Group Response from the Princes Risborough Bypass Action Group (BANG) to the Princes Risborough Expansion Plan Consultation June – July 2019

Group response from the Princes Risborough Bypass ActioN Group (BANG) to the Princes Risborough Expansion Plan consultation June – July 2019

Contents

1 Introduction 1 2 Summary of BANG’s response to the consultation 2 3 Background 3 4 The SPD 3 5 BANG’s view on the consultation process 4 6 Safety 5 7 Air Quality 7 8 Noise 8 9 Statutory compensation 8 10 Impact on the character of the area 9 11 Loss of amenity 11 12 Community severance 11 13 Cost savings 11 14 Planning and transport policy 12 15 Errors and omissions in the consultation materials 14 16 Conclusion 16 Appendix 1 Additional information about the proposed changes to 18 Shootacre Lane and Picts Lane Appendix 2 Email from David Lidington MP 20 Appendix 3 Email from Carl Etholen, County Councillor 21 Appendix 4 BANG residents survey, December 2016 22 Appendix 5 BANG bat survey, 2016 24 Appendix 6 Media coverage by Mix 96 25 Appendix 7 Signatures of BANG members 29

1. Introduction This document sets out the response of the Princes Risborough Bypass ActioN Group (BANG) to the draft Princes Risborough Expansion Supplementary Planning Document (SPD) which was issued for consultation on 4 June 2019. Our comments primarily concern Shootacre Lane and Picts Lane and the delivery of the ‘Culverton Link’. These matters relate to multiple parts of the SPD but mainly to the Delivery Plan in Part 2 of Section 5. Whenever possible, we have indicated where comments relate to a specific section of the SPD or supporting documents.

BANG group response to the Princes Risborough Expansion Plan consultation

2. Summary of BANG’S response to the consultation BANG strongly objects to the use of Shootacre Lane and Picts Lane as interim relief road route. These lanes are unsuitable for this purpose and the additional traffic would make them unsafe. The key change we regard as necessary to the SPD is to bring the Culverton Link forward to Phase 1 of the Delivery Plan. We have commissioned a professional report from an independent transport consultancy which identifies a number of serious safety issues with the interim relief road proposal. The report we obtained from Carl Tonks Consulting Limited (cTc) dated 19 July 2019 (cTc Report) is attached to this response and it forms an integral part of our response. In preparing the report, cTc examined the SPD and the Phasing Tests and a two- person team spent a full day carrying out a detailed survey of Shootacre Lane and Picts Lane. Our key objections to the interim relief road proposal are summarised below. • SAFETY: Shootacre Lane and Picts Lane are not suitable for the additional traffic and this would endanger residents, cyclists, pedestrians and equestrians. • AIR & NOISE POLLUTION: There would be an unnecessary increase in air pollution and traffic noise for residents. This would also lead to claims for statutory compensation. • CHARACTER OF AREA: The increase in traffic, particularly HGVs, would harm the character of the area which is currently a tranquil, rural setting providing access to important countryside. Both lanes are bordered by Green Belt and Shootacre Lane is in the AONB. • LOSS OF AMENITY: The grassland area on the corner of Shootacre Lane and Picts Lane is used by residents and the wider community for dog-walking, strolling and community gatherings. The proposed alterations to the junction will significantly reduce the size of this green space, while the increase in traffic will make it less pleasant and attractive for these pursuits. • COMMUNITY SEVERANCE: The proposed alterations to the junction between Shootacre Lane and Picts Lane, together with the increase in traffic and lack of pedestrian footpaths and crossings, will create a barrier effect, discouraging journeys on foot or by bicycle. Further comments relate to: • COST: Spending £376,000 on an inadequate temporary measure is a waste of public money and creates more infrastructure than is necessary. • POLICY: The proposals conflict with key elements of planning and transport policy. There is a simple solution which avoids all of the above problems: build the Culverton Link at Phase 1 of the Delivery Plan.

BANG group response to the Princes Risborough Expansion Plan consultation

We have petitioned David Lidington MP who has written to WDC in support of our position. His email to WDC dated 18 July 2019 is attached (see Appendix 2). Buckinghamshire County Councillor Carl Etholen has also written a letter of support (see Appendix 3).

3. Background BANG is a residents group representing 129 individuals from 70 households on Shootacre Lane, Picts Lane, Horsenden Lane and Bledlow Road in Princes Risborough. The names, addresses and signatures of our members are attached (see Appendix 7). BANG was formed in March 2016 following the publication of the draft Princes Risborough Town Plan by Wycombe District Council (WDC). The draft Local Plan outlined plans for major expansion of the town and considered a number of options for the route of a new relief road, including Shootacre Lane and Picts Lane. Following representations from BANG, WDC commissioned further work1 and decided that the best option for the relief road would be to build a new section of road linking the A4010 to Picts Lane - the ‘Culverton Link’. This would mean no significant additional traffic would travel along Shootacre Lane and Picts Lane. The Culverton Link is shown in the October 2017 publication version of the Local Plan.

