Eastleigh Local Plan Examination

Twyford Parish Council

Responses to Inspectors Questions October 2019

By Chris Corcoran MA Dip TP MRTPI as Twyford Parish Councillor

Matter 2 Question 2.5 Does the SA consider all likely effects on the environment, together with economic and social factors.

1. Introduction Twyford Parish Council (TPC ) has put in a full statement which explains its objections and statement in mid 2018 took full account of the evidence then available. It • Objected on the grounds that the SEA was incomplete in respect of the impacts on Twyford • Objected to the S5 S6 policies for a Strategic Growth Area at Bishopstoke and Fair Oak on the basis that the plan took inadequate account • Proposed amendments to the EBLP if the S5 S6 policies are adopted.

TPC has now had the benefit of the additional documents submitted since June 2018. These include the • proposed changes of July 2019 SD33 • the Statement of Common Ground (SoCG) by South Downs National Park Authority (SDNPA) in October 2019; ( SDNPA is the Planning Authority for Twyford) • the SoCG of City Council (WCC) (WCC is Twyford’s Local Authority in many other respects as well as that of with which Twyford has close links and many common interests, for instance the traffic on B3335)

TPC’s view is that

1. The SA is still incomplete in its assessment of the SDNP and of Twyford in particular. see...... Matter 2 Question 2.5 Does the SA considers all likely effects on the environment, together with economic and social factors? 2. Harm caused to Twyford as a village in a National Park is contrary both to NPPF and the statutory purposes of the SDNP. S5 and S6 will cause harm to Twyford in various ways for which no or inadequate mitigation is proposed. In addition there appear to be risks that the link road will not be completed or will be completed late , the consequences for which will be unacceptable on Twyford. Matter 5 Q 5.14; 5.17 ; 5.24 3. The proposed Modifications in ED 33 especially of Para 4.30 take are insufficient . Matter 5 Q 5.11 ; 5.17

TPC’s Neighbourhood Plan is still in preparation and should be at Pre-Submission stage by the time of the hearings. This has been prepared in close cooperation with the SDNPA. It identifies first the special qualities which justify the inclusion of the whole Parish of Twyford within the SDNP and proposes both protection and enhancement measures. It further identifies the multiple environmental challenges faced by the parish, of which the exceptionally heavy use of B3335 and the multiple urban developments in the vicinity are two.

Twyford PC has found that it has been hampered in its responses by the extended period between pre submission the Examination, by the late papers for instances, the responses to objection of Sept 2019, by late and partial Statements of Common Ground and by the absence of agreed evidence on certain topics.

Twyford Parish Council is a supporter of the ADD group, has contributed to it financially and relies on the ADD evidence for the major objection to S5 and S6.

1. Does the SA consider all likely effects on the environment, together with economic and social factors?

While it is clear that the Allbrook link road will provide additional capacity and an alternative to B3335 to access the M3 and Winchester, there are following effects to consider: a. The predicted small reduction in vehicle numbers on B3335 through Twyford see TRA 1 and 2; b. The increased use by HGV’s unable to use the Allbrook Rail Bridge c. Increased use by busses because of height restriction and demand for public transport from SGO to Winchester d. Increased cycle use e. Increased use in the period before the link road is complete, including the period of construction and the potential for delay. f. Access to Shawford Station via B3335 and the Shawford Road and parking g. Consequential effects on Shawford Road and Hazeley Road

Of these , it appears that only (a) has been considered. As the finished scheme predicts a small reduction in the level of usage through Twyford, no mitigation is proposed. However the following should also be considered: a. The predicted reduction is dependent on assumptions the behaviour of motorists preferring the longer route to M3 via the Allbrook link, and the likelihood of congestion and delay on both the Allbrook link junctions up to M3 and on M3 itself . see Note 3 below The figures used in the EBLP for the Motorway flows appear lower than DTp /Highways Agency in their figures for M3 Smart Motorway upgrade ,programmed for next year (see Note 1 below for link and numbers ). b. See Note 2 below. The numbers of HGV’s is likely to increase during the construction period and then as a result of the S5 commercial development of 30,000 m sq for which the shortest route north is via B3335. HGV’s of this size are more likely to travel at non working hours when the roads are quieter c. More busses: there are bus routes using double deckers for which the Allbrook bridge is inadequate and the Allbrook link is not on the desire route; public transport demand to the north is likely to increase...see below d. The B3335 through Twyford is already a busy cycle route; the demand is primarily a commuting one as the residents from the settlements south of Winchester ride into work in the city. Winchester itself has been a more dynamic employment centre than Eastleigh in recent years. This is likely to continue See comments under issue 5 below. e. Increased use until the link road is open. The delivery of the link road appears to be a continuing uncertainty. If the SGO is commenced the B3335 becomes its principle link to the M=way system via jnct 11 and to WCC one its principle employment centres. Construction traffic is one factor. The more development takes place before the link road the greater the consequences for B3335. As the B3335 is already near capacity, the delays for all users will increase. There is no Plan B. So the potential consequences of both delay and failure must be assessed. f. Use of Shawford Station. Shawford Station is highly attractive to commuters as it provides hourly direct main line service to Waterloo, more in peak hours. It is accessed via Twyford (B3335 and Shawford Road) and will be used by SGO residents. g. Both Hazeley road and Shawford road are heavily used roads through Twyford linking to main roads, M-Way junctions and other settlements including Winchester. Both go through the village and SDNP and are substandard. They will also attract SGO residents .

