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Department of Transport,                                                              Tunbridge Wells Friends Of the EarthSouth East Construction Programme Division, 
                                                                                                       c/o xx xxxx xxxxx,
Federated House,                                                                          Southborough,
London Road,                                                                                Nr. Tunbridge Wells,
Dorking, Kent.                                                                               TN4 xxx
Surrey, RH4 1SZ.                                                                            7 December 1992

Tunbridge Wells Friends of the Earth Objection To: A21 Tonbridge Bypass to Pembury Bypass Dualling

Dear Sir/Madam,

Opening Comment

We believe that this road scheme will result in the permanent loss of Public Rights of Way, and natural countryside including ancient woodlands, which cannot be put back. The scheme will encourage more road usage, and will lead to adverse health effects and major environmental damage.

The question we ask is:- Should we be balancing a permanent loss of our natural environment with the short term benefit of fast convenient road infrastructure, and long term road chaos with even more roads congested with traffic, which may eventually lead to the eventual abandonment of large amounts of the road infrastructure, and still leave the natural environment seriously damaged. Our answer we suggest is:- no.

Tunbridge Wells Friends of the Earth’s Case

Reference numbers throughout are those in the Environmental Statement which I have used to support the points made. The effect of the finished scheme on Road Traffic and Health Despite the urgent need to reduce traffic on the A26

 {3.7.3} and other routes through Tunbridge Wells, figure 14 of the Environmental Statement projects no significant change to the volume of traffic on the A26 between now and the design year 2011. We accept that this scheme will very likely attract traffic away from the A26

 {1.4:ii} but it appears that more traffic will be attracted onto the A26 to replace that traffic so therefore it cannot be said that this scheme will alleviate traffic on the A26 through Tunbridge Wells as is stated elsewhere in the Environmental Statement.

More traffic will be encouraged on to other roads if the Dualling is undertaken, and therefore this will not be environmentally beneficial. This is also illustrated quite well in figure 14 of the Environmental Statement which shows projected increases in traffic on:

A21 Tonbridge/Longfield Road Section,
A21 Pembury/Kippings Cross Section,
Longfield Road (Industrial Estate), A264.

Bringing more traffic into Tunbridge Wells via the A264 will not help either. The road infrastructure in Tunbridge Wells cannot cope with increased traffic.

We suspect that there are already adverse health effects, particularly to people working at or walking to North Farm Industrial Estate, and to people living or walking along London Road / St Johns Road, Tunbridge Wells, that would at best not be improved on, and more likely worsen as a result of the likely increased traffic. There would also be indirect adverse health effects, in the residential areas where the extra traffic attracted to this new road will start from, go through, and end up at.

Damage to the Natural Environment

We are concerned with the loss of ancient woodland, semi-natural ancient woodland, including what is believed to be a relic of the extensive ancient forest of Andredsweald, as well as ordinary fields which are a feature of the countryside and the loss of all types of animal wildlife not just for instance the Nightingales or Great Crested Newts of Castle Hill Wood.

Cuttings and Embankments are a feature of the scheme. The suggested modifications

{6.6.6} will not mitigate the environmental impact significantly. Abandonment of the Scheme is the best modification.

About The area:

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 North Part of Castle Hill, Western extension of Pilgrim’s Wood and Prowles Gill show few signs of recent management, which increases their ecological interest.

{2.7.2.1} – The Pembury Cutting and Pit near Pembury Hospital just to the south of the proposed scheme is a Site of Special Scientific Interest (SSSI).

{2.7.2.2} – Sites of Nature Conservation Interest (SNCI’s) are adjacent to the study area.

{2.7.4.1} – Numerous woodlands within the study are subject to Tree Preservation Orders.

{2.8.1/2} – The Area is within the Metropolitan Green Belt, and is covered by the approved Kent Structure Plan, 1990. The overall plan is to conserve and enhance the quality of Kent’s countryside, as reflected by policy S6 which contains a strong presumption against development of fresh land in the countryside and development in the Metropolitan Green Belt and areas protected by the Plan’s Countryside and Coast policies.

{2.8.4/5}{2.7.1.1} – The greater part of the area is designated as an Area of Outstanding Natural Beauty (AONB), and locally as a Special Landscape Area (SLA) as designated by Kent County Council.

{2.10.5}{2.6.1} – Open fields in the area are mainly improved and reseeded grassland, but the field west of Colebrooke retains a community of fine-leaved grasses and a number of herb species.

