Created; <2009, Changed; 30/09/2017, 07/05/2014

Response to: Access to Hastings Multi-modal Study Final Report

TO: Martin Tuggwell – SERA.
ON BEHALF OF: Tunbridge Wells Friend of the Earth;

Dear Sir, Our response to follows below. Please would you pass on our complaint that consultation period is to short, that no letter or other note to explain the process and the consultation period, has reached me. We have not seen a steering committee chairman’s summary is there one?

Andrew Lohmann, 12/12/00, ahs3finl.doc
High Brooms,
Tunbridge Wells,
Kent, TN4 XXX.
Tel: 01892 XXXXX,
E-MAIL: AndrewHLohmann@compuserve.com

Please also see our additional comments:
(A) AHS3NEW2.DOC, on newsletter three.
(B) Draft Press Release. Our views are:-
1) Castle Hill:- The recommended that a 4 lane carriageway be built on-line. 1.0.1. Though we don’t know what is proposed, but it seems that an on on-line scheme is less bad. But;
1.1.0. Extra traffic attracted to Tunbridge Wells. See point 5.1. No long term local benefits as far as traffic reduction. This is contrary to Tunbridge Wells Local Plan policies; TP10 and TP11. 1.1.1. Rail that is a feature of access to Tunbridge Wells, is not developed. For example rail freight sidings and shuttle trains could be very profitable. But see points 3.3, and 5.0.

1.2.0. Serious injuries due to crashes;
1.2.1. The report compares the off-line (with substandard bends and 4 or 6 lanes) scheme with it’s own scheme and claims accident benefits.
1.2.2. The summary therefore does not contradict Tunbridge Wells Borough Council’s figures showing a good safety record on this stretch of road.
1.2.3. The combination of 50MPH speed limit and an invitingly fast 4 lane road is worrying. If the crash rate with serious injuries and fatalities were to increase would the H.A undo the widening?

1.3.0. Damage to the Urban Environment;
1.3.1. More vehicle traffic be attracted to Tunbridge Wells This will reduce Air quality and road safety in Sherwood, Longfield Road and High Brooms, for example.
1.3.2. Therefore severance will also be an issue for the residential area Sherwood.

1.4.0. Damage to the Natural Environment;
1.4.1. We understand that on-line widening would have a much more limited environmental impact than the on-line scheme proposed at the Public Inquiry. The Borough Council’s own alternative of 1992 snaked about through a house and Tuddley Wood (RSPB nature reserve).
1.4.2. Archaeological damage would occur with road widened, but the degree depends on how the road widening is carried out in the vicinity of the Hill Fort (scheduled ancient monument).
1.4.3. Road widening would affect designated areas: High Weald Area of Outstanding Natural Beauty, Metropolitan Green Belt, Kent Special Landscape Area, Special Nature Conservancy Interest, and Tuddley Wood RSPB nature reserve.
1.4.4. Severance;
1.4.5. Two public footpaths be severely severed by a wider road at the Stud Farm and near the petrol station.

1.5.0. Less bad aspects;
1.5.1. Drop our object to; Noise and visual intrusion for North Tunbridge Wells, High Brooms etc.

1.4.2. Destruction of Ancient Woodland, and the pond with Crested Newts are saved for now. Presumably the Nightingales will be disturbed less.
1.4.3. Much of the 65,000 lorry movements during construction stage will now not occur. Therefore transportation is reduced during construction stage.
1.4.4. Less quarrying for building material elsewhere. The approved scheme featured the construct of embankments and cuttings.

2) Longfield Road roundabout;
2.0.1. This junction does not give vehicles or any other users a fare turn. Traffic lights may be more appropriate.
2.1.2. Severance is not addressed for Cyclists and Pedestrians between the two sides of the A21, Pembury and Tunbridge Wells.
2.2.0 Peak journey time saving are questioned bearing in mind that the bottleneck seems to be traffic entering Tunbridge Wells.
2.3.0. This may be changed “improved” as part of a planning gain connected with a B+Q building on the old SEEB site. Will the study state it’s aspirations?