A further issue discussed more below is the degree to which the SGO will be self contained in employment terms. I am not aware of any evidence that such self containment is achievable and there is plenty of evidence to the contrary. The likelihood is that new residents will continue to commute out of the area in much the same way that the residents of fair oak and Bishopstoke do now. One consequence is the increased demand for access to Winchester for work. It is not clear that this possibility is properly recognised or assessed in the SEA.

In summary, the SGO has a range of potential impacts on Twyford , of varying type and severity. Some are certain, some less so. In the short term ( for several years all access from the north will pass through Twyford with major conflict between users of the highway (cars/ busses/cyclists and Twyford residents).

These effects do not seem to have been properly identified or assessed or mitigated.

The mitigation proposed by the Modification of para 4.30 is addressed below.

The SEA is therefore deficient .

Note1. "Re-routing of Overly Large HGVs 2.4 The existing section of Highbridge Road would also serve as a redirection route for overly-large HGVs that are unable to navigate under the (improved clearance) Allbrook Rail Bridge). This would be achieved through a one-way route at the rear of the turning head (supported by associated signage and Traffic Regulation Order (TRO)). This arrangement is demonstrated within Appendix A, which also shows tracking manoeuvres for an articulated vehicle re-routing back to the northern end of Highbridge Road through the new T-junction access. Given the improved clearances and number of HGVs using this route on a daily basis (further details within Paul Basham Associates Allbrook Appraisal and Systra’s Local Plan Transport Assessment), this re-route arrangement is not anticipated to be used on a regular basis but acts as a mitigation route improvement over the current arrangement. 2.5 This re-routing arrangement will be supported through the use of early warning systems, as outlined within the submitted Allbrook Appraisal, including additional/improved advanced warning signage, infra-red sensors and physical systems on the bridge itself. This arrangement will not only mitigate against potential impacts of the SGO but also provide improvement over an existing constraint for existing HGVs attempting to travel along this route. "

Note 2.

The Highways report accessed by this link https://highwaysengland.co.uk/projects/m3- junctions-9-to-14-smart-motorway/ refers to the traffic on the M3 growing towards 2036. The EBC studies do not show the same level of growth: "This route is heavily used by cars and freight, and faces congestion during peak travel hours caused by the volume of traffic using the network. In 2036, this section of the M3 (junction 9 to 14) is forecast to carry an average of between 63,000 and 86,000 vehicles per day, which is an increase of 20,000 vehicles compared 2015." I.e. between 1/4 and 1/3 increase.

Note 3: Note to Chris Corcoran:

Most of the information is in two Systra Reports produced in April and May 2018. Transport and Highways Assessment TRA001 and TRA002.

TRA002 is a more detailed consideration of the Preferred option and you need to look at pages 111-115, i.e. Para 7.2.15 - 7.2.25. . This includes a couple of diagrams showing traffic flows and flow changes in Twyford, CC, , . There are some big gaps (like between Fishers Pond - Twyford Moors) and any flows on the new Link Road. . Note the comment in the text in this report at Para 1.6.4.

1.6.4 The B3335 corridor through Twyford will be approaching capacity in all test scenarios, with other sections of the corridor operating within capacity. Local Plan growth does not trigger any significant impacts.

Also note that the numbers are pcu (passenger car units) which will be about 10-12% higher than "vehicles".

TRA001 ( i.e. vol 1 from Systra) considers all the 6 (?) options they looked at for the LP. Basically DS2 and DS3 are the ones with all the Bishopstoke + Fair Oak housing with DS3 including more infrastructure improvements. Figures 41 and 42 these rather muddled figures show the flow differences on various roads around Twyford /CC / Owslebury etc. . These seem to be consistent with the numbers set out in the TRA002 . These figures show that Twyford should have a reduction in traffic when the Link Road is complete but that is predicated on the traffic travelling to Junction 13 of the M3 (Allbrook) and then using the M3 - which is already at walking pace in the AM peak. These two diagrams show the traffic on the new Link Road as 938 + 196 in the AM peak and 534 + 398 in the PM peak ( obviously the "existing" is zero so all this traffic is a difference). These flows of around 1000 vehicle per hour in the two peaks are significant as prior to the completion of the Link Road the traffic will have to use existing roads.

The timing of the Link Road is critical , as no doubt the developers will argue that building 15%/ 25% /35% / 40% of the new housing can be accommodated without the link road. Possible costing £42m