 The Effect the Scheme will have on the Environment:

{1.5} – The road scheme would result in major earth works, substantial loss of vegetation, and be visible and detract from the surrounding landscape designated as an Area of Outstanding Natural Beauty (AONB) and KCC’s Special Landscape Area (SLA).

{4.2.2.1/2} – Partial loss of Castle Hill Wood on the North facing slopes of Castle Hill and a cutting, involving loss of ancient woodland from Calves Lodge Wood. Also loss of ancient woodland along stream courses at Pilgrim’s Wood and Prowles Gill.

 {3.2.4} – Embankments 10 – 12 metres high south of Castle Hill crossing two valleys coincident with Pilgrim’s Wood and Prowles Gill, returning to a cutting up to 8 metres deep near Colebrooke.

{4.2.1.2} – The proposed earthworks would include a major new cutting some 20 metres deep through Castle Hill. Fields in the Area are an important feature of the countryside.

Loss of animal wildlife:

{4.2.6.1/2} – the loss or disruption of animal foraging paths as a result of partitioning would be likely to result in reduced animal and plant dispersion and small mammal populations would be particularly affected. Bird populations of the woodlands would be locally reduced which may include the Nightingales of Castle Hill Wood and Great Crested Newts, a protected species, along with frogs and palmate newts in a pond in the field to the south of Castle Hill Wood.

{2.10.6} – Rabbits and foxes are locally common and deer may be present.

Public Rights of Way and Historic Interest

 Loss of Rights of Way and encroachment on Somerhill Park which is of historic interest will serve to further devalue the area as a public amenity.

{3.2.7} – 4 Public footpaths would be severed by the new route these would be substituted by an underpass and a footbridge across the dual carriageway cannot be compared with peaceful walking in the countryside that will be lost.

{4.2.1.1} – The road would pass close to Somerhill Park, which is Grade II listed in the Register of Parks and Gardens of Special Historic Interest in England prepared by English Heritage.

Effects on water supply

{4.2.6.3} – The Assessment states that the large cutting through Castle Hill with its associated drainage problems would depress ground water level in the immediate proximity, and may also intercept the flow on the more easterly of two streams.

{2.4.7} – Stringent measures would be required to protect an aquifer that provides Pembury’s public water supply if the road is built.

Disruption During the Road Building Period

We are concerned about the amount of vehicle movements. And where material taken away will go to or where material brought will come from. The vehicle movements will involve large consumption of fuel (an exhaustible resource) and release of CO2, a greenhouse gas. The Statement says

 {4.2.10.2} – that there would be movement of 1.2 million cubic metres of material in total, and the requirement for 150,000 cubic metres of granular material for the works involving 19,000 lorry movements.

{4.2.10.3} – 250,000 cubic metres of Wadhurst Clay would be removed, involving 30,000 lorry loads and 130,000 cubic metres general fill material, in addition to the granular material, would need to be imported, involving 16,000 lorry movements.

{4.2.10.4} – no local facilities exist for the extraction of the granular material, so this would have to be imported from other areas.

Our Preferred solution

Our preferred solution to road transport is to switch priorities to building up Rail, and Rail infrastructure, buses, coaches and use of canals and rail for freight, and encouragement of the use of Local supplies of goods to save long journeys. We don’t want this new road to be built, but if the D.O.T. decides to proceed, the D.O.T. should limit itself to improving the old A21 route.

Questions we would like to ask:


 1) How much more will it cost the NHS in illness due to car injuries, asthma, and all other anticipated related health effects.

 2) How many buses, or trains could be purchased with the money saved if the scheme did not go ahead.

Conclusion

Circumstances have changed since the road infrastructure started to be developed on a large scale for the car in the 1920′s and 30′s. At that time it may have been quite justifiable to load advantage towards road building in order to get road building going. The situation is different now, the necessary road infrastructure is in place, and the attitude towards road development needs to change accordingly. Alterations to, and new, road schemes should be judged on all of their merits and demerits, including health aspects, and human and natural environment. Alternative forms of transport must be considered urgently. There is no need to stack the advantage towards road building any more. A change in national policy would help resolve some silly contradictions like – you may not pick wild flowers or put endangered species at risk unless it’s with a bulldozer, and you are building a road. It must not be forgotten that large numbers of animals are killed during any major road building scheme.

Final Point

One final point: your choice of venue for your exhibition at Weald of Kent Girls Grammar School, Tudeley Lane, Tonbridge, was not at all convenient for cyclists, public transport users, or residents of Southborough or Tunbridge Wells.
 

Yours truly
Nigel Hewlett
Coordinator of Countryside Land Use and Transport Group of
Tunbridge Wells Friends of the Earth

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