3) The A21 south of Tunbridge Wells;
3.0.1. 60% of traffic enters Hastings via A21, but even so Hastings Borough Council figures show this is local traffic.
3.0.2. Information from the WS-Atkins 1996 shows that flow rates vary widely and the lowest flow is at Battle is 5,000 vehicles per day. Again confirming local or cross country travel.
3.1.0. Much of the whole route includes Archaeological important features.
3.2.0. Much of the whole route is within the High Weald AONB or has other environmental designation.
3.2.0. Crash black spots with serious injuries at Kippings Cross, and Flimwell have not been considered.
3.3.0. The whole A21 should be detrunked south of Tonbridge. County Councils may then carry out any appropriate traffic calming measures. This should be the final A21 study and that is it as far as this road is concerned. Our understanding is that this road has been studied many times, including by the Kent County Council and the failed Weald and Downland DBFO scheme.
3.3.1. The Tunbridge Wells aspect of the study requires rail options to be considered particularly because Rail access to the town is its feature. There is under investment in rail in this area.
3.4.0. A26 though Tunbridge Wells to A21;
3.4.1. No measures to mitigate rat-running across Southborough Common, (Highways Department of Tunbridge Wells Borough Council have recommended Traffic calming on the common – The closure of Constitution Hill between Victoria Road and St. Peters Church).
3.4.2. Road constriction suggested by other or complimentary measures mentioned in the study could be carried out with aside from any other road building.
3.5.0. Pembury High Street and other areas;
3.5.1. Rat-running not addressed. But may be exasperated.
3.5.2. Additional inappropriate traffic through other areas.

4) Linked issues;
4.0.1. Any road building or widening (what ever route) is linked by government policy to development of North Tunbridge Wells. Our concern is that building should not occur in areas that are presently AONB etc.
4.0.2. Opinion within Borough Council links the road to closing two existing Hospitals, and development at the Knights Park Multiplex and Bowling centre. This area is between Pembury By-pass and Longfield Road
4.0.3. The area near Knights Park includes ancient woodland and has designations AONB, MGB, KSLA, SNCI.
4.0.4. A small part is designated Rural Fringe could be built on already.
4.0.5. A small part in this area was described in ‘Detailed description of sites’ of Nature conservation interest for the Tunbridge Wells Borough Local Plan’ of September 1993. This study suggests a very high quality biodiversity.

5) Sustainability has not been addressed adequately;
5.0.1. The case for more rail infrastructure investment has been omitted.
5.0.2. Rail Track have been criticised for resisting investment.
5.0.3. Local MP Archie Norman was a director of rail track last year, admits to pressing for A21 road be built at Castle Hill.
5.1.0. Dissatisfaction;
5.1.1. It was admitted at a reference group meeting in Tunbridge Wells that 8% reduction in traffic claimed on the A26 would transfer to the A21 would not be noticed on the A26. In any case additional traffic would take up this capacity on the A26 in due course. 5.1.2. Same point admitted by DoT in a letter to me of 1992, when confronted with their own figures presented at public exhibition.
5.1.3. Other roads are already being debated by Conservative Party Councillors such as; a bypass of the A26 such as across Southborough Common, Speldhurst, to Langton Green.
5.2.0. Political motive;
5.2.1. FoE’s Briefing – Green Fuel Tax – The Case Against Cuts.
5.2.2. Note. 5 On 6 June 1997, John Prescott told the Guardian “I will have failed if in five year’s time there are not many more people using public transport and far fewer journeys by car. It’s a tall order, but I urge you to hold me to it’ – evidently conservative interests are pushing to arrange his failure. 5.3.0. Climate change flooding is now an important issue.
5.3.1. Air quality is poorer (Up to 24,000 people die annually due to vehicle emissions – New Scientist January 1998). Note: During the week 9th to 15th September air quality improved in cities and the roads were quieter (Independent says 75% reduction in pollution in cities). Injury rates dropped (channel 4 say’s by a third). Note in 1970′s injuries were halved in USA when 55MPH speed limits were introduced.
5.3.2. Is high reliance on oil and gas a good idea? Trams used a 12th the energy of a conventional bus. Electric trains are even less. Also see 7.0.1 below.

