Mr G Hanson, xx, xxxx Road,
Project Manager for The Access to Hastings Study, High Brooms,
Government Office for the South East, Tunbridge Wells,
Bridge House, Kent, TN4 xxx.
1 Walnut Tree Close, Tel: 01892 xxxxx
Guildford, 01892 xxxxx (work)
GU1 4GA. E-MAIL: AndrewHLohmann@compuserve.com
COPY TO: Mr D Coffee, East Sussex Transport 2000.
FILE: gose21-2.doc 23 September, 1999
Access to Hastings Multi modal study
COMMENTS ON THE STUDY:- The study needs to have an appropriately wide remit, and the steering group should include representatives of archaeological, bio-diversity and habitat specialists, and local residential environmental interest. In asking for these to be included we draw your attention to the inspectors report of Local Inquiry for the 6 lane “A21 Tonbridge by-pass to Pembury by-pass dualling”. Representation were made in regard to the effect on the natural and local residential environment where road building would lead to an increase in traffic through Sherwood and other areas. Who on the Steering Group is qualified to address detailed environmental issues? I draw your attention to the Inspector’s report of the public inquiry in April – May 1993. Though recommending the DTp’s preferred route, he says under the heading: Wildlife and Nature Conservation:- 289. The area is rich in wildlife and habitats, especially in the ancient semi-natural woodland and replanted ancient woodland. Such areas have a high degree of naturalness, diversity of species and stability and represent a serious loss, largely because of their qualities are difficult if not impossible to replicate. With this exception, however, the ecological impact of the published route is slight. To some extent this seems to be a somewhat fortuitous outcome. Only limited information was available before route selection was made and, even now, it is clear that detailed, sophisticated research is needed, preferably in partnership with the nature conservation interests – for example the Kent Trust for Nature Conservation – to ensure that the ecological harm of the route, if it is built, is kept to a minimum and the most appropriate mitigation measures put in place. The draft consultants brief for the Access to Hastings Multi modal study should have a wide enough remit to consider how a collection of local measure such as pedestrian and cycle crossings to link either side of the A21 along its length e.g. north end of Vaxhall Lane to access Somerhill and Tonbridge, Longfield Road to Pembury Hospital, Blackhurst Lane to Tonbridge Road, Dundale Road to Pembury High Street can be included. The existing A21 is a barrier for people who need or wish to walk or cycle. The study should not discount the option for example of de-trunking of the whole section of A21 south of Tonbridge. You may note that the unsuccessful ‘Weald and Downland DBFO Project’, was road trunking from Chevening, Sevenoaks to Eastbourne via Hastings and Brighton, would the restoration of the rail line Tunbridge Wells to Brighton be more appropriate? See our comments attached on the draft consultants brief. PTO Will the study and interests on the steering group include as a central objective national and international objectives of; * “Sustainability” and the objectives of “Local Agenda 21″. * Ecological view such as the reduction in energy use and the creation of CO2. For example the reduction in car traffic, the encouragement of increased use of other modes of transport and the improvement of pedestrian facilities?
Andrew Lohmann (Southborough Town Councillor)
Val Catt (Tunbridge Wells Borough Councillor)
The draft consultants brief We support:- in section 3 last paragraph “In addition A21 Tonbridge to Pembury Dualling scheme…………. did not represent a sustainable solution to the problem”. We oppose in the same paragraph last sentence “The study will need to consider alternatives …………….” the paragraph should end “and must also address division of communities severed by road demanding car usage to cross that line for every purpose”. To enhance section “4. STUDY CONTEXT” sentence after last dot point ending “inclusive society”. Append “- not one physically divided”. The heading “General aim requirements” “NEED HASTINGS REGENERATION STRATEGY(?)”. In the third paragraph “The Study will also……….” replace “….safety problems associated with the A21 between Tonbridge and Pembury” with “…. noting good safety record associated with the A21 between Tonbridge and Pembury by-pass, and the dangers associated with high speeds of traffic on the Pembury by-pass”. Reword last part of final sentence of same paragraph to read “……….the Study will need proposals that deliver Sustainability”. – We note that in the minutes of “Access to Hastings” Steering group meeting 19 July 1999.
