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. Much of the following discussion is with reference to this road scheme. I am currently a member of a discussion group called “Stop The Road” set-up to oppose the “A21 Pembury bypass to Tonbridge Bypass dualling”. People who have attended this group will be sending in separate submissions. The group STOP THE ROAD meets in High Brooms, Tunbridge Wells, and people who have attended meetings include people from the vicinity who have voiced the concern for many years (10) about traffic, the need for road crossings, and busses. ** Items or amendments not submitted to the DETR. It has been noticed that in Volume 2 of the Roads Review that the standard for this road (page 81) is D2, dual 2 lane (four lanes) but the public inquiry approved only a dual three lane trunk road (six lane). Any such change would surely require a new public inquiry because a key part of the case has changed. My view is that this scheme that had two years ago been depriorities to 2 should now be deleted from the roads programme. The road review and integrated transport policy consultation are difficult to address separately, in anycase roads should be integrated not a special case. Therefore this response is an integrated response dealing with aspects of both documents. I have made some comments on the Integrated Transportation Strategy, (appendix 3).
1) See appendix (1) Alternatives **and (1b) TP 18. I support public
transport alternatives to the road such as, Rail, and freight to rail,
and frequent busses. But oppose future technical fix solutions such as
cars will get environmentally cleaner because they won’t relative to
other
modes of transport. - Manufacturers of cars have to juggle parameters
such
as engine flame temperature, which if high burns nitrogen and produces
NO emissions, but the engine has a lower fuel consumption. If the
engine
flame temperature is lowered NO emissions are minimised but unburned
hydrocarbons
are emitted. If the engine flame is too fast this causes engine damage
through knocking, and the fuel octane requires increasing, the flame
also
continues too long and causes valve burning damage to the engine. High
octane fuels that minimise these problems either contain lead or
alternatively
very high octane non oil based fuel such as ethanol used in racing cars
is not available. If you do all these things, reduce speed limits to
50MPH
and optimise the engine for 50MPH not 100MPH that most cars are
optimised
for perhaps you would double fuel efficiency. Town Busses are already
optimised
for 30MPH and carry more people. Trains run on lines without
bottlenecks
and fast sections like roads and carry lot’s of people you will never
match
either of those with a private car.
- Rail sidings are being considered by Railtrack at North Farm
Industrial
Estate where the main rail line passes beside. This site could provide
additional local car parking for rail users. (Appendix 1a)
- Reopen rail line to Brighton, and the line north of Summer Hill
tunnel,
between Tunbridge Wells and Tonbridge to Paddock Wood and Ashford.
Thereby
creating links cross country Brighton or Hastings via Tunbridge Wells
to
Ashford or Gatwick. These links could use the available capacity on the
rail outside London during peek times, to create new services. -
Traffic
calming measures on the existing sections of trunk road At Castle Hill
section of the A21 add an Additional crawler lane and road realignment
to the existing road. Crash rail in front of the houses where an
accident
occurred 2/10/97, this was at one of two houses close to the road and
was
an isolated incident, and is not on the bend said by the DoT to be
substandard.
- Better regulation of commercial traffic driving and working hours, to
minimise accidents due to tiredness and speed.
- There is another proposal that would address the substandard road
bends admitted to by the DoT in the published scheme this proposal is
to
tunnel through Castle Hill. I don’t approve of this option because of
the
visibility, environmental and archaeological impact, though this
proposal
has the benefit over the approved scheme of not being six lanes, or
have
a new substandard bend.
- I am not generally opposed to bypasses for local needs though I would
be concerned that village businesses would loose trade. Such bypasses
must
not attract more traffic, speed, noise, etc. to other people. They
should
incorporated with traffic calming measures on old roads to minimise
rat-running.
- I am opposed to Park and Ride this is out of town parking for car
users and takes passengers away from public transport. (See appendix
1c,
E Parkinson on Park and Ride) I hear that in Singapore a city bus or
car
licensing system was introduced in 1974, in addition car parking at the
city edge was built. In 1975 traffic fell in the city to a third and
has
not increased greatly since. The car parking was scrapped in a few
years
after 1975 because the busses were needed for public transport the car
parks had been little used. What had happened was that people were
using
busses for the whole journey. I have no reference for this example,
though
I heard it at an “A27 action group” meeting in Lewes, East Sussex.