6) The study;
6.0.0. Meetings promised with local groups in Tunbridge Wells have not materialised.
6.0.1. The study has not been Multi-modal but substantially road only specifically an A21 study for Tunbridge Wells.
6.0.2. Therefore investment in rail infrastructure which is a feature of access to Tunbridge Wells has been excluded from the study.
6.0.3. No environmental study has been conducted into the recommendations.
6.0.4. The consultants have been pushed in to expediency rather than the rigor expected.
7) Specific comments on paragraphs within the Final Report
7.0.1. Paragraph 2.35, Table 2.3, Emission factors – we are surprised that electric appears to be by far the worst polluter in grams/giga joule. My understanding is the electric trams v busses consume a 8th of the energy or 12th with regressive breaking. Trains consume even less energy because of there greater length compared to the front. The front does most the work pushing air aside.
7.0.2. Like most machines the internal combustion engine is efficient only at full power. But the requirement for vehicle traction is widely variable loading plus inefficient gear changing in the case of road vehicles. Additional short runs results in very high fuel consumption in private cars particularly. By comparison an electric motor is very efficient at energy conversion across a wide range of loading and when using power from the grid which is generated at a high efficacy should produce a better overall efficiency, and lower pollution levels.
7.0.3.The report correctly notes the benefit of better localised air quality for electric v petrol or diesel that cause up to 24,000 people die annually due to vehicle emissions.
7.1.0. Paragraph 3.24. A264, and A21 – there seems to be a traffic bottleneck is AM entering Tunbridge Wells, particularly on school days. (also see 2.2.0. above).
7.2.0. Paragraphs 3.98 & 3.99 – agree perceived safety rather than actual.
7.2.1. Paragraph 3.98 – note that the fatality was a patent from Pembury Hospital walking contrary to the High Way Code – demonstrates another reason why a hospital should not be situated out-of-town.
7.2.2. Table 3.12 – don’t understand. There needs to be a key.
7.2.3. Paragraph 3.128 – agree.
7.3.0. Appendix E.3.47 – disagree with conclusion because more importance should be placed on the adverse impact on The High Weald Area of Out Natural Beauty its landscape is recognised as nationally important, equal in value to those of the National Parks.
7.3.1. Appendix E.3.57 – agree. 7.4.0.Is strategy 12. on-line or off-line? Also see same contradiction at E.7.79.
7.5.0. Noting point E.6.49 & E.6.52.
7.5.1. Appendix E.6.54 – disagree. Inconsistent (see 1.2 above).


Leo Eyles,                                                                                                         xxxxxxxxxxxx,
SDG AtoH Research,                                                                                        High Brooms,
28 – 32 Upper Ground,                                                                                     Tunbridge Wells,
London,                                                                                                            Kent, TN4 xxx.
SE1 9YA.                                                                                                           Tel: 01892 xxxxxxx 01892 xxxxxx (work)
                                                                                                                         E-MAIL: AndrewHLohmann@compuserve.com

FILE: ahs3new2.doc 17 August, 2000

Access to Hastings Study Newsletter 3

Dear Kate,

I understand that GOSE has asked groups represented by steering group members to forward SDG more detailed comments on the strategy options. The following comments have been copied to other members of the group. Here are the comments: 1) Reflecting a negative agenda – The only view point published in the press or represented in strategies 3 to 5 is the dirtiest vision of the future, but that’s not the only view. A few years ago many of the local papers gave good coverage to concerns people like myself have about a new section of trunk road at Castle Hill. Our concerns are visual intrusion, noise carried across the valley between, poor air quality in Longfield Road, and harm to the natural environment. This same view point was expressed by Tunbridge Wells Borough Council at the public inquiry in 1993 with similar press coverage. 2) Strategies 3 to 5 – It is very apparent that little traffic travels as far as Hastings to Tunbridge Wells, is there any reason to anticipate considerably more traffic. Is encouraging more road usage sustainable anyway I think not. These are strategies from the past that used COBA to justify any grandiose road building schemes. The predictions of 1993 inquiry were very wrong in the case of new section of trunk road at Castle Hill. Providing based on such prediction is flawed, and is counter to the way for example Kent County Local Education Authority works when considering the case for building new schools. Similarly commercial practice does not invest until there is a very apparent need, not a wish. The COBA 9 model for Castle Hill shows a positive or neutral benefit for an 18 lane section of road, this is ridicules. The failure of the Weald and Downland DBFO scheme should have been the final death nail for these old grandiose road building schemes. The Castle Hill dualling gives no long term local benefit, and dualling all the way to Hastings would only save five minutes journey time from Hastings to the M25. 3) What are the consequences to the natural environment, is any of it sustainable? Building a new section of trunk road at Castle Hill even if less than six lanes will lead to much of the need for borrow pits and 65,000 lorry movements originally predicted. This through ancient woodland with nightingales and a pond with Great Crested Newts. There are already strong interests wishing to build in the High Weald AONB south of Castle Hill and between the Pembury Bypass and Longfield Road. But still no environmental assessment of the area has been carried out. The road inquiry inspector express a strong wish that environmental assessment should happen, the Multi-modal study has a wider view an environmental assessment should have a wider view. 4) The first two strategies seem much like the widening of the A21 through villages that has already occurred. All strategies include measures on the A26, are these the same as the bus and cycle lanes on the A26? It appears to me that the complimentary measures on the A26 are the measures to restrict traffic I was told by the Department of Transport in 1992. In the letter of reply I was told that Tonbridge and Tunbridge Wells Borough Council’s has such plans. At that time Tunbridge Wells Borough Council Highways Officer James Whithorn expressed no knowledge of the plans.

