Durham Road Block ID: 1202726 Matter 6

Durham Road Block ID: 1202726

Submission to the Examination in Public of the Plan 2019

Matter 6. Transport Proposals for Durham City

M6(b) Promoting sustainable transport

The measures proposed within the Durham City Sustainable Transport Delivery Plan 2018/Policy 23 are weak, unspecified and at times, illogical.

• There is no strategy for increasing sustainable travel from satellite villages. • No detail is provided on the routes and standard of proposed cycle improvements. To be effective, cycle infrastructure must be convenient, direct and protected from traffic. • No improvements to public transport are proposed. • It is asserted that improvements to cycle networks depend upon displacement of traffic onto the WRR/NRR for lane reductions on the Milburngate Bridge. However: o Most potential cycle routes to the City do not cross the Milburngate Bridge. o Safe cycle links across the Wear in the City Centre already exist: Framwellgate Bridge/ Elvet Bridge and the Pennyferry Bridge. o Allocating space on the Milburngate Bridge for cycles would not make it an attractive route, due to the extremely hazardous roundabouts at either end. o Reallocation of highway space for sustainable transport does not require additional capacity elsewhere; congestion does not occur due to temporal or modal shift. This can also generate benefits including reductions in through traffic and increases in town centre visitor numbers.

We assert that DCC cannot admit that modal shift is possible, as it would undermine the (already very weak) case for the roads.

1 Cairns, S., Atkins, S., and Goodwin, P., (2002) Disappearing traffic: The story so far. Proceedings of the Institution of Civil Engineers, Municipal Engineer 151, March 2002 Issue 1, Pages 13-22

M6(c) Existing highway network problems

Severity of problems and trends in car use

Documents in this discussion:

• Durham City Model Rebase: Jacobs, 2016 - MR 2016 • Durham Local Plan Traffic Impacts Technical Appendix: Jacobs 2019 -TA2019 • County Durham Plan Appraisal Report: Jacobs, 2019 – AR2019 • County Durham Travel Patterns 2011 Census Data Analysis: Jacobs, 2018 – CDA2019

DRB are grateful to Dr Alistair Ford, Senior Lecturer, Geospatial Data, Newcastle University, for his assistance.

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Durham Road Block ID: 1202726 Matter 6

The justification for the WRR/NRR:

• does not evidence significant congestion at present or in 2037 • does not show that the NRR/WRR would greatly reduce congestion • contains significant methodological flaws which undermine its reliability • employs a predict-and-provide (PAP) methodology which is not fit for purpose. • 1) Inability to demonstrate benefits

As AR2019 shows, the highways network generally operates below capacity. In fact, vehicular numbers are decreasing: DfT daily vehicle data for Leazes Road/Milburngate Bridge shows that traffic reduced by 10% between 2018 and 2001 (42,469 and 37,902 movements respectively). The fact that 50% of peak-time journeys are discretionary shows that congestion is not a barrier to access.

There is very slight over-capacity peak times at a few junctions: junction 6 (Gilesgate) which has a PM peak of 103%; and junctions 7 (County Hall), 8 (Crossgate) and 9 (Milburngate), which have AM peaks of 103, 101 and 101% respectively.

Under the “Do Nothing” (DN) scenario, by 2037:

• Junctions 2, 3, 4 and 5 are below capacity, with some significant improvements. • Junction 6 is below capacity, due to improved signalisation (p24) • Over-capacity elsewhere is almost exactly the same as in 2015, with two exceptions: o Junction 1 (Sniperley Park) - a very slight AM peak of 101%. o Junction 7 (County Hall) - where current traffic patterns will not apply in 2037; County Hall is being replaced on another site with less parking.

Under the preferred “Scenario 4A” (the NRR/WRR), any improvements shown in 2022 have largely been lost:

• Junctions 1 and 7 are over capacity at the AM peak. • Junctions 2-6 are below capacity, as in DN. • Junctions 8 and 9 are at 99% and 97% respectively (102% and 104/2% under DN.) • Reductions in vehicular movements are small – nowhere more than a few hundred; only 52 at junction 8. • Time savings at junctions nowhere exceed 33 seconds (apart from at County Hall, which will no longer apply) • Eastbound journeys along the A690 are slower than in DN.

Presumably, since only very marginal capacity issues exist now or in the future, the additional highway space would make little difference. You can’t solve a problem that doesn’t exist.

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2) Methodological flaws

2i) Extrapolation

MR2016 states that, in 2015, journey data (vehicle type, origin, destination, purpose, occupancy) was collected at roadside interviews (RSIs). The RSI findings were then extrapolated to traffic count figures.

