John Payne C.Eng MICE Transport Planner

John Payne C.Eng MICE Transport Planner 3 Ardenlee Drive,Maidstone,Kent ME14 5LU Tel 01622 758049 e-mail :- [email protected]

CANTERBURY DISTRICT TRANSPORT STRATEGY 2014-2031

Submission to the Public Inquiry Hearing

1 Introduction

1.1 This submission is made to reflect the concerns and views of the Campaign to Protect Rural England (CPRE) and the Herne and Broomfield Parish Council on the Canterbury Transport Strategy and its use as a basis to advise the preparation of the Canterbury Local Plan.

1.2 It is not possible within the resources of these organisations to deal with all the issues relating to Transport Strategy nor would it assist this hearing to reiterate the detailed comments already made at the draft stages of these documents. It is therefore proposed to take as read the detailed submissions already made by the Parish Council and CPRE and then to draw particular points from these to address the key issues, answer the questions subsequently raised by the Inspector following the Pre-Inquiry meeting and address the implications of more recent documents.

1.3 The earlier comments are attached as Appendix A (Parish Council) and Appendix B (CPRE)

2 Appropriateness and suitability of the Transport Strategy together with delivery of identified infrastructure needs

2.1 These issues are at the heart of the role of the Transport Strategy in advising the Local Plan and very real concerns over its fitness for purpose are central to the views expressed in this statement.

2.1 The Inspector has raised them in his questions under "Matter 5: Infrastructure and Implementation". The main issue is:-

"Whether the infrastructure requirements for the Local Plan are soundly based and deliverable and whether there are clear mechanisms for implementation and monitoring?"

2.3 In relation to Transport, these points are detailed in the two questions:- " e) Does the Canterbury District Transport Strategy 2014-31 provide an appropriate basis for the Local Plan?

f) Have the overall transport implications of the Local Plan been adequately assessed and will the identified infrastructure requirements be effective in addressing those impacts? Is it clear how the infrastructure will be delivered?

2.4 It is my submission that the answer to both these questions is a firm "NO" and I set out the reasons in the following sections.

3 Problems from the outset

3.1 At the very start of the Strategy, the Canterbury Council accepts that the current funding environment is challenging and states :-

" therefore, although it is important to maintain a level of realism over what might be delivered by 2031, a strategy that is constrained by known funding will not provide the evidence base to support future funding and investment opportunities."

3.2 It goes on to present an ambitious strategy but one which can only be assumed to be based on unknown funding. This is not considered a sound basis for the strategy.

3.3 With the recent announcements from Government of their support for a Northern Hub to take the pressure off London and the South East it can only be assumed that available funding will increasingly be diverted away from areas such as Canterbury.

4 Main strands of the Transport Strategy

4.1 Four key strands are identified:-

(1) Encouraging sustainable travel

(2) Car parking strategy

(3) Managing the network

(4) Reducing demand for travel

4.2 A whole series of ideas are set out for these strands and the main concern has to be how realistic will these ideas be in achieving the aims. Many brave words are used but there has to be concern that words alone cannot bring about success and each of these strands is now examined.

4.3 The ideas mentioned above are incorporated into a series of schemes and policies built into the proposed transport system to serve the developments promoted in the Local Plan and it is this new system which is tested by the Visum Transport Model. 5 Encouraging sustainable transport

5.1 In the Preferred Option Testing Report, it is made clear that the Visum Model does not model specifically the walking and cycling modes of travel. Para 2.2.3 of this report states that a higher proportion of walking and cycle trips have been assumed from the new development areas in order to reduce those made by car though no justification is given.

5.2 Even with such assumptions, the testing reveals the fragility of the local transport system and the concern of the modellers is clear from the summary which states :-

"..... it is realistic to assume that additional sustainable transport measures, over and above those tested in the model will be required to address future network pressures."

5.3 It is such concerned words by skilled professionals which highlight the concerns of CPRE and Herne and Broomfield Parish Council.

5.4 Similar concerns are expressed in relation to potential shifting of modes of travel. For example the Visum report in para 5.4 states :-

"The model outputs demonstrate relatively modest modal shift to public transport and indicate that the package of measures proposed in the Do Something, while providing benefits, will be offset by the overall increase in car demand. Additional measures are likely to be required...... "

6 Car parking strategy

6.1 A key element in the parking strategy is that of reducing the number of spaces in the city centre and raising charge rates to influence travel choice.

6 2 CPRE's earlier submission (Appendix B) stated that there was little evidence that elected Members will implement such measures against a strong lobby from the powerful business and tourism interests. Such concern is borne out by the Council's attitude on changing their draft strategy when, in their Addendum 1 - List of agreed changes they state;-

" reductions in city centre parking would only happen if there is clear evidence that there is adequate overall supply".