4. The SPD In June 2019, WDC issued the SPD for consultation. This was accompanied by a report dated 28 May 2019 ‘Princes Risborough Phasing Tests’ (Phasing Tests), prepared by Jacobs for Transport for Buckinghamshire. The SPD proposes that Shootacre Lane and Picts Lane will act as an interim relief road route for accessing the Princes Risborough expansion area, until such time as the Culverton Link is built. The key elements of the interim relief road proposal are that: • £376,0002 is spent initially on “interim safety improvements to Shootacre Lane”3 – these include (a) widening the arc of the junction of Shootacre Lane and Picts Lane; and (b) closing the junction of the A4010 and Upper Icknield Way.4 • Significant additional traffic is then expected to travel down Shootacre Lane and Picts Lane – for example the AM Peak hour traffic along Shootacre Lane is forecast to increase by 6717% (para 4.7, cTc Report). There will also be construction traffic to the expansion area, over and above the traffic above.

1 Report by DRF Consulting “Princes Risborough Feasibility Review of Southern Alternatives” dated 4 September 2017 2 SPD, Appendix 4 3 SPD, p.174 4 The SPD does not specify what the improvements are - the details were only established after BANG requested this information from WDC during the consultation.

BANG group response to the Princes Risborough Expansion Plan consultation

• Shootacre Lane and Picts Lane will continue to be used as the interim relief road until 1,100 houses have been built – this could be 2033 or beyond. • Once 1,100 homes have been built, the Culverton Link will be built and it will become the main relief route. Shootacre Lane and Picts Lane are then forecast by the Phasing Tests to revert to carrying local traffic only.

5. BANG’S view on the consultation process The SPD contains no detailed information about the proposed changes to Shootacre Lane and Picts Lane. Some more detail was provided eventually, but this was only after we arranged a meeting during the consultation period and specifically requested that information. The additional diagrams and maps we were given are included in Appendix 1. We would like to register strong disapproval about the lack of detail that has been provided in relation to Shootacre Lane and Picts Lane and communicate that our members feel that WDC has not been sufficiently open about its plans. This has hampered our ability to respond effectively to the consultation and hampered the ability of our traffic consultant to comment. Legality of consultation BANG queries the legality of conducting a consultation on the SPD when the new Wycombe District Local Plan has not yet been formally adopted.5 Regulations 8(3) and 8(4) of the Town and Country Planning (Local Planning) (England) Regulations 2012 provide that any policies contained in a supplementary planning document must not conflict with, and must be consistent with “the adopted development plan”. The SPD purports to be supplemental to the new Wycombe District Local Plan. But at no time during the SPD consultation period has the new local plan been formally adopted. Technically, then, the relevant “adopted development plan” remains the local plan adopted on 7 July 2008 and this has been the case throughout the SPD consultation period. Clearly the policies in the SPD conflict with the 2008 local plan, and/or are inconsistent with it. As such, does the SPD fail to comply with regulations 8(3) and 8(4) of the Town and Country Planning (Local Planning) (England) Regulations 2012? Errors The SPD and the Phasing Tests contain a number of material errors, including errors in the key traffic data for Shootacre Lane. These errors call into question (a) whether the data can be used as a reliable basis for decision making; and (b) whether an effective

5 The Planning Inspector’s report on the Local Plan dated 10 July 2019 was only made available on 19 July 2019. The Local Plan itself is scheduled to be adopted by WDC on 19 August 2019.

BANG group response to the Princes Risborough Expansion Plan consultation consultation has been carried out. The cTc Report also identifies these errors and calls into question whether they are valid for decision-making. These errors are explained fully in section 15 below.

6. Safety Shootacre Lane and Picts Lane currently have very low traffic movements.6 These are tranquil, rural lanes used for walking, cycling and horse riding. In particular Picts Lane and Shootacre Lane are popular routes by foot to the railway station. Sections of Shootacre Lane have no pavement. Picts Lane forms part of Sustrans National Cycle Route 57. The SPD proposes using these quiet lanes as an interim relief road: they would be transformed into busy roads carrying substantially more traffic, including significant construction traffic and HGVs, for a period of many years. The increase in traffic is analysed in the cTc Report (para 4.7). It is clear from this that there will be a very significant increase in traffic. For example, some of the modelled scenarios in the Phasing Tests show an increase in AM Peak hour traffic on Shootacre Lane of 5617%. Not only will there be a huge increase in traffic levels, the traffic will be moving at greater speed. It is proposed that the junction of Shootacre Lane and Picts Lane is improved by widening the arc of the junction of Shootacre Lane and Picts Lane. The effect of this change will be to increase the speed at which vehicles can travel through the junction (see cTc Report paragraph 4.16). The consultation documents contain no detailed information about the proposed interim relief road measures. However, we understand from a meeting on June 25 between BANG representatives and John Callaghan, WDC Team leader (Infrastructure and Projects) that there would be no reduction in the speed limit along either of the lanes and no safety provision for pedestrians at the junction between the lanes. Existing infrastructure The cTc Report has identified the following areas of concern with the safety of the existing road infrastructure: • Visibility from Shootacre Lane at the junction of the A4010 to the left (towards northbound traffic) is substandard and a highway safety risk. • The average carriageway width of Shootacre Lane is 5.2m – anything below 5.5m raises safety concerns about pedestrians and cyclists sharing the carriageway. • Visibility from the Upper Icknield Way at the junction with Shootacre Lane is substandard and therefore a highway safety risk.

