FoE98A21

Added; <2009, Changed; 13/05/2014, 30/09/2017

Objections to the approved new section of trunk road the A21 six lane dual carrageway

In 1993 Tunbridge Wells Friends of the Earth objected to this scheme, the “published route”. At the time I went to the public inquiry to present my own personal objection, feeling I did not want to present the local groups argument because I had not been to a public inquiry before.

The arguments against remain:

* Doubling of traffic on the A264 Pembury Road, Longfield Road then presumably in to Sherwood and High Brooms, and no reduction in traffic on the A26.
* Loss of habitat These points were endorsed by the Tunbridge Wells Borough Council’s objection to the published scheme.

In August last year a group “STOP THE ROAD” was briefly set-up to respond to the governments Roads Review and Integrated Transport Strategy Consultation. I have a considerable quantity of good quality criticism of the scheme. This group successful drew in people from High Brooms and Sherwood who would be adversely affected by the scheme.Many of the people from High Brooms have voiced the concern for years about traffic, the need for road crossings, and buses. Alternative discussed: Rail, and freight to rail, and frequent buses. There are no technical fixes that would make the car ok because a road car is optimised for 100MPH and a bus is optimised for 30MPH. There is no technical way to design a car that will consume less than 3 times the fuel for it weight than a bus. In addition a car will always be considerably less efficient when first started, an issue that does not seriously arise with a bus.

- Rail sidings are being considered by Railtrack at North Farm Industrial Estate where the main rail line passes beside. This site could provide additional local car parking for rail users. (Appendix 1a)

- Reopen rail line to Brighton, and the line north of Summer Hill tunnel, between Tunbridge Wells and Tonbridge to Paddock Wood and Ashford. Thereby creating links cross country Brighton or Hastings via Tunbridge Wells to Ashford or Gatwick. These links could use the available capacity on the rail outside London during peek times, to create new services. – Traffic calming measures on the existing sections of trunk road At Castle Hill section of the A21 add an Additional crawler lane and road realignment to the existing road. Crash rail in front of the houses where an accident occurred 2/10/97, this was at one of two houses close to the road and was an isolated incident, and is not on the bend said by the DoT to be substandard.

- Better regulation of commercial traffic driving and working hours, to minimise accidents due to tiredness and speed. – There is another proposal that would address the substandard road bends admitted to by the DoT in the published scheme this proposal is to tunnel through Castle Hill. I don’t approve of this option because of the visibility, environmental and archaeological impact, though this proposal has the benefit over the approved scheme of not being six lanes, or have a new substandard bend.

- I am not generally opposed to bypasses for local needs though I would be concerned that village businesses would loose trade. Such bypasses must not attract more traffic, speed, noise, etc. to other people. They should incorporated with traffic calming measures on old roads to minimise rat-running.

- I am opposed to Park and Ride this is out of town parking for car users and takes passengers away from public transport. (See appendix 1c, E Parkinson on Park and Ride) I hear that in Singapore a city bus or car licensing system was introduced in 1974, in addition car parking at the city edge was built. In 1975 traffic fell in the city to a third and has not increased greatly since. The car parking was scrapped in a few years after 1975 because the buses were needed for public transport the car parks had been little used. What had happened was that people were using buses for the whole journey. I have no reference for this example, though I heard it at an “A27 action group” meeting in Lewes, East Sussex. 2) Appendix (2) Criticism of COBA and other computer models

- The computer model in this case justifies 6 lane and joins to four lane sections the four miles south joins to two lanes. The model also would justify 12 or 18 lanes for this 2.4 mile section of trunk road. Dual 9 that is 18 lanes would still break-even on a low growth projection. This is ridicules it seems COBA will justify any grandiose road scheme.

- Mr Mainhood who has agreed that members of STOP THE ROAD using his criticism of COBA. – I am pleased to see that Tonbridge and Malling Council’s position opposing the approved scheme has not changed. I strongly oppose the suggestion that the South coast should have to have more road traffic. The south coast surely needs rail particularly to the channel tunnel, that should be solely for rail. Its not for any person or authority to expect traffic on there patch to be shoved on to another's. 5) Appendix (5) Traffic flow figures.