DRB do not accept that the extrapolation is justified, because of:

• insufficient numbers: TA2019 states (p13) that the number of interviews was 20. • lack of demographic information: we do not know whether the interviewees were representative of the population at large, or the working population. Even if they were representative today, extrapolation to 2037 is invalid, since significant demographic change is predicted. • Absence of data on the origin and destination of traffic on Milburngate Bridge.

2ii) Internal zone: definition of through traffic

MR2016 establishes an aggregated “internal zone” within the cordon of RSIs. Trips originating and ending outside it are deemed “through traffic”. It is claimed that 33-36% of journeys fall into this category and that this causes problems.

However, this includes much of the city: Mount Oswald, Carrville and Belmont, parts of Newton Hall, and all of Durham City’s major employment locations outside the City Centre: Belmont, Dragonville and Abbey Road/Arnison Centre.

2iii) Internal journeys: number and modal split

MR2016 discounts as insignificant the internal journeys which would not be recorded by any RSI; yet this would include movements from Whitesmocks, North End, Old Elvet and Claypath.

40.27% of commuting journeys from Durham City are by sustainable transport. This demonstrates that modal shift is unachievable. It also undermines the relevance of the assertion that the City has too much through traffic. Since many internal journeys are not made by car, this brings down the proportion of motorised journeys classed as internal.

Even according to MR2016, the vast majority (67%) of journeys have an origin, destination or both in the City.

The figure of “33-36% through trips” on which the strategy relies:

• Has been calculated through invalid means. • Would not demonstrate the road system is unfit for purpose, even if it were true.

2iv) Failure to consider alternative routes

DCC assert that no alternative routes exist for vehicles travelling from the west of the city to the A1). However, there are no larger settlements to the west of Durham without alternative routes to

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the A1 (via the A693 or A688). Since through trips do exist, therefore, congestion cannot be severe. This means drivers may not even use the new roads; they might avoid newly congested areas around relief roads by driving through town.

Some smaller settlements within 3 miles of the City Centre exist from which W-E journeys by another route would entail a detour; these villages, however, arguably operate as suburbs of the City.

2vi) Assumption of increased traffic

AR2019 calculates trip rates from planned (allocated and committed) housing sites and assumes (p7) “all the trips are car based” - although 40.27% of commuter journeys originating in the City are not.

Given the predicted demographic shift towards an ageing population, we question the validity of trip rates based on current demographics, applied to 2037.

Given the uncertainties in the housing market, the over-allocation of land across the County, and predicted demographic shifts, we question whether the proposed development will take place.

3) Invalidity of PAP.

The shortcomings of the PAP model of traffic management are well-known. Increasing road capacity stimulates traffic growth, thus negating congestion benefits (1) – particularly where benefits are marginal, as they are here. This also means greater carbon emissions and local air and noise pollution.

Recent research (2) adds:

• PAP predictions are not being met at present; typically, mileage, driving licences and vehicle ownership are decreasing among younger generations and in cities, and increasing among older people. The number of 17 to 25-year-olds taking the driving test has fallen by 18% over ten-year period; in 1993, 55% of 17 to 20-year-old males held a license; this is now 33%, even lower for women. • PAP gives a false sense of certainty in a highly uncertain context. Technological and social changes may have unpredictable effects.

Rather than PAP:

• Government should practice “decide-and-provide” traffic management, with traffic volumes as an outcome rather than an input. • Government should not equate traffic growth with economic growth. • The carbon implications of different scenarios should be calculated and published.

DCC’s proposals fail in every respect.

1) Bongardt, Daniel; Creutizig, Felix; Huging, Hanna; Sakamoto, Ko; Bakker, Stefan; Gota, Sudhir; Bohler-Baedeker, Susanne (2013). Low-carbon land transport policy handbook. Earthscan, Oxon.

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Durham Road Block ID: 1202726 Matter 6

2) Commission for Travel Demand (2018). All Change: The future of travel and the implications for policy and planning.