6 Pages 2 and 3 of Appendix H of the Phasing Tests show that the 2013 AM peak traffic volume on Shootacre Lane is as 0/5 and the PM peak is 0/0; the 2013 AM peak traffic volume on Picts Lane was 87/100 and the PM peak was 86/99).

BANG group response to the Princes Risborough Expansion Plan consultation

• A significant number of houses have private residential driveways with substandard and potentially unsafe visibility (12 houses on Shootacre Lane and 32 on Picts Lane). • Many houses do not have turning areas and residents have to either reverse onto or off their driveway. • There is a pedestrian desire line on the verge on the eastern side of the Picts Lane which crosses Shootacre Lane to connect with the public footpath to the railway station and over the railway bridge. Cars also park on the verges near the junction to use the public footpath. The proposed realignment of the Shootacre Lane/Picts Lane junction does not cater for this pedestrian demand. The cTc Report concludes that as the SPD proposals will lead to significant increases in traffic flow and traffic speed on Shootacre Lane and Picts Lane, this will exacerbate the safety issues with the existing infrastructure, putting all road users at increased risk. The cTc Report recommends mitigating these risks by building the Culverton Link at phase 1. Pedestrian, Cyclist and Equestrian safety Both Shootacre Lane and Picts Lane are widely used by pedestrians. This includes local residents walking to the railway station, to the town centre and to school. Runners also use this route. Both lanes are also widely used by cyclists. Picts Lane forms part of National Cycle Route 57 and both it and Shootacre Lane form part of the Chiltern Cycleway Link. Shootacre Lane connects two popular bridlepaths (the Ridgeway and the Phoenix Trail) and equestrian use is widespread. Several residents own horses and stable them in land to the rear of their properties. The use of Shootacre Lane as an interim relief road would put horse riders in direct conflict with a significant number of vehicles. The cTc Report states that it is essential to consider the impact on horse riders, along with pedestrians and cyclists before progressing further, and recommends that a Walking Cycling and Horse-Riding Assessment is completed. Furthermore, the cTc Report states at paragraph 4.9 that it is probable that the impact on horse-riders, pedestrians and cyclists “could wholly outweigh any perceived benefit of delaying construction of the Culverton Link”. Safety issues have not been properly considered The Delivery Plan states that one of the key questions it considers is: “What level of development could be accommodated, using Shootacre Lane as an interim route to connect the SRL to the A4010 before the Culverton Link Road is in place?”7

7 Page 152, SPD.

BANG group response to the Princes Risborough Expansion Plan consultation

This question is, correctly, framed in broad terms about the suitability of the Shootacre Lane/Picts Lane route as a whole. As such, it requires consideration of the capacity, suitability and safety of the proposed route as a whole. Instead, the conclusion reached in the delivery plan is based only on narrow issue of whether the Shootacre Lane junction with the A4010 could accommodate the additional traffic. That is the only issue relating to the Shootacre Lane route which is analysed in the Phasing Tests – for example (our emphasis): “Modelling test J is intended to look at the performance of A4010/Shootacre Lane junction under Modified Scenario 3, and to determine how the introduction of the Culverton Link would impact on traffic assignment and the resulting available capacity at the junction”.8

7. Air quality The SPD proposal to use Shootacre Lane and Picts Lane as an interim relief road would meet the triggers in the relevant statutory guidance requiring a full Air Quality Assessment. The 2015 EPUK and IAQM guidance provides that an Air Quality Assessment is required where there is a change of LDV flows of more than 500 AADT (Annual Average Daily Traffic). The Phasing Tests indicate that this threshold will be easily passed.9 However it appears from the SPD that no Air Quality Assessment has taken place. An Air Quality Assessment should look at the likely changes in air quality as a result of the SPD proposals. These changes should be quantified and the overall significance of the impact should be determined. The percentage change in air quality relative to the existing Air Quality Assessment Level (AQAL) would be significant. The negative impact on air quality will be substantial in both total and percentage terms. The statutory guidance indicates that attempts must be made to mitigate the negative impact in such circumstances. Our key point here is that building the Culverton Link at the initial phase of development would avoid these issues: there would be no negative impact on air quality on Shootacre Lane and Picts Lane; and there would be no need to carry out a full Air Quality Assessment in relation to Shootacre Lane and Picts Lane.

8 Page 35, Phasing Tests. 9 Comparing the 2013 baseline for Shootacre Lane with the flows shown for Modified Scenario 3 (Without Culverton Link) indicates that there will be an additional 342 movements during the 8-9 AM peak and an additional 256 movements during the 5-6 PM peak alone (see pages 2,3,6 and 7 of Appendix H of the Phasing Tests). The figures are similar in Scenario 3B (Without Culverton Link).