Point 5 C The land-use planning debate should not be re-opened….”? It is most likely that the local plan review will be under review during the study. In anycase it may be necessary to delete reference to A21 trunk road at Castle Hill for example, and enhance rail options. Fifth paragraph, third point, “The Access to Hastings Study should consider options for dealing sustainably with congestion and safety problems on the A21 between Tonbridge and Pembury” is this necessary? See our point above on paragraph 3 re safety of this section because of lower speeds. Seventh paragraph “This strategy should provide……” – “up to 30 years”. Is this sustainable? It could mean 2, 5 or 10 years. Replace with “at least 30 years”. Same paragraph “In order to provide…………links established between improved accessibility and regeneration” – what links? Refer instead to SACTRA report casting doubt on such links. Same paragraph last dot point we question. What is the percentage of Tonbridge Pembury traffic which is longer distance / private car / van / lorry and how would link roads between A21 and Tunbridge Wells cope with extra traffic unless it is rail that is being suggested here.
Paragraph 10 “Tenderers will need……” replace sentence with “Tenderers will need to indicate how they propose to address problems such as too much traffic accessing Tunbridge Wells……..” you should note Tunbridge Wells Borough Council’s objections at public inquiry in 1993 on the point particularly access via the A264 the local inquiry inspect mentions. Local plan policies TP10, and 11.
Paragraph 11 in the sentence “By this is meant that a decision would not be different, nor its justification significantly enhanced,……………” the wording “would not be different” – how will this be known if no greater detail has been analysed to justify a case. “Justification significantly enhanced” does not include the possibility of it being diminished.
Paragraph 14. “Travel demands will need…….” Travel demand is changing because of mode changes and the need for travel. This will make predicting for the next 30 years difficult. A cautious approach, that takes account of national and international targets and objectives for mode change should be taken. “Consultation/communication”
Paragraph 16 subparagraph 5. “Meaningful participation” – from whom? Subparagraph 6 – to whom? “Implementation Programme and Recommendations” Paragraph 21 Delete “in land use.” – are the local and county land use and transport plans to be open or not? They are currently under review at present and may remain so until at least summer next year. Any proposals could both affect and be affected by these plans. It is important not to build transport infrastructure to cater for possible future land use plans. This is in order to break the cycle of transportation opportunity creating unsustainable demand by firms re-locating, and resulting in yet again inadequate transport infrastructure. Alternatively new infrastructure not being used, wasting the expenditure and environmental degregation. “8. STUDY MANAGEMENT” Paragraph 30 first line “Working Group to assist” – who will be represented? See our comments in the covering letter.
Paragraph 31 “It will include representatives from a wide range of interests”. – How selected? “9.1 Data collection”
Paragraph 37 “The collection of demand……….” append “data should be reanalysed in context of the SACTRA report. Therefor data analysed using COBA9 for example, which in the case of the A21 at Castle Hill would justify any grandiose scheme such as an 18 lane road”. “9.3 Environmental issues”
Paragraph 45 “…………(e.g……) add “Archaeological Sites” – the area Castle Hill is a Bronze/Iron age settlement surrounded with accent woodland very little study work has been done in this area. This also has a bearing on the local and county strategic plans which are under review. – these studies are therefor essential. English Heritage state that the scheduled monument site map is inadequate and the site must be rescheduled. (Enclosed Western Area Planing subcommittee pages) “9.4 Appraisal” We support
Paragraph 48 “These are as follows” All dot points “9.5 Communication/consultation”
Paragraph 50 “The consultants shall…………” append “The project manager should be aware of political opposition to the Labour Government proposals being expressed in support for road schemes where scepticism had been the case six years ago towards the same schemes” “Report on Options Appraisal”
Paragraph 59 “Consultants will…….” append “should be aware that land use plans do not necessarily take account of Archaeological and Natural environmental aspects that have not been studied. Studies of these aspects should be conducted in order for the multi-modal study to take account of these aspects in proposals it makes”. Hence the need for experts in these fields.