M6(f) Impact of the proposed northern and western relief roads

Constructing the two roads directly deprives communities of ‘accessible green infrastructure’ (Spatial Vision document). The Northern Relief Road (NRR) impacts directly and negatively on communities in Newton Hall, Brasside, , . Newton Hall and Brasside’s 8500 residents currently enjoy excellent access to the 30-acre Low Newton Junction Local Nature Reserve and adjoining SSSI, Brasside Pond. CDP’s preferred route for NRR ruinously intersects the railway path through Low Newton. It dangerously bisects the green bridleway Frankland Lane, containing native semi-natural woodland. This major heritage asset forms the ancient route taken by 10th century monks bringing St Cuthbert’s coffin to Durham. A popular walk, with stunning views of the Cathedral, it is officially recognized as part of Camino Ingles, directly connecting Durham with Santiago-de-Compostela. Frankland Lane also forms part of 74-mile Weardale Way. Clearly, the adverse impact of thundering traffic would be unbearable.

Low Newton reserve, as DCC’s own leaflet observes, “provides an excellent wildlife corridor on the edge of the East Coast Main Line and Newton Hall”, providing habitat for the nationally-rare dingy skipper butterfly; a European Protected Species, great crested newt; and birds including reed bunting (amber UK conservation status) and willow tit (red UK conservation status). Protected White Clawed crayfish are recorded at Brasside SSSI. Smooth newt, common frog and common toad – all Durham Biodiversity Action Plan species – subsist in Low Newton corridor and Brasside Pond. Both road routes impact adversely on habitat for otters and water voles, priority species in UK Biodiversity Action Plan.

CDP’s alternative NRR route crosses Grade 2 listed Belmont Viaduct and bisects Brasside Pond, a 62- acre wetland and woodland SSSI. NPPF (para 175) states: “development on land within or outside an SSSI, and which is likely to have an adverse effect on it [...] should not normally be permitted”.

Crossing the River Wear, the NRR impinges directly on Frankland and Kepier woods, an extensive area of ancient and semi-ancient oak woodland along the river. The 15,000 residents of Belmont, Carrville and Gilesgate Moor currently enjoy excellent access to Kepier Gorge, an idyllic and historic landscape. Any bridge works require a major building project, massively intrusive groundworks, and entail permanent despoilation of the gorge itself. DCC designates Kepier and Frankland Gorge as Areas of High Landscape Value, i.e. “attractive, mature and undeveloped landscapes”, assessed in the Landscape Impact for NRR “as being of high sensitivity to the effects of a new highway”.

NPPF (para 175) states that: “development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”; clearly, no such exists. Woodland cover is already low; Durham Wildlife Audit describes ancient woodlands as: “the most precious of all our woods, now occupying only 1.3% of the county”. As the Exceptional Circumstances document notes, ancient woodland is irreplaceable and it is impossible to compensate for its loss.

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In terms of heritage assets, NRR destroys important archaeological evidence in the Wear Gorge, including probably the most important mining history site in . We attach (Map 1) a map of known mining sites (National Coal Board archives), in fact just a small part of the available evidence. Graham Robson of Grange Iron Company restoration project documents important historical drift mine sites which are destroyed by NRR; see David Simpson’s book Durham City (ISBN 978 1 901888 50 8) pp. 133-4.

Various significant finds originate in an area known to locals as “The Sandy Beach”, e.g. Dave Shotten’s finds of 25 Roman coins, declared a horde by DCC Portable Antiquities Scheme (Receipt No. 268, 54.797.1260-15459609, 9.4.2018). Despite this being a possible River Wear crossing point for the Roman Cades Road, DCC’s Portable Antiquities scheme has failed to respond to historians’ requests to be allowed to investigate the area in detail.

Perhaps most remarkable is the re-discovery of a section of roadway in Moor House Woods, a putative coal and stone supply route for Finchale Abbey. Briefly investigated by DCC in 1963 and declared “probably medieval”, this area clearly requires extensive research, an opportunity lost forever if the NRR is built.

The Western Relief Road (WRR) impacts directly and negatively on communities including Bearpark, Broom Park, Crossgate Moor, Framwellgate Moor and Pity Me. The Browney Valley, including the historic Neville’s Cross Battlefield and medieval Beaurepaire estate are heritage assets. The route dissects two designated wildlife corridors. It crosses National Cycle Route 14, Lanchester Valley railway path, constituting a major threat to well-being for cyclists and walkers, plus loss of national amenity; Route 14 is a long-distance cycleway. A major viaduct over the Browney Valley is an evident blight and despoilation of peaceful green space. No one wants to walk or cycle alongside a polluting road full of thundering traffic!

The road corridor for the WRR is adjacent to four designated and protected local wildlife sites: Lower Browney Valley, Bearpark Bog, Baxter Wood and the Deerness Valley. Red squirrels, in decline across England, were recently recorded in the WRR corridor. There is an appreciable bat presence along the route, particularly Club Lane/River Browney; merely by increasing light pollution, the adverse effects are significant, impacting on bat commuting and foraging behaviours. River Wear is a major bat feeding and commuting route. The Ecological Assessment for NRR notes significant bat presence: “New roads are known to increase levels of bat mortality through direct impact fatality, [and] fragmentation of populations contributing to species decline”.