- note though there is little to compare against but figures stated at the public inquiry in 1993 and figures for 1996 presented at a Government Office of the South East meeting in October by the DETR appear to show considerably less traffic now. That is ignoring predicted figures which again appear lower now. In 1992/1993 when the DoT where pressed on the point that if the section of A21 road were built traffic initially drops then rises again on the A26 and therefore there is no local benefit long term. The DoT replied to this point by say Tonbridge and Malling and Tunbridge Wells Borough Councils had a plan to restrict traffic on the A26. I wrote to Tunbridge Wells Borough Council and was told there were no such plans, and I have seen none since. At the public inquiry I pressed the point about no local benefit to Southborough this time I was told traffic will increase to 40,000 per day if the new section of A21 were not built (appendix 5c). I don’t believe it the road is at capacity. Because of both of these reasons I find the figures doubtful and in any case strongly recommend that they are discounted. The figures appear to be taken form a base of 1986, presumably when traffic flow figures were measured. Surely if 1986 is the year when traffic figures were measured then the whole justification for any road scheme should be on those figures, as these figures are known. As I say above the DoT in there description of a trunk road scheme usually attempt to give the impression of a local benefit, in this case a reduction of traffic on the A26 in the opening year. Overall there would be more traffic on other roads and a subsequent rise in traffic back to previous levels on the A26. This is dishonest particularly as people locally are hoping for traffic and accident rate reductions. The DoT admit that bends in there published route are substandard, but also justify de-trunking the old road because of a substandard bend. No mention was made of the accident rate anticipated in the two lane bottle neck 4 miles south, or residential areas that would also carry doubling of traffic. At the 1993 public inquiry it was said by the DoT that this would be the only section of 6 lane road and they knew of no plans to make any other section of this trunk road 6 lane (DoT speak for not telling you). I would prefer more openness ** Appendix (1b): The borough local plan contains policies that would turn down planning applications which would lead to substantial extra traffic in the town centre via the A264 Pembury Road and other roads (TP10, 11). Therefore there is conflict with the borough’s position likely to send as its submission to the DETR of the A21 road capacity increase. This increased road capacity would cause more traffic on the A264. The DoT used the previous local plan that contained policies to use the Pembury Road as the main rout to the town centre to justify more traffic on this road. This policy does not exist in the current local plan. Nightingales discussed in the Environmental Assessment have been heard last spring this spring, and every spring. Part of the wood was cleared four years ago since then more Nightingales have been heard with each year. Cost of Policing car related and road related crime. There would be a saving if speed pressure points on trunk roads and traffic calming measures taken to change discourage aggressive driving.


- this resource should be switched to sensitive community policing much regarded by the rest of the world but know not so apparent.
- enforce road policing to control speed, driving times and distances to below regulation levels to improve safety.
- in some cases de-trunking, lane closure, and traffic calming on villages bypassed, such as the Pembury bypass would reduce noise and a speed pressure point.

f) Cost to the health service due to car injuries, could be switched to better quality of care with stimulation as opposed to crisis care solely.
- It has been said locally that the government should finance both a new local hospital and a new 6 lane dualling of Castle Hill, thereby apparently linking the issue of roads speed and casualties. Instead measures to reduce speed pressure points will allow savings in health care, as well as saving in fuel costs by this speed reduction.

g) Road building weakens the case for public transport therefore forcing people to drive or not to travel. This therefore cause public transport to be cut.

h) Other car encouragement measures at the expense of public transport such as park & ride are: – by there subsidy attracting people away from public transport, and therefore causing residential traffic due to residential driving to out of town parking for the cheap bus instead of walking to the bus stop. – At least the subsidy should be stopped. – Causing extra traffic possibly 30% more to towns, by allowing additional out of town parking: – Out of town car parking and other development should be discourage, in this case because of CO2 creation. – Alternative to Park & Ride is a distributed form where car parking in villages can feed and revitalise village shops and community as well as feed public transport to the towns. This would allow those away from villages to come in to there nearby village and connect with public transport. – In essence no stick but no more carrots for road vehicle users either. The more traffic on roads will be there own stick if no more roads were built. – also remove carrots such as company car allowances. And the cost of road usage to reflect all the costs environmental, economic, and the cost of past and present road building.


Andrew Lohmann
Southborough Town Councillor,
11, 13, 17, 21 November 1997
XX, XXXXXX Road,
Xxxxxxxxxxx,
Tunbridge Wells,
Kent, XXX XXX.