BANG group response to the Princes Risborough Expansion Plan consultation

8. Noise The Design Manual for Roads and Bridges10 (DMRB) sets out threshold criteria, which, where it is possible that they will be met or exceeded, trigger the requirement for a detailed traffic noise assessment. The threshold criteria include: • Change in daytime traffic noise impacts in the short term of 1 dB LA10,18h (Opening Year 1). • Change in daytime traffic noise impacts in the long term of 3 dB LA10,18h (typically 15 years after project opening). DMRB provides guidance on the significance of changes in road traffic noise. Assuming no changes to the proportion of heavy vehicles or traffic speeds, an increase in traffic volume of 25% is required to alter the noise levels by 1 dB(A). Given that the peak traffic on Shootacre Lane is forecast to increase by as much as 5617%11 the above thresholds in relation to both Shootacre Lane and Picts Lane will be easily passed. A detailed traffic noise assessment should therefore be carried out and appropriate steps taken to mitigate the impact of the additional noise. Our key point here is that building the Culverton Link at the initial phase of development would avoid these issues: there would be a significantly lower impact from traffic noise on Shootacre Lane and Picts Lane, and there would be no need to carry out a detailed traffic noise assessment in relation to Shootacre Lane and Picts Lane.

9. Statutory compensation Part 1 of the Land Compensation Act 1973 provides that compensation can be claimed for the reduction in value of residential property caused by physical factors including noise, vibration, smell and fumes caused by “public works”. This includes any work on roads and highways, and also includes changes in use. The SPD proposes a number of public works which would result in the use of Shootacre Lane and Picts Lane as an interim relief road, directly causing a substantial increase in traffic (up to a 222% increase on Picts Lane). These proposed public works include: • widening the arc of the junction of Shootacre Lane and Picts Lane; • closing the junction of the A4010 and Upper Icknield Way; and • building approximately 1,100 new houses in the Princes Risborough Expansion Area. The noise, vibration, smell and fumes resulting from the public works and the new interim relief road route facilitated by those works would adversely affect and cause a

10 Volume 11, Section 3, Part 7, HD 213/11 (2011) 11 See para 4.7 of the cTc Report.

BANG group response to the Princes Risborough Expansion Plan consultation reduction in the value of a significant number of residential properties. Approximately 75 residential properties are within 50 metres of the proposed interim relief road route12. If these public works go ahead and Shootacre Lane and Picts Lane are used as an interim relief route, claims for Part 1 compensation would be made by affected residents. Although the SPD does include an allowance for Part 1 compensation of £1,767,299 in relation to phase 1 of the Delivery Plan, it is unclear whether this includes any allowance for residents on Shootacre Lane, Picts Lane, Horsenden Lane, Bledlow Road and Goodearl Place.13 We suspect that insufficient provision has been made for claims by these residents. We note that previous work commissioned by WDC estimated that using Shootacre Lane and Picts Lane as the final route for a relief road would result in total Part 1 compensation claims of around £2,600,000.14 Our key point here is that building the Culverton Link at the initial phase of development would avoid these issues: there would be no reduction in the value of our members’ residential property and there would be no need for WDC to face claims for substantial Part 1 compensation.

10. Impact on the character of the area Shootacre Lane and Picts Lane are tranquil, rural lanes currently used for walking, running, cycling and horse riding. The residents survey carried out by BANG in December 2016 (see Appendix 4) found that non-motorised usage by local residents was high, for example: • 59% of residents walked to catch the train or bus; 20% walked to work; 13% walked to school; 92% walked for leisure purposes; and • 21% of residents cycled to work, school or to the train/bus station. In addition, Shootacre Lane and Picts Lane are widely used by local people in Princes Risborough and around. Both Shootacre Lane and Picts Lane are used as a gateway to the countryside by the people of Princes Risborough, on foot and by bike. Picts Lane is used for many pedestrian journeys from Princes Risborough town centre or railway station in order to access the cricket club, tennis club and football club on Horsenden Lane. They are special places which deserve to be protected. Some of the factors which contribute to this character are:

12 Page 10 of the report prepared by DRF Consulting “Princes Risborough Feasibility Review of Southern Alternatives” dated 4 September 2017 states that 66 houses are within 50m of the Shootacre/Picts route. Since then a number of new houses have been built on Picts Lane and Goodearl Place. 13 Appendix 4 to the SPD lists Part 1 compensation costs of £1,767,299 in relation to phase 1 of the Delivery Plan. 14 See page 85 of the report prepared by DRF Consulting “Princes Risborough Feasibility Review of Southern Alternatives” dated 4 September 2017.

