Created < 2009, Changed; 08/10/2017, 29/02/2020

Old this webpage; http://ww1.andrew-lohmann.me.uk/environment/a21-at-castle-hill/access-to-hastings/ahs_comm/

Comments on Access to Hastings Study Commissioning Report.

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. I have regularly attended meetings of East Sussex Transport 2000 & East Sussex Sustainability forum. Since the start of the study a discussion forum has formed by Tunbridge Wells Friends of the Earth for people interested in the study. The forum is open to any one or group concerned with nature, wildlife, archaeological heritage, Sustainability and alternatives to Roads building. I wish to reaffirm my interest in joining the reference group for the Access to Hastings Study. Would you tell me any meetings will occur and send me a copy of terms of reference. Please note that some of the comments are from other groups who can give better explanation of problems they see and there proposed solutions. The comments in this paper may be endorsed by Tunbridge Wells Friends of the Earth, and other groups, in due cause. Sections I have included are; Comments on Access to Hastings Study Commissioning

Report. Options that I would like the study to consider. Appendixes – please refer to the following appendixes in my submission to the Roads Review and Integrated Transport November 1997.

(1) Alternatives (1a) Rail Alternative and (1b) TP 18.

(1c) case against Park and Ride

(2) Criticism of COBA and other computer models – Mr Mainhood who has agreed that members of STOP THE ROAD use his criticism of COBA.

(3) Response to Integrated Transport Strategy.

(4) Local Councils Position

(5) Traffic flow figures.

Additional appendixes; (1d) Additional Rail options.

- From myself and Cllr. Val Catt letter to Government Office for the South East dated September, 1999. To follow

- (5b) Accident figures analysed for various sections of the A21. – Note I would appreciate receiving this information from the study consultants in order for me to comment and create this appendix.

Andrew Lohmann

Member of Tunbridge Wells Friends of the Earth.

FILE: ahs-comm.doc, 18-12-99

Comments on Commissioning Report

2.4 Dot 4 – Consensus probably is not possible. You will note Tunbridge Wells Local Transport plan appears to be suggesting the council do nothing itself but it does tell the government to build a new section of A21 trunk road at Castle Hill, and build a new out of town hospital. Neither policy is consistent with the borough councils view prior at the time of the last government. The Kent and Sussex hospital has very good accessibility by public transport, and much investment has been made in new building on this site. The local council was sceptical about building the A21 trunk road at Castle Hill at the time of the public inquiry on the road in 1993.

2.6 Don’t agree compared to Tunbridge Wells Hastings is very accessible though there is lack of rail freight sidings in both Tunbridge Wells and Hastings. Roads in to Tunbridge Wells are at capacity and there is no way of alleviating this where as rail capacity could be increased.

2.8 append after “…. the choice solutions safety and congestion problems on the A21 between Tonbridge and Pembury” “may exasperate these problems and does not address severance of communities where as a rail for freight could provide new access opportunities to both towns.”

3.7 Dot point 1 – must consider severance of communities. Also consider the causes of problems where crashes occur with fatal and serious injuries and suggest solutions. Congestion due to vehicle tail backs from Tunbridge Wells centre there are strong policies in the local plan to prevent etra traffic from being created in the town centre. Local policy expressed in the public inquiry in 1993 was changed so as not to make Pembury Road the main route in to town.

3.10 Dot point 4 add A26 to Newhaven. 3.21 Holes Hall Road/Conford Lane to be no through route. I don’t support Rail Line crossing at Nells bridge and therefore discourage Grosvenor Road another route in to town.

3.24 Note rail and bus to be integrated I support the creation of local transport authorities like London Transport for towns such as Tunbridge Wells.

3.26 Key issue school term time traffic congestion. Encourage parents to send their children to the nearest school, and offer free bussing to school for any distance.

3.28 Delete any COBA analysed data and re-assess the data with the principals of SACTRA. There is a discrepancy between COBA estimated figures for 1996 and actual traffic figures that have occurred.

