To; Mr. C G Mc Quilkin
DETR Zone 3/1
Great Minster House
76 Marsham Street
This is the joint position statement of the following organisations on the proposed A21 works between Tonbridge and Pembury. Position Statement; We believe that the proposed new section of the A21 from Tonbridge to Pembury as envisaged will (in no order of importance); Be extremely environmentally damaging . Be visually intrusive.. Lead to further roads based developments. Not solve congestion. Use up funds which are desperately needed elsewhere, and furthermore that it: Ignores the transport possibilities of the railway line in this transport corridor. Be based on a discredited COBA. (Cost Benefit Analysis). Not bring the claimed economic benefits. Page 1 of 5
2. Taking these one at a time; Environmental damage; Damage to an AONB; the proposed new road will destroy an area of ancient woodland, as well as threaten the flora and fauna along and adjacent to the proposed new road. Increased air pollution from increased traffic; the road will generate more traffic and thus lead to higher levels of air pollution. Tonbridge in particular is vulnerable to air pollution becoming trapped in the valley. Both towns are suffering from high levels of traffic related air pollution. Increased noise pollution; The noise from the exiting dual carriage way sections of the A21 are already intrusive for the residents of Tonbridge and Pembury. The proposed new road would cause further intrusive noise, adding the residents of Tunbridge Wells and Southborough to those already affected. Damage to Bronze Age Hill forts: Castle Hill fort dates from the Bronze Age and has yet to be explored by professional archaeologists. Visually intrusive; The proposed road is a six lane dual carriageway with embankments and a cutting on the ridge line at Castle Hill. This will be visually intrusive and detrimental to the High Weald AONB. The road will be visible from Southborough, Tunbridge Wells and further afield. Lead to further roads based development; Breaking the visual gap between the towns of Tonbridge and Tunbridge Wells will lead to pressures for more development along and adjacent to the road. Strips of land alongside the road will be marginalised and subject to speculative planning applications. Any extra development will create more traffic and negate any perceived traffic flow improvements created by the new road. TWBC has already had planning applications for a motorway style service area on the crest of Castle Hill,- prior even to any road construction. This threatens the integrity of Local and Kent County Structure Plans and would seem to be inconsistent with Central Government guidance and PPG 13 in particular. Congestion; The new road is unlikely to shorten overall journey times. The extra three lanes each way and the continued use of the old route as a local feeder will increase congestion. Driving will be encouraged over other forms of transport. The present feeder roads are at capacity, and any extra traffic attempting to enter the two towns will increase traffic on residential roads. Page 2 of 5
3. Local transport needs; Both towns desperately need investment in local transport measures, to improve accessibility for residents, particularly for those without access to a car. The use of scarce funds for the A21 scheme can only put back the day when this investment can be made. The Rail / A21 Transport corridor; The railway line in this corridor seems to have been disregarded in transport planning terms, with reference to its ability to provide an alternative to increasing the capacity of the road. Unlike the A21 Trunk Road the railway accesses the centre of the towns along the corridor. The line from Tonbridge to Hastings was electrified only a few years ago, allowing for more direct trains to London from stations south of Tonbridge. Greater return on this investment should be sought before any new road construction be considered. The COBA for the scheme; According to the SACTRA report of 1994 this is most likely flawed, and should be the subject of reappraisal. The inclusion of this road in the TWBC Local Plan and KCC Structure Plan should be in doubt for this reason. The Economic argument; Economic benefits claimed for this scheme appear to be questionable. Locally, a likely scenario is that this road will hasten the loss of local trade to the major new car- borne shopping facilities, including Lakeside and Blue Water Park. Regarding the south coast will better road connections to Hastings really regenerate the town, or cause economic activity to flow out of the town.? Would the town not be better served by improved rail access, and better access along the coast to the Channel Tunnel?. In any case the proposed capacity increase to the A21 could only reduce journey times by a few minutes between Hastings and London. Only a dualling of the whole A21 could conceivable significantly reduce road journey times. Is this the intention, and at what cost to environment and public purse? A thorough appraisal of this subject has been carried out by SCAR, a summary of which is attached at Annex 1. Page 3 of 5
4. Solutions; We believe that there is a viable alternative to the proposed road, which would better serve the interests of the local communities, give better economic value for money and be consistent with Central Government guidance on transport and planning. We call on the Government to implement the following as an alternative to the proposed road; A quality cycling / walking network in Tonbridge and Tunbridge Wells,- including a link between the towns. Upgrading of Public transport, including; bus lanes, bus stations in the two towns, improved bus stops and real time information systems. a goods / passenger station at Longfield Road, Tunbridge Wells. Traffic management/ calming and restraint measures in the two towns. Improved train services on the London
- Hastings railway line. An upgrade of the A21 on the existing line, such as; a crawler lane up Castle Hill. traffic management measures to improve safety.
We believe that these proposals would have a multi – user approach to transport provision, are in line with planning and transport guidance, would improve road safety, and assist in reducing pollution /improving health.
The proposals for the two towns could be funded through a Package Bid, such as that proposed for the two towns by Kent County Council. These proposals would require close co-operation of the Local Authorities and Kent County Council. The railway proposals would require the co-operation and input of the Rail companies. Page 4 of 5 SIGNED: Organisation Print Signed “STOP THE ROAD” A21 Pembury Bypass to Tonbridge bypass dualling Tunbridge Wells FoE.