7 Managing the network

7.1 The fragility of Canterbury's highway network has already been mentioned and this is acknowledged in the Visum report which in para 3.1 states :-

"... future development would have significant impacts on an already constrained network. Any development strategy would therefore need to bring forward significant transportation improvements to assist with existing and future capacity issues." 7.2 It is considered that this is an important and fair comment therefore it is encouraging to see certain highway improvements being put forward. Such a way forward is supported but only provided that such schemes are suitable and are built at the appropriate stage. It is not acceptable to have inadequate schemes being delivered AFTER development as increased danger, delay and congestion will adversely affect all the population to various extents.

7.3 The crucial issue in such new projects is acceptability of schemes, state of preparation and deliverability, all these are explored later.

8 Reducing the demand to travel

8.1 The Strategy contains many ideas such as mixed developments where people live and work in close association but most of these are considered to be optimistic assumptions and this is graphically demonstrated by the comment in para 8.28 that even the city council cannot implement its own travel plan because:-

it is "hindered by the provision of ample and free parking for staff."

9 Summary of general comments on the Transport Strategy

9.1 It should be apparent from the above that there is considerable justification in the concerns expressed by CPRE and Herne and Broomfield Parish Council that the Transport Strategy is founded on an unreasonable assumption of available funds, greater amounts of sustainable travel are needed, car parking assumptions are already being diluted, new transport projects are described but deliverability is questioned and essential reductions in travel sought by the Visum modellers are unlikely to be achieved.

9.2 It is for these reasons that this submission considers that the answer to the Inspector's question e) is that the Strategy does not provide an adequate basis for the Local Plan.

10 Transport improvements

10.1 The Strategy identifies a number of new schemes that are needed to support the development proposals and, in principle, these are all supported in this submission. However the Inspector asks specifically if they will be effective in addressing the impacts of the development and how they will be delivered. These are considered to be the key issues in the whole Transport Strategy/Local Plan process.

10.2 The Inspector also asks in his question l) if the improvements to the highway network are justified and deliverable:

o Whincheap Traffic management Scheme

o A2 Bridge Interchange

o Herne Relief Road

o Sturry Relief Road o A28/A257 Barracks Link Road

11 Effectiveness of the proposed schemes

11.1 Whilst the principle of these schemes is supported, their specific effectiveness cannot be judged as these are little more than at a conceptual stage.

11.2 This concern is shared by the Visum modellers who state in para 3.8:-

" It is recognised that a number of the key infrastructure improvements are still are still at the high level conceptual stage and details of capacity, junction arrangements and physical alignment are currently unknown. While various design assumptions have been made, it is recommended that any significant scheme eg Sturry and Wincheap relief Roads, are subject to more detailed assessment".

11.3 At this stage the focus is put on two schemes of great importance and relevance to this submission - Sturry relief road and Herne relief road - and are good examples of the concerns. These are particularly important because some 85% of all strategic housing and commercial development in the District are planned to be built in a narrow corridor running from SE Canterbury up towards Hillsborough. Thus the major traffic impact will be felt in one particular sector and one within which these two schemes are mentioned. Thus their suitability and timely delivery is crucial.

Sturry Relief Road

11.4 This scheme is to relieve a notorious traffic bottleneck and it is considered essential before any new development is built in any area to the north and east. This is clearly a crucial issue to the Council who published a "Position Statement" dated May 2015 (attached as Appendix C).

11.5 This document has no reference or author but it does state that the constraint of the highway system:-

"... was stated by KCC Highways officers at the last local plan Inquiry in 2004 and the situation has not changed: in fact with the background growth it has been exacerbated. At that time, KCC stated that no additional strategic sites should be located north of the level crossing..."

11.6 This view is fully supported in this submission but it is noted that the Position Statement now states:-

" It is understood that some enabling development would be needed to take place to allow this improvement to be delivered".

It goes on to mention a figure of 650 new houses and this is considered to be totally unacceptable in this submission. 11.7 The Position Statement also says:-

that this "increase could be acceptable providing certainty of the delivering of the link road".

However, later in the Statement it says:-

"If the Sturry link road does not proceed then other dependant sites cannot be commenced".

This raises doubt over the provision of the road and reveals a sorry and confused situation which is considered to be unacceptable.

11.8 Furthermore, the Position Statement says that the 650 houses:-

"will only be acceptable as a package, to run in parallel with the construction of the link road between Sturry Hill and the A28.."

Surely this is all part of the one scheme and it is a situation that needs urgently to be clarified.

11.9 When clarification was sought from KCC it brought the reply:-

"This scheme is to deliver a new road linking the A291 and A28, including structures over the railway line and the river. The new road will be 2 way single carriageway and include a westbound bus lane and a shared footway/cycleway. We are in the very early design stages and still considering route options so I am afraid that I can't provide a layout at this stage; the aim is to be in a position to consult on proposals in summer 2016".

