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Consult - Roads Review 1997

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Roads Review and Integrated Transport Strategy Consultation

My name is Andrew Lohmann, I am a Southborough Town Councillor and was an objector at the public inquiry in to the A21 Pembury to Tonbridge Bypass dualling in 1993. At that time I was also involved with writing Tunbridge Wells Friends of the Earth’s object to this scheme. Much of the following discussion is with reference to this road scheme. I am currently a member of a discussion group called “Stop The Road” set-up to oppose the “A21 Pembury bypass to Tonbridge Bypass dualling”. People who have attended this group will be sending in separate submissions. The group STOP THE ROAD meets in High Brooms, Tunbridge Wells, and people who have attended meetings include people from the vicinity who have voiced the concern for many years (10) about traffic, the need for road crossings, and buses. ** Items or amendments not submitted to the DETR. It has been noticed that in Volume 2 of the Roads Review that the standard for this road (page 81) is D2, dual 2 lane (four lanes) but the public inquiry approved only a dual three lane trunk road (six lane). Any such change would surely require a new public inquiry because a key part of the case has changed. My view is that this scheme that had two years ago been de-priorities to 2 should now be deleted from the roads programme. The road review and integrated transport policy consultation are difficult to address separately, in any case roads should be integrated not a special case. Therefore this response is an integrated response dealing with aspects of both documents. I have made some comments on the Integrated Transportation Strategy, (appendix 3).

1) See appendix (1) Alternatives **and (1b) TP 18. I support public transport alternatives to the road such as, Rail, and freight to rail, and frequent buses. But oppose future technical fix solutions such as cars will get environmentally cleaner because they won’t relative to other modes of transport. – Manufacturers of cars have to juggle parameters such as engine flame temperature, which if high burns nitrogen and produces NO emissions, but the engine has a lower fuel consumption. If the engine flame temperature is lowered NO emissions are minimised but unburned hydrocarbons are emitted. If the engine flame is too fast this causes engine damage through knocking, and the fuel octane requires increasing, the flame also continues too long and causes valve burning damage to the engine. High octane fuels that minimise these problems either contain lead or alternatively very high octane non oil based fuel such as ethanol used in racing cars is not available. If you do all these things, reduce speed limits to 50MPH and optimise the engine for 50MPH not 100MPH that most cars are optimised for perhaps you would double fuel efficiency. Town Busses are already optimised for 30MPH and carry more people. Trains run on lines without bottlenecks and fast sections like roads and carry lot’s of people you will never match either of those with a private car.
- 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.

3) Appendix (3) Response to Integrated Transport Strategy.

4) Appendix (4) Local Councils Position
- I support much of the Tunbridge Wells Borough Council position of 1992. I agree that more traffic could be attracted to Longfield Road, and Pembury Road then through residential areas and in to the town. I also agree with their disapproval of the published route. You will see that appendix (1b) that there are strong policies in the local plan presuming against additional traffic in the town centre. The alternatives the borough suggested that was still a road capacity increase on this section of road I find inconsistent and oppose to it. I am opposed to what may be presented as Tunbridge Wells Borough Councils position as of this month. It is not clear what they want. If they want more traffic do they want it in the town centre I presume yes, and do they still oppose the published route but want more capacity, I don’t know. In any case none of what they are saying will have been approved by council by the 14 November when the DETR should have received their submission. Their submission should be taken as the views of officers only.
- 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 anothers. Other schemes; I am opposed to the A228 which I presume is a road capacity increase (called bypassing) because of extra traffic attracted to Tunbridge Wells.

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 addition traffic on the A26 through Southborough is at capacity I believe, therefore traffic cannot increase further. Traffic that use this section of road and find that the journey time is unacceptably long, will do something else such as find alternative routes, move home, find work nearer. 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. For a detailed criticism of the “A21 Tonbridge bypass to Pembury bypass Dualling” refer to the letter of 10 June to Gavin Strang MP from myself and Cllr Val Catt. 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. Costs

a) Threat to economic development caused by interests in the DoT for roads undue influence over policy of the DoE. Now formally acknowledged in the combining of the two departments. These departments should work together to protect the environment not conspire to build roads. I understand that there is a Highways directive to Kent County Council from government passed on to Tunbridge Wells Borough Council limiting development of the industrial estate until the A21 trunk road is built. I have no title for this directive that became apparent about the time of the announcement of the DoT DoE roads review. Planning consent was turned down for a company moving from one to another premises on the industrial estate that wanted permission to let their existing premises.

b) The AA and RAC have said that Roads cost £50bn a year and there is an income of £16bn therefore a net drain on the economy.

c) It can be said that roads bring in trade and personal communication, but roads also take trade away.

d) Costs and casualties that lead to break downs in communication such as road rage.

e) 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.

i) The Laundering of protected Green land to build roads on and the creation by de-trunking of brown land for building on. – I am concerned that this trunk roads on an ANOB will allow development on brown land when released. At the inquiry in to the Tunbridge Wells borough local plan in 1994 a company Knights Park asked for zoning for houses on the old A21 route (inspectors report 13.24.2). There has been a planning application for a motorway style service area at Castle Hill. These are unacceptable costs they weigh strongly against personal power and choice assumed benefits of car ownership.


Andrew Lohmann Southborough Town Councillor,
11, 13, 17, 21 November 1997
xxxxxxxx, Tunbridge Wells, Kent, TN4 9DN.
Tel. 01892 xxxxxx (home)
E-MAIL: xxxxxxxx@compuserve.com

(1a) Rail Alternative & (1b) Tunbridge Wells Borough Local Plan

(1c) Response critisim of park and ride

(2a) Criticism of COBA public inquiry

(2b) Critisim of COBA

(3) Developing an Intergrated Transport Policy response

(4a) (4b) Council

(5a) (5b) (5c) (5d) Traffic Figures

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