2) Appendix (2) Criticism of COBA and other computer models
- The computer model in this case 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.
This
is ridicules it seems COBA will justify any grandiose road scheme.
- Mr Mainhood who has agreed that members of STOP THE ROAD using his
criticism of COBA.
3) Appendix (3) Response to Integrated Transport Strategy.
4) Appendix (4) Local Councils Position
- I support much of the Tunbridge Wells Borough Council position of
1992. I agree that more traffic could be attracted to Longfield Road,
and
Pembury Road then through residential areas and in to the town. I also
agree with their disapproval of the published route. You will see that
appendix (1b) that there are strong policies in the local plan
presuming
against additional traffic in the town centre. The alternatives the
borough
suggested that was still a road capacity increase on this section of
road
I find inconsistent and oppose to it. I am opposed to what may be
presented
as Tunbridge Wells Borough Councils position as of this month. It is
not
clear what they want. If they want more traffic do they want it in the
town centre I presume yes, and do they still oppose the published route
but want more capacity, I don’t know. In anycase none of what they are
saying will have been approved by council by the 14 November when the
DETR
should have received their submission. Their submission should be taken
as the views of officers only.
- I am pleased to see that Tonbridge and Malling Council’s position
opposing the approved scheme has not changed. I strongly oppose the
suggestion
that the South coast should have to have more road traffic. The south
coast
surely needs rail particularly to the channel tunnel, that should be
solely
for rail. Its not for any person or authority to expect traffic on
there
patch to be shoved on to anothers. Other schemes; I am opposed to the
A228
which I presume is a road capacity increase (called bypassing) because
of extra traffic attracted to Tunbridge Wells.
5) Appendix (5) Traffic flow figures. - note though there is little
to compare against but figures stated at the public inquiry in 1993 and
figures for 1996 presented at a Government Office of the South East
meeting
in October by the DETR appear to show considerably less traffic now.
That
is ignoring predicted figures which again appear lower now
- In addition traffic on the A26 through Southborough is at capacity
I believe, therefore traffic cannot increase further. Traffic that use
this section of road and find that the journey time is unacceptably
long,
will do something else such as find alternative routes, move home, find
work nearer. In 1992/1993 when the DoT where pressed on the point that
if the section of A21 road were built traffic initially drops then
rises
again on the A26 and therefore there is no local benefit long term. The
DoT replied to this point by say Tonbridge and Malling and Tunbridge
Wells
Borough Councils had a plan to restrict traffic on the A26. I wrote to
Tunbridge Wells Borough Council and was told there were no such plans,
and I have seen none since. At the public inquiry I pressed the point
about
no local benefit to Southborough this time I was told traffic will
increase
to 40,000 per day if the new section of A21 were not built (appendix
5c).
I don’t believe it the road is at capacity. Because of both of these
reasons
I find the figures doubtful and in anycase strongly recommend that they
are discounted. The figures appear to be taken form a base of 1986,
presumably
when traffic flow figures were measured. Surely if 1986 is the year
when
traffic figures were measured then the whole justification for any road
scheme should be on those figures, as these figures are known. As I say
above the DoT in there description of a trunk road scheme usually
attempt
to give the impression of a local benefit, in this case a reduction of
traffic on the A26 in the opening year. Overall there would be more
traffic
on other roads and a subsequent rise in traffic back to previous levels
on the A26. This is dishonest particularly as people locally are hoping
for traffic and accident rate reductions. The DoT admit that bends in
there
published route are substandard, but also justify de-trunking the old
road
because of a substandard bend. No mention was made of the accident rate
anticipated in the two lane bottle neck 4 miles south, or residential
areas
that would also carry doubling of traffic. At the 1993 public inquiry
it
was said by the DoT that this would be the only section of 6 lane road
and they knew of no plans to make any other section of this trunk road
6 lane (DoT speak for not telling you). I would prefer more openness **
Appendix (1b): The borough local plan contains policies that would turn
down planning applications which would lead to substantial extra
traffic
in the town centre via the A264 Pembury Road and other roads (TP10,
11).