BANG group response to the Princes Risborough Expansion Plan consultation

• Very low traffic movements and substantial use by cyclists, pedestrians and horse riders.15 • Proximity to the railway station means that for many visitors Picts Lane and Shootacre Lane are the gateway to the Chilterns. • The Ridgeway long distance national walking route crosses Shootacre Lane and many walkers access the Ridgeway via Shootacre Lane, either from Princes Risborough town centre or from the railway station. • Shootacre Lane and Picts Lane form part of the route of the Icknield Way Trail, a long-distance regional walking route. • Sustrans National Cycle Route 57 runs along Picts Lane, over the railway bridge and down Horsenden Lane. This also gives access to the “Phoenix trail” a popular off-road cycle route to Thame. • The Chiltern Cycleway Link runs from the railway station, up Picts Lane and along Shootacre Lane to connect with the Chiltern Cycleway at the Upper Icknield Way. • Shootacre Lane is part of the Chilterns Area of Outstanding Natural Beauty (AONB). • Shootacre Lane and Picts Lane are bordered by Green Belt land. • Shootacre Lane and Picts Lane both have ancient hedgerows and a number of protected trees. • Shootacre Lane has wide verges which support a range of rare and protected wildflowers including bee orchids and native bluebells (Hyacinthoides non- scripta). • Several horses are stabled behind Shootacre Lane. Shootacre Lane itself is widely used as an equestrian route for riders to access the bridleways on both Horsenden Lane and the Upper Icknield Way. • Shootacre Lane, Picts Lane and Horsenden Lane currently support a significant bat population (see Appendix 5). Under the SPD proposals these tranquil rural lanes would be transformed into busy roads carrying substantially more traffic, including significant construction traffic and HGVs, for a period of many years. These lanes would cease to be safe, pleasant spaces for walkers, cyclists and equestrians. The special character of these lanes would be destroyed and there would be a substantial loss of amenity not only to the residents but also to the wider population of Princes Risborough and the many visitors to this area. Our key point here is that building the Culverton Link at the initial phase of development would preserve the special character of this area and avoid any negative impact on the special nature of Shootacre Lane and Picts Lane.

15 Pages 2 and 3 of Appendix H of the Phasing Tests show that the 2013 AM peak traffic volume on Shootacre Lane is as 0/5 and the PM peak is 0/0; the 2013 AM peak traffic volume on Picts Lane was 87/100 and the PM peak was 86/99).

BANG group response to the Princes Risborough Expansion Plan consultation

11. Loss of amenity The triangular grassland area at the corner of Shootacre Lane and Picts Lane, often locally referred to as ‘The Green’, is currently a peaceful green space used by residents and the wider community for a range of pursuits. These include dog-walking, strolling and community gatherings. Some of our older residents can recall cows and horses grazing here. The proposal to widen the junction between Shootacre Lane and Picts Lane will involve at least 120sqm of land take16 from this precious community amenity. The increase in traffic will also make the area less peaceful and attractive for leisure pursuits and community events, resulting in loss of amenity. A recent photograph from our media coverage shows this area being used by the community. See Appendix 6.

12. Community Severance The significant increase in traffic, combined with the proposed alterations to the junction between Shootacre Lane and Picts Lane, will create a barrier effect, discouraging journeys on foot or by bicycle. Some residents board the Risborough Area Community Bus at Picts Lane in order to access town centre amenities. The proposed interim relief road route could prevent the bus from stopping safely in Picts Lane to collect passengers. In a Residents Survey (see Appendix 4), 49 out of the 59 households who responded felt that routing a relief road along Shootacre Lane and Picts Lane would have a very detrimental effect on their sense of connection with neighbours, while 50 said it would have a very detrimental effect on their connection with the town. Out of 180 residents surveyed, 153 currently walk to access town centre shops and facilities while 166 walk for leisure.

13. Cost savings The SPD identifies that £376,000 will need to be spent initially on interim “safety” improvements to enable the use of Shootacre Lane and Picts Lane as an interim relief road. In this response we have identified a number of other areas where further expense is likely to be required if Shootacre Lane and Picts Lane are to be used as an interim relief road: • creation of a new pedestrian crossing at the junction of Shootacre Lane and Picts Lane; • a Walking, Cycling and Horse Riding Assessment; • an Air Quality Assessment;

16 The figures are barely legible on the diagram provided (see Appendix 1) but the figure is either 120sqm or 150sqm

BANG group response to the Princes Risborough Expansion Plan consultation

• detailed traffic noise assessment; and • payment of compensation under Part 1 of the Land Compensation Act 1973. When taken in aggregate, the costs above associated with the interim relief road are likely to form a significant proportion of the estimated cost of providing a final route in the form of the Culverton Link (the total cost of building the Culverton Link has been estimated at £2,596,971).17 As such, it would be a more cost-effective use of public funds to build the Culverton Link at the initial stage of construction. This would avoid wasting public money unnecessarily on all the above expenditure associated with the interim relief road route along Shootacre Lane and Picts Lane.

14. Planning and transport policy Some of the relevant policies we have identified are outlined below. The National Planning Policy Framework National planning policy is contained in the National Planning Policy Framework (NPPF) dated February 2019. This encourages sustainable development and aims to reduce reliance on the car for regular journeys. New development should be targeting increased use of cycling and walking as a practical mode of travel. For example: • Paragraph 102 of the NPPF provides that “opportunities to promote walking, cycling and public transport use are identified and pursued” and that planning policy should provide for “high quality walking and cycling networks and supporting facilities”. • Paragraph 110 of the NPPF provides that development should give first priority to pedestrian and cycle movements, and create environments which “which minimise the scope for conflicts between pedestrians, cyclists and vehicles”. LTP4 Local transport policy is made by Buckinghamshire County Council. Key policies contained in its local transport plan ‘Buckinghamshire’s Local Transport Plan 4’ provide that: • Policy 12 - Walking – “Walking should be the best option for more of our short journeys. We will look to develop the walking network and encourage walking, to help ensure it becomes one of the most convenient ways to make short journeys.” • Policy 13 – Encouraging cycling – “We will look to develop the cycling network through a combination of new infrastructure, maintenance and promotion.” • Policy 17 - Road safety – “We will work to ensure that new developments provide safe and suitable access.”

