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Created;< 2009, changed; 14/09/09, 11/04/2012
Please find att info on the proposed  third Canterbury park and Ride site.

This is my objection.

If any part is useful for any similar purpose, then please use--esp the references.

All good wishes,

Eric Parkinson
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Director of Planning                                            13th. August 1997
Copies to City Councillors for information.
Copy to Chief Executive

Re. Planning Application  CA/96/0030/CAN
Out-of-town car park ("park and ride") to promote unsustainable car-led 
development in south Canterbury.

Dear Mr Jagger,

I have viewed the plans for the proposed out-of-town car park.

They reinforce my belief that City Council officers offer poor, misleading 
advice to Council Members. Short range park and ride is for the 
economic benefit of the few at the environmental  expense of  
Council Members have perhaps been sheltered from the growing  body 
of environmental evidence against short range park and  ride.
I am delighted that my letter may become a public document open to the 
scrutiny of interested persons.
The more people that become aware of the  shortfall of short range park 
and ride  the better.

The park and ride site has been proposed as a means of re-locating car 
parks displaced from city centre redevelopment.

In essence, it is out-of town expansion by the back door.  Instead of 
building directly in the countryside, inner city car parks are  displaced 
into the countryside. This is clear from existing literature on the 
Whitefriars development (CCC/ Land Securities!

 1996)  where it is noted:

The increase in the retail floor space means that there  would normally 
be a need to provide more car parking spaces than exist at present. In 
line with normal policy, agreement will be  reached with Land Securities 
on the payment of contributions for the provision of replacement and 
additional parking in a new park and ride site on the south side of the 
city...to ensure that environmentally acceptable development takes 
place" (para. 8.7)

So, will you please tell me  how this resultant car park dumped in the 
countryside will ensure that "environmentally acceptable development 
takes place" ? Whose environment are we talking about?

Then of course, there is that term "additional parking".
I am pleased to recall the words (CCC 1997) of the Local Plan  Public 
Enquiry Inspector , commenting on the provision of car parks as a traffic 
generator in the context of rejecting  land for  business allocation. 
Business allocation ?--Sounds seriously similar to the Whitefriars--and yet 
it is roundly dismissed with these profound words:

"Moreover, such an allocation would release a greenfield site outside 
the urban area for a substantial development which it is clear from the 
evidence presented is intended to have generous car parking provision, 
thereby encouraging the use of private cars with serious implications for 
future transport provision...." (Chapter 3, Page 3 para c1.8)

If that is the case, so clearly printed out in black and white, that  car  
parking on this proposed green field site outside the urban area would  
encourage the use of private cars--with serious implications for future 
transport provision, then why on earth is short range park and ride 
considered at all? It is EXACTLY the same thing!

The Whitefriars Approved Development Brief (1996) has a few more 
gems in store--perhaps that is the wrong term to use--for it makes these 
interesting claims....

" The guiding principle of the transport strategy  (the PARC Plan) for 
Canterbury is to provide a balanced system which conserves the 
environment and heritage of the city whilst allowing for travel necessary 
for the economic well-being  of Canterbury. The strategy involves 
managing car travel and providing alternatives to it including cycling, 
walking, public transport and a comprehensive park and ride system. 
Traffic management measures are an important part of the strategy. 
...planning and land use policies are aimed at reducing the need for 
private car travel"  (para10.1)

This last statement is not  true. Planning and land use policies via park 
and ride are aimed at increasing the need for private car travel.   CCC 
statistics from the Park Plan Review demonstrate that short range park 
and ride encourages car use. In terms of land use, it wastes space with 
out-of-town car parks. In my communications with Council Officers, it 
has been established that Canterbury short-range park and  ride takes 
travellers away from more sustainable, lower energy modes of travel 
(CCC Parc Plan Review 1995) so that up to 8% have abandoned buses 
and trains.
The Parkhurst (1996) research recognises this pattern of development 
in studies of nine English cities cursed with park and ride....

".....In fact, it is not unreasonable to suppose that an aggressive policy 
of short-range bus-based park and ride implementation   could reduce 
revenue to local public transport operations, reduce their  energy 
efficiency and in some cases lead to service cuts...." (p.27)

Short range park and ride also promotes new journeys--by car of course.

It promotes the use of cars for the longest leg of journeys and only 
supplies public  transport for the shortest distance into the  city centre.

It will not, repeat NOT,  assist in any traffic reduction measures beyond 
the urban mass. So far it has only served to increase traffic beyond 
It will certainly  not assist the Council in addressing the challenge of the 
Road Traffic Reduction Act. 

One of the claimed benefits of park and ride in Canterbury is that there 
has been a  reduction in traffic flowing through the urban cordon. In fact 
 this assertion  is  based on  selectively used figures. The Parc Plan 
Review uses the  1991 peak of  165,000 vehicles/day  (also a peak of 
economic activity)  and a dip in 1993 of 150,574 vehicles/day to 
illustrate traffic reduction.   The trend however (1996 figs not yet 
available) has been of  stability at 155,000 vehicles per day.  There 
should of course be no satisfaction in that. 