4.5 Accessibility I am concerned that the equation shown could be distorted if the costs are in pounds (this is the same problem that COBA model had). The cost should be recalculated in to time equivalent and summed. I believe that time saved is a more equitable currency. For example a section of fast trunk road, were to sever a community. A millionaire earning £1000 an hour were to save six minutes journey time that would be equal to £100 saved. On the other hand a low paid worker paid £4.00 an hour who cycles to work but would be unable to cross the new section of trunk road. If the worker spent an hour longer equivalent to £4 or spend £4 on a taxi fare. Presumably sum of jobs costed in pounds would give a figure of £96 towards the road, but if costed in time would give 50 minutes towards the cycle option

5.9 Please see alternative options for A21 at Castle Hill. Note safety ordit needs to be done.

5.14 Add Wealden Line Access Group – to restore the rail line. Also add Kent Wildlife Trust.



  • Reduction in road speed by 30% and reduce total transportation, the encouragement of local supply for local needs.

  • Where transportation is necessary I support the switching of modes of transport to more sustainable forms such as rail. Vehicle emissions which are a major cause of respiratory illness and death, also cause global warming. Policy in the past has relied on vehicle emissions dropping through technical design fixes, such technical fixes have not occurred and are unlikely to achieve enough. Technical development has resulted in increased vehicle speed and acceleration, but not fuel efficiency, and can never deal with congestion. A high accident rate is often the results of high speeds.

  • The outcome of the study should take account of national and international objectives of; “Sustainability” and the objectives of “Local Agenda 21″. The reduction of the creation of CO2.

  • Sale of British Rail land should be considered carefully. Some of this land could be in the area of the study.

  • Take account of Wildlife and the Natural environment in the whole area of the study. Therefor:

  • Consider the environmental impact of the approved scheme for a new section of 6 lane trunk road at Castle Hill. This new road would go across an iron age settlement, Castle Hill, cause the loss of semi-natural ancient woodland, including what is believed to be a relic of the extensive ancient forest of Andredsweald. The road goes through a pond with Great Crested Newts, an endangered species. This contravenes accepted law. Nightingales discussed in the Environmental Assessment are heard every spring Before any such road is considered a proper environmental assessment must be demanded. The inspector’s report after the inquiry in 1993 said “…Only limited information was available before route selection was made and, even now, it is clear that detailed, sophisticated research is needed, …”.

  • Consider the archaeological impact – Material of archaeological interest in the ditch surrounding Castle Hill was lost when the previous section of Pembury By-pass was constructed. The whole area surrounding Castle Hill and the Pembury by-pass is rich in natural wildlife and archaeology. The approved route can be viewed from many parts of Tunbridge Wells and the area is a local landmark. It is also known by the Pembury TV transmitter. From Tunbridge Wells, Castle Hill is visible from a 4 mile radius through 100′ angle. The Local plan pays attention to protection of the natural surround of Tunbridge Wells.

  • Severance the communities – Access between Tunbridge Wells & Pembury across the A21 by pedestrian and cycle is very difficult.

  • Replace Longfield Road roundabout by Traffic lights to allow fair turns for all road users as well as pedestrian and cycle users to crossing the A21 at Longfield Road.

  • There is consensus amongst many local groups that option for a 6 lane section of trunk road has a serious natural environment impact. There is no necessity for such a high speed road to be built given that the majority of traffic should be slowing down to enter Tunbridge Wells. An additional crawler-lane at Castle Hill may be a suitable palliative for those wishing road building. Such a lane could be used for traffic cueing to enter Tunbridge Wells, thereby allowing through traffic to pass. I don’t support building a crawler lane, and prefer that the whole of the A21 be de-trunked south of Tonbridge.

  • Reassess any analyse done with COBA. – The computer model in this case of the new section of A21 trunk road at Castle Hill 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. (Reference Mr Mainhood objector at the public inquiry in 1993) This is ridicules it seems COBA will justify any grandiose road scheme.

  • Figures of accidents to Hastings on A21 – Good safety at Castle Hill but stage slowing down required on the Tonbridge by-pass where there is a safety problem. Pembury by-pass should be made slow, and Traffic Calming at Flimwell for safety reasons.

  • Rail Park & Ride, John Goodfellow has developed the Cllr Bannerman proposal. The proposal is to build new rail stations including at Longfield Road, Good Station Road, and run additional train in to Tunbridge Wells.

  • Villages should be encouraged to consider a central bus stop, shop, and car park, to enable rail users to bus in to rail station such as High Brooms for example. This would additionally provide extra support for village bus service, and shops.