Therefore there is conflict with the borough’s position likely to send
as its submission to the DETR of the A21 road capacity increase. This
increased
road capacity would cause more traffic on the A264. The DoT used the
previous
local plan that contained policies to use the Pembury Road as the main
rout to the town centre to justify more traffic on this road. This
policy
does not exist in the current local plan. For a detailed criticism of
the
“A21 Tonbridge bypass to Pembury bypass Dualling” refer to the letter
of
10 June to Gavin Strang MP from myself and Cllr Val Catt. Nightingales
discussed in the Environmental Assessment have been heard last spring
this
spring, and every spring. Part of the wood was cleared four years ago
since
then more Nightingales have been heard with each year. Costs
a) Threat to economic development caused by interests in the DoT for roads undue influence over policy of the DoE. Now formally acknowledged in the combining of the two departments. These departments should work together to protect the environment not conspire to build roads. I understand that there is a Highways directive to Kent County Council from government passed on to Tunbridge Wells Borough Council limiting development of the industrial estate until the A21 trunk road is built. I have no title for this directive that became apparent about the time of the announcement of the DoT DoE roads review. Planning consent was turned down for a company moving from one to another premises on the industrial estate that wanted permission to let their existing premises.
b) The AA and RAC have said that Roads cost £50bn a year and there is an income of £16bn therefore a net drain on the economy.
c) It can be said that roads bring in trade and personal communication, but roads also take trade away.
d) Costs and casualties that lead to break downs in communication such as road rage.
e) Cost of Policing car related and road related crime. There would
be a saving if speed pressure points on trunk roads and traffic calming
measures taken to change discourage aggressive driving.
- this resource should be switched to sensitive community policing
much regarded by the rest of the world but know not so apparent.
- enforce road policing to control speed, driving times and distances
to below regulation levels to improve safety.
- in some cases de-trunking, lane closure, and traffic calming on
villages
bypassed, such as the Pembury bypass would reduce noise and a speed
pressure
point.
f) Cost to the health service due to car injuries, could be switched
to better quality of care with stimulation as opposed to crisis care
solely.
- It has been said locally that the government should finance both
a new local hospital and a new 6 lane dualling of Castle Hill, thereby
apparently linking the issue of roads speed and casualties. Instead
measures
to reduce speed pressure points will allow savings in health care, as
well
as saving in fuel costs by this speed reduction.
g) Road building weakens the case for public transport therefore forcing people to drive or not to travel. This therefore cause public transport to be cut.
h) Other car encouragement measures at the expense of public
transport
such as park & ride are: - by there subsidy attracting people away
from public transport, and therefore causing residential traffic due to
residential driving to out of town parking for the cheap bus instead of
walking to the bus stop.
- At least the subsidy should be stopped.
- Causing extra traffic possibly 30% more to towns, by allowing
additional
out of town parking: - Out of town car parking and other development
should
be discourage, in this case because of CO2 creation.
- Alternative to Park & Ride is a distributed form where car
parking
in villages can feed and revitalise village shops and community as well
as feed public transport to the towns. This would allow those away from
villages to come in to there nearby village and connect with public
transport.
- In essence no stick but no more carrots for road vehicle users
either.
The more traffic on roads will be there own stick if no more roads were
built.
- also remove carrots such as company car allowances. And the cost
of road usage to reflect all the costs environmental, economic, and the
cost of past and present road building.
i) The Laundering of protected Green land to build roads on and the creation by de-trunking of brown land for building on. - I am concerned that this trunk roads on an ANOB will allow development on brown land when released. At the inquiry in to the Tunbridge Wells borough local plan in 1994 a company Knights Park asked for zoning for houses on the old A21 route (inspectors report 13.24.2). There has been a planning application for a motorway style service area at Castle Hill. These are unacceptable costs they weigh strongly against personal power and choice assumed benefits of car ownership.
Andrew Lohmann Southborough Town Councillor,
11, 13, 17, 21 November 1997
25, Andrew Road, Southborough, Tunbridge Wells, Kent, TN4 9DN.
Tel. 01892 542471 (home)
E-MAIL: AndrewHLohmann@compuserve.com
(1a) Rail Alternative & (1b) Tunbridge Wells Borough Local Plan
(1c) Response critisim of park and ride
(2a) Criticism of COBA public inquiry
(3) Developing an Intergrated Transport Policy response
(5a) (5b) (5c) (5d) Traffic Figures
Last changed 02-07-01, 06-01-04