Vehicle flows through the urban cordon are crude indicators of  vehicle 
activity and related air and noise pollution. Vehicles that once parked in 
the city centre now park in out-of-town car parks. A number of short 
range journeys have been eliminated from the city margins to the  
centre. However, if the traffic flows through the urban cordon have 
stabilised at 155,000 vehicles per day, then other traffic has replaced 
the short range journeys. The replacement traffic will probably have 
travelled further than the two km  short leg it has displaced. This is 
damaging long range through traffic which has taken up the space 
vacated by park and ride users.
So in summary, park and  ride does the following things:

* causes travellers to abandon train and bus for the out-of-town 
convenience of greenfield site car parks;

* enables the growth of through traffic;

* initiates new journeys to Canterbury (by car) because of the so called 
"easy" parking.

What has been established so far is that some people who will make 
money out of city centre redevelopment are happy to concrete over the 
countryside for unsustainable park and  ride measures. It appears that 
the City Council will go along with this since Land Securities will fund 
part of cost of  the out-of-town car park.

But there are other players in this arena.

For some time, higher education establishments have been hoping to 
add additional capacity via development in out-of-town locations. That 
they should wish to do this is surprising since in the future, intensively 
used inner city locations will prove invaluable since they are near 
sustainable long-haul travel transfer points such as rail and bus stations. 
In 20 years time, park and ride will have been long gone. But that is their 
Four out-of-town sites  were considered, but lo and behold, along comes 
an Officer of the City Council with an offer not to be refused. I refer to 
the submission by Grimleys (Wilson 1996a) in which the following 
comment is made...

"The Identified Procedural Difficulty and Solution....Since the 
submission of the College's initial representations  the Planning Officers 
have encouraged the College to select a preferred site...within the last 
six months  particularly, the planning officers have led the College to 
select the land to the south of the New Dover Road as the least 
sensitive option for a second campus...." (para. 3.19)

So why this rush to assist institutions of higher education? Perhaps the 
answer lies in this next (Wilson 1996b) statement....

"A final issue which was highlighted by JM (Jean Morgan) was the 
possibility of a college contribution to infrastructure requirements in 
connection with an educational campus to the south of  the New Dover 
Road. Possible improvements to the A2 junction, and the release of  
college parking space for use as part of the park and ride (at weekend 
and vacations when there  is limited demand from the college) were 
both highlighted as possible contributions."  (Section 10. Para. 8)

So the secret is out. Institutions of higher education are being asked to 
fund the unsustainable park and ride aspirations of the City Council 
Moreover, the  institutional car parking spaces are to be used as top up 
for the park and ride.
But wait a moment. Education is very much a business these days. All 
institutions have business plans and some of them may seem keen to 
play part-time road infrastructure developers.  This sounds like a 
business allocation to me.

Let me recall again the words of  the Local Plan  Public Enquiry 
Inspector, commenting on the provision of car parking  as a traffic 
generator in the context of rejecting  land for  business allocation. 
Business allocation--yes indeed, it sounds seriously similar to institutions 
of higher education. And yes as we know,  it is roundly dismissed with 
these words. Here they are again:

"Moreover, such an allocation would release a greenfield site outside 
the urban area for a substantial development which it is clear from the 
evidence presented is intended to have generous car parking provision, 
thereby encouraging the use of private cars with serious implications for 
future transport provision...." (Chapter 3, Page 3 para c1.8)

I would want to see a full environmental impact assessment on the 
effects of park and ride both on traffic flows within and beyond the city 
centre before ANY land is converted to out-of town car parks to please 
Land Securities or anybody else.

. There are alternatives to short range park and ride.
There is the direct use of public transport with access by  walking and 
cycling,  and there is the development of long range park and ride .

In these models, the fundamental part of the journey is taken by energy 
efficient train or bus-- NOT  by car.  Such  schemes might, for example, 
require limited  improvement of outlying rail station car parks  and 
co-ordination of a more frequent  train service at an attractive price.

Neither of these aspects are beyond the planning capability of city 
council Officers.
The development of light rail around the route of the ring road as has 
been explained in previous communications, is something to be  taken 
into account for the future.

In the Canterbury District Local Plan Inspector's Interim Report  (1997), 
the inspector notes "It is surprising that a traffic impact analysis has not 
been made available for the park and ride site..." (para cl.14, page 4), 
and indeed it is surprising that so much public money can be thrown 
away on what will be short term car parks--  with limited awareness of 
how the park and ride model is interacting with ALL aspects of  
transport, land use and environmental impact.

In the absence of useful data from the Parc Plan Review, a short survey 
was conducted on behalf of Canterbury Friends of  the Earth at the 
Wincheap Park and Ride site on Monday the 11th of August between 
07.15 and  09.00 hrs.  There were  93 respondents. This is  the bulk of  
users in that time span--there were three  subject  refusals and about 10 
subjects  missed due to simultaneous arrivals and unavailability of 
sufficient data collection personnel. 