17 See page 61 of the report prepared by DRF Consulting “Princes Risborough Feasibility Review” dated 4 September 2017.

BANG group response to the Princes Risborough Expansion Plan consultation

Wycombe District Local Plan • Principles for Princes Risborough policy - “[WDC will] facilitate local infrastructure [and] achieve an improved (our emphasis) environment for walking and cycling, in both the existing town and the expanded town”;18 Conflict with the NPPF, LPT and Local Plan “Principles for Princes Risborough policy” It is clear that the proposed increase in traffic will endanger pedestrians and cyclists. Full details of the safety impacts are set out in the cTc Report and in section 1 above on safety. Clearly where a road becomes less safe for pedestrians and cyclists, this discourages them from using it. The increased air pollution and traffic noise will also discourage use of the road by pedestrians and cyclists.19 The BANG resident survey (see Appendix 4) indicates that in such circumstances car use would increase i.e. “there would be a marked increase in car use for journeys that would not have previously been by car”. This means that the proposal to use Shootacre Lane and Picts Lane as an interim relief road is contrary to the aim of sustainable development in the NPPF, and contrary to the above policies in the LPT4, and contrary to the Local Plan “Principles for Princes Risborough” policy. This point is also made in the cTc Report - see section 5 of the report. In terms of cycling, this is a significant conflict as Shootacre Lane and Picts Lane junction is part of an important route for cycling for both locals and visitors, forming part of Sustrans National Cycle Route 57 and the Chiltern Cycleway.

Conflict with the Local Plan Policy PR5 - the strategic buffer

• Policy PR5 - the strategic buffer - “The purpose of the strategic buffer is to protect the open and undeveloped character of the area within it.”20 “Essential infrastructure required (our emphasis) to support the expansion of the town will be permitted outside the settlement boundary.”21 The junction of Picts Lane and Shootacre Lane is on and forms part of the boundary of the strategic buffer. As such, only essential infrastructure which is required to support the expansion of the town should be permitted here. The interim changes being proposed in the SPD are not required to enable the expansion of the town. The changes to Shootacre Lane and Picts Lane are instead being proposed in order to accommodate a preferred order of funding the delivery of the expansion. In other words, the changes to Shootacre Lane and Picts Lane are being proposed to meet a preference, not a requirement. At the southern end, only the

18 Para 5.3.8 of the publication version of the Wycombe District Local Plan, October 2017. 19 This point is supported by the survey of local road users that BANG carried out in December 2016 - see Appendix 3. This indicates a high level of pedestrian and cycling use by residents. 20 Para 5.3.59 of the publication version of the Wycombe District Local Plan, October 2017. 21 Para 5.3.54 of the publication version of the Wycombe District Local Plan, October 2017.

BANG group response to the Princes Risborough Expansion Plan consultation

Culverton Link is required to enable the expansion of the town, as only it will have the necessary capacity for all of the expansion area. For the above reason, the infrastructure changes being proposed under the SPD conflict with Policy PR5 in the Local Plan. Conflict with policy PR8 – Provision and Safeguarding of Transport Infrastructure • Policy PR8 - “Some lengths of existing roads (Grove Lane, B4009 Lower Icknield Way, Summerleys Road, Picts Lane and Shootacre Lane) along this route will need improvement to carry the forecast volume of traffic”22 WDC has confirmed that the above reference to Shootacre Lane is an error which will be deleted and will not appear in the adopted version of the Local Plan.23 As such the infrastructure changes to Shootacre Lane being proposed under the SPD conflicts with or is inconsistent with Policy PR8 in the Local Plan. • Figure 30 is an “indicative plan showing required highway changes for the relief road”.24 Figure 30 contains no reference to closing the junction of the A4010 and the Upper Icknield Way. The SPD is therefore proposing another change which conflicts with Policy PR8 in the Local Plan. Summary Our key point here is that changing the SPD so that the Culverton Link is delivered at the initial phase of development would avoid the above policy issues as the SPD would then: • better accord with the aim of sustainable development in the NPPF; • comply with local transport policy in LTP4; and • avoid the conflicts and inconsistencies we have identified with the Local Plan - it would achieve an improved environment for walking and cycling, it would mean the only development taking place in the strategic buffer would be required for delivery of the expansion, and it would be consistent with the highway changes shown in Policy PR8.

15. Errors and omissions in the consultation materials The SPD BANG has identified a number of errors and omissions in the SPD as follows: • No Walking, Cycling and Horse-Riding Assessment Review (WCHAR) has been carried out – government guidance provides that this should be carried out for schemes likely to impact upon vulnerable modes. (cTc Report paragraph 6.5).

