significance, nowhere in the document or its data is there any reference to the significant number of privately owned Amazon ‘Flex’ vehicle movements.
The ‘car’ numbers, therefore, are significantly understated, but there’s more. The ‘trip generation’ numbers also claim that each van would make only one delivery round-trip from the site per day, just one of the many unsupported claims made.
So the business operational model which is now proposed to run at 32 New Lane is completely different from that described in the OMP and previously approved by HBC for the site.
How well do the numbers stack up?
Well in short, they don’t.
The inconsistencies reported against the original planning applications are, of course, still there, manipulated and re-interpreted in the data at Appendix A of the OMP.
Taking one example from the OMP, the number of LGV (Vans) moving in and out during the day. Paragraph 3.1, below, clearly shows ‘505’, ‘based on the data in Appendix A’ which it describes as having been ‘confirmed as robust’ by Hampshire County Council.
So let’s just take a look at the ‘approved occupier data’, as defined in the OMP at Appendix A – Traffic Data. (You’ll find a scrap of paper and a calculator helpful since the table uses Vectos’ tried-and-tested approach of omitting the row totals to mislead the reader.)
Of the van movements shown in the data, 630 are leaving, 629 are arriving. Rather more than the 505 noted in paragraph 3.1, and, for that matter, paragraph 4.8, here:
What about the proposed approach to monitoring?
We’ll leave you to read Section 5 – Monitoring, to make what you will its content. The bottom line is that the occupier proposes to report the detail of its traffic movements for just two hours of each day on just two weeks of each quarter, the dates being agreed in advance. Think about that for a moment, get out that calculator again and you’ll realise that they’ll be self-reporting on just 1.2% of their annual traffic movements. The occupier’s executives are not stupid and neither are their legal advisors. The company can easily manage to hit whatever targets they want within those pre-determined times, leaving otherwise predictable chaos on the roads for the remaining 98.8% of the year.
Paragraph 5.1 probably sums it up:
That effectiveness was never in doubt. The Operational Management Plan, in common with the rest of the Vectos documentation submitted to HBC Planning Services through Amazon’s network of agents, has absolutely no credibility and is not fit for purpose.
So what should be done?
Firstly, the two local authorities must not only insist on a complete re-write of the Operational Management Plan, but they must participate in that activity with appropriate skills. As a pre-requisite to that activity, Amazon should be tasked with providing real 24/7 traffic data from the equivalent live operations at, for example, Peterborough and Melton West.
Secondly, HCC must set up their own automatic traffic monitoring equipment in New Lane, collecting 24/7 data from movements across the three site entrances. That 24/7 data should be stored at the data services centre already tasked with such activity for HCC Highways. We note that HCC already records 24/7 traffic data from 184 sites across the county, either directly fed daily or automatically dialled-up daily. Not only is this basic technique clearly understood by the County Council, but it’s also proven to be reliable and is in constant use.
We also know that HCC already uses feeds of ANPR data to monitor that a specific access to a commercial site is within boundaries defined in a Planning consent. [1] There is no excuse for HCC not to do this for the proposed operation at 32 New Lane.
This approach will enable the occupier to cut their own costs and drop their completely unnecessary proposal to use an ‘independent Specialist Traffic Survey company’. Once HCC make the 24/7 traffic data available, then there will be a large number of citizen scientists across the county, armed with nothing more than a laptop and a spreadsheet, who will be able to come up with the independent reports required. If HCC Highways still have the analytical skills within their own ranks, they could, of course, do this in-house. The cost of 24/7 data collection and storage is trivial and if Amazon claim that their traffic movements are ‘commercially confidential’, then they should be reminded that the traffic servicing their customers will be running on HCC’s roads.
Postscript
We’ve heard that Amazon was sufficiently unhappy with TSL’s construction at 32 New Lane that they didn’t accept it on the first planned handover date. TSL continued with snagging activities and while some residents have been getting animated about the lighting coming from the multi-storey van park, council representatives have been scurrying around, trying to put pressure on TSL to finally get the operation up and running.
Reading between lines, we suspect that Amazon is actually unhappy about the surveillance cameras and automatic traffic recorders (ATRs) which are supposed to be monitoring its traffic coming and going through the site entrances. This is, of course, more than a bit rich coming from a company which monitors every waking moment of its own mostly sub-contract workforce.
On 16 January 2023, Cllr Tim Pike, HBC’s ‘Levelling up’ leader and Amazon champion from the outset, alluded to the uncertainty by stating that “the Council won’t be sharing information about them until they notify us that they’ve taken occupation of the site”.
So, for Amazon, there’s an easy alternative available if they don’t want those cameras on the premises. We can also save them money since there would be no need to pay for that independent traffic survey company. HCC can continuously monitor the usage of their own road – New Lane – and keep the data safely in-house, knowing that there are plenty of Citizen Scientists out here who’ll be more than happy to crunch the data and generate the reports if they don’t have the time themselves.
The reason everyone is getting a little twitchy is perfectly obvious to those who bothered to perform due diligence on the planning documents. Amazon, Kingsbridge Estates, TSL, HBC and HCC all know that the real traffic volumes that will be generated by the new ‘Delivery Station’ at 32 New Lane will be significantly higher than any of the numbers bandied around by its former Transport Consultant in their transport documentation. In fact, they’ve all been in possession of that information from the very start.
If only Havant Borough Council (and, presumably, Portsmouth City Council) had agreed to locate Amazon at Dunsbury Park, an awful lot of time, money and face could have been saved and the site would have been up and running months ago. It would have been a win-win all round.
[1] Data from response to Freedom of Information request raised by HCS to HCC on 11/11/2022
Havant Civic Society 
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