5) None of the strategies look forward and consider Sustainability and non-transport alternatives.

6) Why do you have to choose between better rail service to Hastings or Wadhurst? Would for example widened for dual working the Tunbridge Wells Central Rail Station south east tunnel lead to improvements to all rail services? If the rail line Tunbridge Wells to Lewes were restored accessibility of Tunbridge Wells would be further improved. A local transport authority, like London Transport could be set up to integrate all public transport to make the buses arrive and on time. Shuttle trains could run between long distance services, the loop restored at Eridge to facilitate trains passing. The creation rail freight sidings to carry waste from the Industrial Estate Longfield Road, could additionally allow long distance trains to pass shuttle trains.

7) Severance could be minimised with traffic lights at Longfield Road /A21 junction give everyone a fair turn for all including cyclists.

8) The Castle Hill at present has very low serious injury rates (one fatality in five years), but crashes due to the Pembury bypass are comparatively high. The Pembury bypass provides no journey time savings and contrary to what may have been wished for Pembury Village is the bypass for traffic cueing to enter Tunbridge Wells in the morning. There is a good case for detrunking the whole of the A21 south of Tonbridge, and making a staged speed reductions at the end of the Tonbridge bypass.

8) As four lanes instead of six are to be considered then the two published routes and the Tunbridge Wells Borough Council’s alternative of 1992 may be more suitable. I don’t support any of them.

9) People in Tunbridge Wells wish traffic moderation and to that end, they support public transport, and presumably non-transport alternative solutions, what ever their view of trunk road building. The study has given little education and opportunity to think about this as a possibility.

10) People had come to realise that road building had come to an end and it was now time to switch away from private car use. Traffic appears to have reduced in recent years on the A26 into Tunbridge Wells, until the recent road building hysteria when the trend reverted.
Yours sincerely
Andrew Lohmann
for Tunbridge Wells FoE and Stop the Road (A21)


DRAFT PRESS RELEASE – TW FOE – Access to Hastings Multi-Modal Study Contact: Andrew Lohmann 01892 542471 or 01892 500426. The Access to Hastings Multi-Modal Study is the first to involve ordinary people in the evaluation processes. The study recognises that high level of car dependency contribute to environmental and safety problems in this area. The study recognise disparity in perceptions and actualities. It is disappointing that the study has not been as Multi-modal as we may have wished. We don’t think the effect of additional traffic has been mitigated, or potential for expansion of access to Tunbridge Wells by rail that is a feature of the town. The possibility of re-opening the line to Lewes, and rail freight sidings at Longfield Road, and restoring dual track working to Hastings, has not been explored. The report acknowledges that accident rate at Castle Hill is equivalent to the national average for the road type. The study compares an on-line with off-line road scheme and predicts that the former would better in this respect, but does not compare with the road as it is. No noticeable short term traffic reductions on the A26, and no long term local benefit. Presumably we can expect more vehicle traffic to reduce Air quality and road safety in Sherwood, Longfield Road and High Brooms, for example. How will Cyclists and Pedestrians cross the A21 at the Longfield Road? The study does not rate this problem, though hospital employees cycle across this junction. A wider road would exasperate severance of the two public footpaths at the Stud Farm and near the petrol station. We don’t know how this will be addressed? Particular note is made of the adverse effect to the High Weald Area of Outstanding Natural Beauty form much of the length of the A21 studied. Though a environmental study has not been carried out on the proposals in the study, Castle Hill is designated Metropolitan Green Belt, Kent Special Landscape Area, Special Nature Conservancy Interest, and Tuddley Wood RSPB nature reserve. There is also Hill Fort (scheduled ancient monument). Building in the north Tunbridge Wells will follow result in loss to more of the natural environment.