22 Para 5.3.140 of the publication version of the Wycombe District Local Plan, October 2017. 23 Email from Rosie Brake, Principal Planning Policy Officer to Philip Hayes 28 February 2019. 24 Para 5.3.132 and page 221 of the publication version of the Wycombe District Local Plan, October 2017.

BANG group response to the Princes Risborough Expansion Plan consultation

• The triggers requiring an Air Quality Assessment are met but this assessment has not been carried out. • The thresholds requiring a detailed traffic noise assessment are met but this assessment has not been carried out. • It appears that no allowance has been made for the statutory compensation that would be payable to residents on Shootacre Lane, Picts Lane and Horsenden Lane. • An assessment of the impact of construction traffic should be carried out and a construction management plan should be prepared - it does not appear that either of these things have been done. The most significant omission is that the SPD provides no detail on the specific improvements that are being proposed for Shootacre Lane and Picts Lane. These details only emerged after requests from BANG. The other related point is that no analysis has been made of the effect that the proposed changes will have once the Culverton Link has been completed. There is the risk of the improved Shootacre Lane/Picts Lane route causing (a) traffic to rat-run along it rather than using the Culverton Link; and (b) safety issues from more traffic using the junction with Shootacre Lane/A4010. The Phasing Tests BANG has also identified a number of potentially significant errors and omissions in the Phasing Tests which we list below. Of particular concern is that the 2013 baseline traffic flow figures for Shootacre Lane and Picts Lane appear to be incorrect in the Phasing Tests. This is a key piece of data for much of the analysis. We wonder how widespread these issues are and question whether the Jacobs reports are a reliable basis for decision making. The cTc Report echoes these concerns and states that the model output in the Phasing Tests should be afforded only limited credibility. 2013 baseline figures The Princes Risborough Area Transport Study prepared by Jacobs dated January 2014 shows the following data for the 2013 baseline (pages 12 and 13): AM peak PM peak Shootacre Lane 39/55 70/53 Picts Lane 122/135 131/114

The Phasing Tests show substantially different figures for the 2013 baseline (see pages 2 and 3 of Appendix H of the Phasing Tests): AM peak PM peak Shootacre Lane 0/5 0/0 Picts Lane 87/100 86/99

BANG group response to the Princes Risborough Expansion Plan consultation

There is clearly an error here as the 2013 baseline figures in the Princes Risborough Area Transport Study 2014 and the Phasing Tests (2019) (both of which were prepared by Jacobs) should be the same, or at least substantially similar. In this response we have assumed that the data in the Phasing Tests is correct, as that is the document currently under consultation. Page 29 of the Phasing Tests This is the key page of the Phasing Tests for BANG, as figure 11 should show the expected AM and PM flows at Shootacre Lane and Picts Lane under Modified Scenario 3 (without Culverton Link). In other words, figure 11 should show the anticipated traffic along Shootacre Lane and Picts Lane if they were used as an interim relief road up to the completion of 1,100 homes. The left-hand side diagram is labelled “AM Flows (without Culverton Link)” and has a footnote stating that “Note [the Culverton Link] appears within the model but is closed and has 0 flow”. The right-hand side diagram is labelled “PM Flows (without Culverton Link)” and has no such footnote. The diagram itself shows that the Culverton Link has a flow of 126/203. Clearly there is an error here, as if the right-hand side diagram did show "PM Flows (without Culverton Link)" as it labelled, then there would be 0 flow along the Culverton Link. Construction traffic It is obvious that the major infrastructure and development contemplated in the SPD will generate a significant volume of construction traffic over a period of many years. But the Phasing Tests appear to have made no allowance for any additional traffic associated with the construction. Nor has any allowance for HS2 construction traffic been made. Closing the junction of the A4010 and Upper Icknield Way The SPD proposals include closing the junction of the A4010 and the Upper Icknield Way. However, the effect of this closure has not been modelled: all of the traffic modelling in the Phasing Tests assume that this junction remains open. It is therefore unknown what effect this is forecast to have on traffic flow on and around Shootacre Lane and Picts Lane.

16. Conclusion Shootacre Lane and Picts Lane are unsuitable for use as an interim relief road. The significant increase in traffic, together with the proposed road layout alterations, will create a dangerous and hostile environment for residents and visitors, including pedestrians, cyclists and horse-riders. Although the measures are described as ‘interim’, they will cause long-term harm to this very special area and have a negative impact on its rural character.

BANG group response to the Princes Risborough Expansion Plan consultation

Appendix 1 – Additional information about the proposed changes to Shootacre Lane and Picts Lane

BANG group response to the Princes Risborough Expansion Plan consultation

Appendix 3 – Email from Carl Etholen, County Councillor

On Friday, 19 July 2019 08:44:13 BST, Etholen, Carl - (County Councillor) wrote:

Dear Sir/ Madam

I am writing to express my concern over the proposals contained in the Princes Risborough Consultation regarding Picts Lane and Shootacre Lane following concerns raised by local Residents to me as their County Councillor for the Ridgeway West Division which abuts Princes Risborough.

The current proposals do not include the new Culverton Link Road in the Phase One infrastructure planning will mean that traffic will increase down Shootacre Lane and Picts Lane.