  • Rail reopen the rail line to Brighton to Tonbridge via Tunbridge Wells. (Add the route of the A26 to Newhaven to the study).

  • Use Newhaven as a sea/rail freight interchange and therefor supporting the reopening the rail line to Brighton or Newhaven to Tonbridge via Tunbridge Wells.

  • Rail for Freight – carry waste from Longfield Road – Freight siding on west side use by Shell to transport heating fuel oil were revamped 17 years ago but have not been used for 10 years. Oil is carried by road through residential areas. – Gypsum is carried from Mountfield Halt near Hastings by rail.

  • Upgrade rail through Tunbridge Wells to twin track working, by widening the tunnels. This may be achieved by removing the brick lining of the tunnel and re-lining the tunnel with steel to gain 18 inches required. Therefore support of TP18 in the Local Plan for Lewes-Uckfield-West Station Tunbridge Wells.

  • Rail and bus to be integrated. The study should recognise the problems with the bus services and support the setting of an agency like London Transport. Such an agency would contract companies to run all routes and manage the collection of and redistributed fares. The problems that should be addressed is:- – No through ticketing between different modes of public transport. – Disparity in ticket types and prices e.g. – Most bus companies accept all return and explorer tickets but some do not necessarily. – One local bus company manage many bus stops but do not display current timetable information of there own and are worse at displaying commercial services run by other bus companies. These bus stops should be maintained independently of the companies. – Poor reliability on popular commercial routes run by a sole operator are cancelled at random. – Poor availability of no-step-buses for easy push and wheel chair access they are put on any route at random making it impossible to plan an outing. Most of these buses are in cities leaving large and small town and villages with very little availability.

  • Problem with traffic using Holes Hall Road/Cornford Lane should be made a no through route.

  • Pembury Village requires that traffic be discourage from passing through the village when the Pembury by-pass is congested with traffic entering or leaving Tunbridge Wells. Make two of the four lanes Pembury by-pass (A21 trunk road) no exit along its length therefore a by-passing the A264 turn off. Make the other two lane extensions of the A264 in order to carry traffic cueing to enter Tunbridge Wells.

  • Hastings – stop the local policy of relocating unemployed homeless from Tunbridge Wells to Hastings – Rail instead of road commuting between to Hastings and Tunbridge Wells occurs and policies that encourage mode switch towards the non-use of cars for any part of a journey should be pursued.

  • Opposed to any proposals that would increase traffic in Tunbridge Wells Town Centre. I refer to policies TP10, and 11 of the local plan presume against increasing traffic into Tunbridge Wells town. Therefore:

  • Don’t increase the road capacity of the A26 through Southborough or roads on Southborough Common.

  • Don’t build a road bridge to cross the rail line between the two sides of the North Farm Industrial Estate. Such a bridge would increase traffic via Upper Grosvenor Road in to Tunbridge Wells.

  • A New Hospital if necessary should be in Tunbridge Wells Centre as this provides the best accessibility by public transport. In any case the Kent and Sussex Hospital is a comparatively very well run hospital, with new buildings on site. Tunbridge Wells town benefits from many bus services into the town until late evening.

  • The Lamberhurst and Polegate by-passes are within the study area have not been included and will be built what ever the outcome of the study. The study should recommend alterations to these schemes make them more modest before they are built if that is in keeping with the outcome of the study. The Lamberhurst by-pass trunking is proposed to go through the grounds of Scotney Castle the South East head quarters of The National Trust. The grounds have many popular public foot paths and feature much natural wildlife. There are also archaeological implications. Lamberhurst the village nearby has built up like most villages over time because of the trade the major road brought. To remove passing trade could see the demise of local business and the death of a viable village.


Appendix 1d Rail for freight and for short distance travel outside of London Since our submissions to the roads review where we supported the restoration of Lewes-Uckfield-West Station-Tunbridge Wells rail line for heavy rail and the restoration or creation of a railway line Tunbridge Wells to Ashford. we add our support to the creation of Rail sidings and passenger stations in Tunbridge Wells at Good Station Road and North Farm Industrial Estate. This will further encourage smaller, short haul van runs in town rather than long haul lorries. The restoration of rail line is probably a matter for Rail Track to finance, but however it is financed we urge GOSE to pursue it.