During and after construction, these new roads create noise pollution, air pollution, direct disruption to habitat and wildlife corridors, increased animal mortality visual disturbance and loss of green amenity. Simply the presence and speed of new traffic. The roads destroy not only significant semi- natural wildlife habitats, as noted above, but also disrupt, destroy or breach wildlife corridors, contrary to NPPF paras 174–177. These corridors increase biodiversity and prevent loss of genetic diversity (inbreeding) within existing animal populations, enabling vertebrates (mammals, amphibians) and invertebrates (insects) to cross between otherwise fragmented habitats, establish new populations and strengthen existing populations. Fragmentation of habitats into unsustainable

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small pockets is recognized as highly significant in loss of biodiversity.

The NPPF (para 133) states “The fundamental aim of Green Belt policy is to prevent urban sprawl; the essential characteristics of Green Belts are their openness and their permanence”. Para 136: “Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified”. No exceptional circumstances exist; CDP is inconsistent with national policy. Both roads impinge on the integrity of existing Green Belt and constitute an extension to the current boundaries of Durham City, permitting development into surrounding countryside. Large tracts of Green Belt become degraded, destroyed in character or removed entirely.

Benefits of access to green spaces include better mental and physical health, increases in exercise, reductions in stress, depression, and obesity. NPPF (para 96-97) emphasizes: “Access to a network of high-quality open spaces [...] is important for the health and well-being of communities”, and continues: “Existing open space [...] should not be built on”. CDP is therefore unsound, i.e. inconsistent with national policy. Regarding air quality, motor vehicles emit carbon monoxide, nitrogen oxides, and damaging particulates, causing serious adverse respiratory and cardiovascular problems. Even short exposure to diesel exhaust fumes at the typical concentrations found along such roads has deleterious effects on the cardiovascular system. Nitrogen oxides are seriously toxic for the respiratory and immune systems.

M6(g) Benefits of the proposed northern and western relief roads

Since there is no reliable evidence that the NRR/WRR would reduce congestion or traffic numbers, there is no evidence that they would deliver any benefits at all. It has been suggested that they would improve air quality; on which point, it should be noted that Durham figures neither in the list of the top 30 UK towns exceeding safe limits, nor in the list of top 17 UK towns at the limit (1).

It is sometimes argued that new roads yield economic benefits; but links re weak and contested (2). Over recent years, many cities have grown despite traffic reductions (3).

Meanwhile, there is strong evidence to show that every £1 spent on active travel infrastructure yields £13 in benefits (4).

1) https://www.bbc.co.uk/news/health-43964341

2) Melia, Steve (2018). Does road building boost the economy? The claim has never been proven. https://bettertransport.org.uk/blog/better-transport/does-road-building-boost-economy-claim-has-never-been- proven

3) Commission for Travel Demand (2018). All Change: The future of travel demand and the implications for policy and planning.

4) Transport for London (2018). Cycling and walking: the economic benefits.

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Durham Road Block ID: 1202726 Matter 6

M6(h) Green Belt and very special circumstances

Paragraph 146 of the NPPF states that local transport infrastructure in the Green Belt may only be classed as not inappropriate if it can: demonstrate a requirement for a Green Belt location

Durham Road Block contend that the Council have not undertaken sufficient investigations into sustainable alternatives to the creation of the Western & Northern Relief Roads (WRR & NRR) which would address the points they claim would outweigh the potential harm to the Green Belt. Neither road would provide sufficient benefit for allowing development in the Green Belt as would clearly outweigh the harm that would be done as laid out in Paragraph 144 of the NPPF relating to ‘very special circumstances’.

The Council’s four points in favour of the relief roads that they claim make their case:

• Reducing congestion • Facilitating sustainable development opportunities • Improving air quality • Removing traffic from Durham city centre to enable sustainable transport movements would all be achieved through the Durham City Sustainable Transport Delivery Plan if the Council was committed to deliver this. We further suggest that the statistics regarding commuting and through traffic that the Council is using to justify the relief roads are flawed and misrepresent the reality of traffic into and through the city as has been highlighted in the Durham Road Block statements on Matters 1 and 6.

It is in fact apparent that DCC are actively engaged in policies - both within and without the County Durham Plan – calculated to support their own agenda for these roads.

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