Concerns have been raised that these proposals will create an unsafe situation for non-motorised road users such as cyclists and horse riders. Indeed, the road is part of the national cycle network, with the Sustrans Phoenix Trail between Thame and Princes Risborough running down Picts Lane. These Residents fear that there will be an increase in traffic as well as HGV movements which could impede safety on this narrow road. Moreover, Shootacre Lane and Picts Lane do not have pavements all the way down their length thus increasing the danger for pedestrians. I tend to agree that this proposal would make both Shootacre Lane and Picts Lane less safe for pedestrians and non-motorised transport.

In addition, I am concerned that the road would also be impractical for HGV movements as at points both lanes are very narrow, and I question whether heavy goods traffic could pass safely without mounting the grass verges, further endangering pedestrians and other road users. Indeed, the junction at Shootacre Lane and Picts Lane, before the railway bridge, is quite tight and I would suggest there is a need for a substantial alteration to make safe for all road users ultimately adding to the costs of the scheme.

Furthermore, I understand that the scheme to make both Shootacre and Picts Lane viable will cost in excess of £400,000 whereas the Culverton Link Road is £2.6 million. It seems to me that the best use of this £400,000 designated for temporary road alterations would be better spent on the permanent Culverton Link Road.

Kind regards

Carl Cllr Carl Etholen Ridgeway West Division- Bucks County Council Vice Chairman- North West Chilterns Local Area Forum Bledlow & Bradenham-Wycombe District Council

BANG group response to the Princes Risborough Expansion Plan consultation

Appendix 4 - BANG Residents survey, December 2016

BANG group response to the Princes Risborough Expansion Plan consultation

Appendix 5 – BANG bat survey, 2016

BANG group response to the Princes Risborough Expansion Plan consultation

Published by Charlotte Fisher at 5:45am 17th July 2019. Campaigners in Princes Risborough are fighting to save their beauty spot. The group have condemned Wycombe District Council's plans to route a relief road along rural residential lanes in the town. Proposals to route part of a new western relief road along Shootacre Lane and Picts Lane were ditched two years ago after the Princes Risborough Bypass ActioN Group (BANG), backed up by expert reports, established that the roads were unsafe and unsuitable for this purpose. But, the plans have risen to the surface again.. The council is planning to use Shootacre Lane and Picts Lanes as an 'interim' route for 10 years or more and these plans were revealed in the Princes Risborough Expansion Plan. The council has said a new relief route is needed to serve construction lorries travelling to the development site and eventually through-traffic between High Wycombe and Aylesbury. The final route chosen by the council involves the creation of a new £2.5m stretch of road - the 'Culverton Link', which won't be built until the final phase of the plan in about 2033. In the meantime it plans to spend £376,000 on interim measures along Shootacre Lane including widening the junction with Picts Lane so HGVs can pass each other and traffic flows faster. "It will cause permanent harm to this very special area"

BANG group response to the Princes Risborough Expansion Plan consultation

Campaigners gathered over the weekend to protest Picts Lane forms part of a Sustrans National Cycle Route while Shootacre Lane lies within a designated Area of Outstanding Natural Beauty and provides a link between two important bridleways - the Ridgeway and Phoenix Trail. Both lanes are in frequent use by horse-riders, cyclists, walkers & joggers to access the local countryside and are lined with ancient hedgerows and important trees. Campaigners are worried that no safe measures will be put in place to protect people using the lanes.

BANG group response to the Princes Risborough Expansion Plan consultation

So, residents gathered on the corner of the two roads for a Tea on the Green event on Sunday (14 July) to protest against the plans and raise money for their campaign. Mrs Monica Nelson, one of the coordinators of BANG, said: "This latest proposal from Wycombe District Council is utterly staggering. "Despite agreeing that our lanes would make an unsatisfactory and unsafe relief road, it plans to spend almost £400,000 on a long-term interim solution that will cause permanent harm to this very special area and more than a decade of misery and danger for residents. "There is also a risk that this inadequate measure will become permanent if the funding is not there in 10 years time. "This is a very special place and the neighbourhood has really pulled together once again to fight this ludicrous plan with everything we have." Fellow BANG coordinator Philip Hayes added: "I am very concerned by the proposal to use our lanes as the main road for construction traffic heading for the Risborough expansion area. "These roads are completely unsuitable for this increased volume and type of traffic. "There is no evidence of the council having looked at the safety implications for pedestrians, cyclists and horseriders. "The section of Shootacre Lane where I live doesn't even have a pavement." BANG are urging people in the area to respond to the council's consultation on the Expansion Plan, which ends on the 21st July. Wycombe District Council respond "The council is committed to getting the right infrastructure to go with the planned Princes Risborough expansion. "We have always recognised that more work was – and is - required on which sections of road are needed when, and to ensure that they can be delivered in a timely way. "Our current proposals are that the relief road should be provided in full by 2028. "This contrasts with current planning applications from developers who wish to build up to 1200 homes with no real highway improvements and little other supporting infrastructure. "We will resist ad hoc development that does not bring with it – or contribute to – the right infrastructure for the town."