11.10 There is no argument with this statement, but it does explain why it is not possible at this stage to comment on the detailed effectiveness of the scheme.

Herne relief road

11.11 There is similar lack of clarity over proposals for the Herne relief road. This is considered essential to "relieve the excessive traffic demand on constrained routes and improve capacity" as stated in the Visum report. Furthermore additional development sites are proposed to the north of the village which would add additional traffic through the village thus exposing local inhabitants to unacceptable increased danger and congestion, therefore the Parish Council is adamant that the new relief road is a fundamental need.

11.12 It is therefore disappointing to note that the Strategy in para 7.56 considers that it:-

"..is likely to mean that a relief road will be required".

Such a weak statement is not acceptable and shows a lack of understanding of the situation by the Canterbury Council.

11.13 Not only is there a lack of appreciation of conditions in the village but the Strategy in para 7.58 makes vague references to form the relief road might take. Again this leads to this submission not being able to comment on the effectiveness of the proposal which it is felt must include a new road for A291 of appropriate dimensions to provide a safe route from its junction at A299 right down to its rejoining the old route where Bullockstone Road currently joins A291.

11.14 Irrespective of the deficiencies in respect of the Sturry scheme, the Parish Council seeks a clear Position Statement from the local highway authority (KCC) in respect of the Herne relief road. It, and I am sure the Inspector, wishes to see what is proposed and how it will be funded and programmed so that definitive comments can be made.

12 Deliverablityof the proposed schemes

12.1 There are two main issues in relation to deliverability of schemes. There must be the required land to enable them to be built and this can only be achieved by agreement eg if the road is TOTALLY within the ownership of the proposed development or by Compulsory Purchase. This latter would necessitate an approved detailed scheme followed by a public inquiry and there is no guarantee that this would be successful.

12.2 Before any scheme can be considered there has to be certainty of TOTAL funding. It is no use stating that a particular project has a certain percentage of its cost in place if there is no source for the remaining money, even if this may seem to be a relatively small amount.

12.3 The earlier CPRE submission stated that the total cost of the schemes listed in the Strategy amounts to some £97.255m. and that submission went on in para16 to mention the KCC document "Growth without Gridlock" which has the subtitle "A transport delivery plan for Kent". It lists a total of £1.77bn worth of projects yet only 5.6% of this total is for "District-based road improvements" which is a tiny amount for all the schemes in all the local plans in Kent. It is important also to remember that Canterbury will be in competition with the defined growth areas in Thames Gateway (Kent), Ashford, Maidstone and Dover

12.4 A further source of funding has been identified in the Single Local Growth Fund (SLGF) but in the very recent allocation only £5.9m for the Sturry relief road was achieved. However, where will the remainder of the funding, over £20m, come from and when?

12.5 An additional concern is the lack of consistency over scheme estimates. Appendix B demonstrates large differences between the costs mentioned in the Strategy compared to the SLGF bid.

12.6 It is apparent that the delivery of the Canterbury Transport Strategy is very reliant on the private sector and, in my view, this makes it a very high risk strategy.

12.7 This is compounded by the fact that after 6 April 2015 local authorities will not be able to pool contributions from more than five different Section 106 agreements towards strategic infrastructure projects. The Government sees the future being delivery of new infrastructure under the Community Infrastructure Levy (CIL) regime. However, at the current time the Council has no programme for preparing a CIL charging schedule despite agreeing a new Local Development Scheme in May 2014. In any event, I note that paragraph 1.77 of the Local Plan suggests that there may be a ‘nil’ CIL on the strategic sites. All this leads me to the view that there is great uncertainty surrounding the Council’s ability to secure the necessary contributions towards new transport infrastructure. 12.8 It is considered essential that the Council produces a clear statement of its plans as to how it will be using the contributions from each site against each scheme. Only in this way can it be established that there is a funding regime that will work.

12.9 The contents of this section provide views on the Inspector's questions l) s) and u) and it is felt justify the concerns in this submission. It is hoped these assist the Inquiry.

13 Conclusions

13.1 In conclusion I would submit that the Transport Strategy is highly aspirational, inadequate in scheme cost accuracy, too reliant on private funding, lacking in detail of the proposed essential major schemes on which it depends and too risky in allowing too much development before scheme delivery. This is not an acceptable basis for CPRE and especially the Herne and Broomfield Parish Council who have a direct responsibility for existing local inhabitants and those new residents who will come to the area over the future years.

T J Payne C Eng MICE

Transport Planner

On behalf of CPRE and Herne and Broomfield Parish Council

June 2015