The users were asked to supply  their road of origin and postcode. For 
triangulation purposes, from this data, the places of  trip origin were 
zoned  in line with the 7 zones identified in the Parc Plan Review and 
were of similar distribution. 

For comparison, the sets of data on zoning of trip origins is shown 

                                Park Plan Review data    FoE data from 11 Aug.
                                27 Aug 1995                     1997
Zone 1   Canterbury             %               5%
Zone 2    A291/ A28  from  NE   3%              4%
Zone 3    A290 from north               3%              8%
Zone 4    A2 from west          11%             13%
Zone 5   A28 from south         40%             31%
Zone 6  A2 from south east              33%             34%
Zone 7  A257 from east           1%             5%

With regard  to favouring sustainable options--such as rail and bus, rather than promoting unsustainable car-led short range  park and ride, a 
dispersed long-range rail based platform was used as a modelling tool to 
see what alternatives could have been used at Wincheap.

Preliminary analysis  of the data, suggests that 52 of the 
respondents--56%--actually had  trip origins that began within four Km. of 
 rail stations and would have had direct trains to Canterbury. Many of 
the respondents could have walked or cycled to rail stations.

The data further suggests that a further 16% of users had trip origins 
within 4 km of stations --but with the disadvantage of a change of trains 
at Ashford.

72% of users could  have been served with existing infrastructure A light 
rail system would compound the low energy effictiveness of such 

The  words of  the Parkhurst (1996) research come to mind here...

"To date, bus park and ride schemes have been less able than rail 
schemes to assist in the development of the overall public transport 
network" (p.27)

Why  was Wincheap Park and Ride built?  Was it simply a cleverly 
engineered  stepping  stone to the car-led, car dependent out-of-town 
warehouse shops that have come to  symbolise the Sturry and 
Wincheap sites?

I shall not labour the point regarding the loss of agricultural land as a 
long term resource. The Royal Commission on Environmental Pollution , 
Report 19 ( RCEP 1996) made the point that " there should be a strong 
presumption against converting greenfield land to other uses"  (para. 
10.17) and that  "....the adequacy of     soil resources is a global issue. 
Serious forms of soil degradation are apparent in many other countries. 
The   task of managing the UK's soils wisely has to be viewed against 
the probability that increased food production will be necessary in 
temperate countries to meet the rising world demand from a  rapidly 
growing population and in the face of serious shortages of water at a 
global level"  (para. 11.3)

The city is relatively compact,  has the remains of a medieval core 
which the planners did not get their hands on,  and is characterised by 
fertile lands--those lands to assist in feeding demand from a rapidly 
growing population--- at the city margins.

In my view, the fertile land--the hopfields and orchards--are as important 
to the "sense of place" of the  city as the medieval core.

The inspector suggests in the Interim Report that the City Council would 
be " failing   in its responsibilities to residents, and as custodian of the 
historic environment of the city, if it did not look to see what can be done now to help reduce traffic and congestion  in the city centre...." 

I submit that the  "historic environment of the city" includes the total city 
Destruction of the green city margins  with out-of-town car parks AND 
the associated development that accompanies them--as at Wincheap 
and Sturry--is an act of short sighted planning vandalism of Holden Plan 
There are other ways to solve the problem, given sufficient imagination, 
ecourage and public awareness of local agenda 21 obligations.

.Enough mistakes from the destructivness of the  Holden  Plan to 
Buchanan car-led road building have been made at the hands of City 
Council planners. Now it is time to  employ some vision for the future 
rather than replicate and  entrench the failure of bus-based  short-range 
park and   ride. 

I trust that City Council Members will continue to  give this issue serious 
The short term economic benefits of park and ride will principally 
engineer the profits of the few.  This will be done  at the long term 
environmental expense of everybody. The small, distinctive City of 
Canterbury will become a nondescript sprawl indistinguishable from other 
spoilt urban environments. Please, please do not let this happen.

Yours sincerely,

Eric Parkinson.

CCC (1997) Canterbury District Local Plan. Inspector's Interim Report, 
Canterbury: CCC.

CCC (1994) Technical Paper 4,  Canterbury District Local Plan, District  
Transport  Strategies, CCC.

CCC (1995) Parc Plan Review

CCC/ Land Securities PLC (1996) The Whitefriars Canterbury Approved 
Development Brief.

Parkhurst, G., (1996) The economic and modal -split impacts of short 
range park and ride schemes: Evidence from nine UK cities, Oxford: 
University of Oxford Transport Studies Unit.

RCEP (1996)  Royal Commission on Environmental Pollution, Nineteenth 
Report, London: HMSO

Wilson D J M (1996a) Canterbury  District Local Plan Enquiry, Objector 
ref.  292, Proof of Evidence. April 1996,  DJMW/MP/DN/029600344

Wilson D J M (1996b) Canterbury District Local Plan Enquiry, Objector 
ref. 292, 
Appendices, Section 11, April 1996,   PR 57292/2118

Please Note:
In the event of any aspect of development in  South Canterbury being  called in by the Secretary of State, it is my wish that this response is 
formally included as evidence and I assert my right  to supply additional 
information as becomes necessary.