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

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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. 2 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. 3 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. 4 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.
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