Tel. 01892 XXXXXX (home)
E-MAIL: AndrewHLohmann@compuserve.com


(5a) References Note prepared by the Department of Transports case for building the ‘A21 Tonbridge Bypass to Pembury bypass Dualling’. Since the public inquiry we have discovered the scheme now code named the ‘Weald and Downland DBFO Project’, is trunking from Chevening, Sevenoaks to Hastings via Brighton. Reference: The following information is from The Department of Transports Environmental Statement figure 14 which shows the following projected daily traffic flows:

                                                 Current Year (1991)     Opening Year (1996)     Design Year (2011)
Longfield Road,                                            14100                   17500/18700                22000/26500
Tunbridge Wells (Industrial Estate) A264      25100                    38000/40600                47700/57600
A26                                                              28000                    20800/22300                26200/31600

low/high growth figures are given in that order. WS Atkins Consultants Limited, Woodcote Grove, Ashley Road, Epson Surrey. KT18 5BW.

In addition figure 14 gives the following:
A21 old Tonbridge/Longfield Rd.                 31200                       2238/2398                    300/400
A21 new Tonbridge/Longfield Rd.                                         46200/49500               58100/70100
A21 Pembury/Kippings Cross                       25500                   42000/45000               52800/63700
A22/B2017 new Tonbridge by-pass                                       18700/20100               23600/28400

Note The DTp’s environmental statement. The statement says {2.6.2} that the study area includes ancient woodland, the majority of which is identified in the Draft Provisional Inventory of Ancient Woodland prepared by English Nature and is thought to be a relic of the extensive forest of Andredsweald. The Northern Part of Castle Hill, Western extension of Pilgrims Wood and Prowles Gill show few signs of recent management, which increases their ecological interest.

{2.7.2.1} The Pembury cutting SSSI.
{2.7.2.2} SNCI adjacent to the area.
{2.7.4.1} Numerous woodlands within the study area subject to Tree Preservation Orders.

From the Inspector’s report of the public inquiry in April – June 1993: – though recommending the DTp’s preferred route, he says under the heading: Wildlife and Nature Conservation:- 289. The area is rich in wildlife and habitats, especially in the ancient semi-natural woodland and replanted ancient woodland. Such areas have a high degree of naturalness, diversity of species and stability and represent a serious loss, largely because of their qualities are difficult if not impossible to replicate. With this exception, however, the ecological impact of the published route is slight. To some extent this seems to be a somewhat fortuitous outcome. Only limited information was available before route selection was made and, even now, it is clear that detailed, sophisticated research is needed, preferably in partnership with the nature conservation interests – for example the Kent Trust for Nature Conservation – to ensure that the ecological harm of the route, If it is built, is kept to a minimum and the most appropriate mitigation measures put in place.
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(5b) References It has been said at a stop the road meeting in Tunbridge Wells that: No archaeological investigation of Castle Hill has been done. It is probably pre-roman and is likely to be a bronze age settlement. The Romans name for the Celtic tribes who lived in the area became the name we use Kent. Castle Hill may have been reused in Arthurian times as a military settlement. Their is A Roman Mile stone that would be moved at Somerhill Park if at least one of the proposed but schemes where to go ahead this is of historic interest. And an RSPB reserve is threatened by at least one of the routes.
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(5c) Additional figures presented in table form From The Department of Transport of Transport’s Response to Objector No. 5, document No.112, Mr A Lohmann Paragraph 3.3 Traffic on the A26 through Tunbridge Wells In Mr Whittle’s proof of evidence he has demonstrated that the expected traffic flow on the A26 through Southborough without improvement to the A21 would increase from the base year flow …..
                                                               A26 ADDT in year 1986 (Base)     1996         2011

Without the A21 Dualling                                                        19900             29800      42200
With the A21 Dualling                                                              19900             22300      31600
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(5d) Current Traffic figures for roads surrounding the published route Note “A21 Corridor plan Rail and Road use” prepared for the Government Office of the South East meeting of 14 October 1997. Figures taken for roads in connection with the ‘A21 Tonbridge Bypass to Pembury bypass Dualling’. Reference: The Highways Agency consultant: WS Atkins Consultants Limited. These show the following projected daily traffic flows:

                                                                                                    Year 1996     Year 2016
A21 Tonbridge by-pass                                                                35000            47000
A21 Tonbridge/Longfield Rd                                                        25000            33000
A21 North Lamberhurst (previously Pembury/Kippings Cross)     6500              8900

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