Written Statement from Mr T. Bronk (an individual) further to representation response number 027090277 objecting to the Borough Council draft Local Plan

1. My representation stated I was unsure whether the matters I raised fall within the category of Legal and Compliance. 2. My Representation stated I was opposed to the following parts of the draft Local Plan in respect of sustainability and infrastructure: DM3; and in respect of Transport: Policy S6 (do you support or object to this policy on the new Allbrook, Bishopstoke and Fair Oak link road); and Policy S12 (do you support or object to this policy on transport infrastructure).

I have identified that Matters 2 and 5 and issues therein are particularly relevant to my question whether the draft Local Plan has taken: “proper account of its impact on existing infrastructure” and whether in respect of all journeys arising because of the proposed developments Eastleigh Borough Council can be “reasonably satisfied those movements can be accommodated”.

My Statement My representation challenged whether the proposed new Link Road including realignment of Highbridge Road (B3335) by Allbrook railway bridge was a reasonable mitigant to the increase of traffic that will be generated by the proposed new development. I provide the following information to show the inadequacies of the existing transport infrastructure and therefore to emphasise my continuing concern about Issue 2.5: “What reasonable alternatives have been considered to avoid these effects [negative or minor negative] and if they are avoidable, is the Plan justified?”

The further documents issued in support of the draft Local Plan (such as SGO022 and TRA014a) confirm the inability of Allbrook bridge to accommodate large HGVs and double deck busses. The consequence is that all large HGVs travelling north and west from the proposed development sites must therefore travel on the existing road network, in particular the B3354 though and after the Highbridge Road junction the B3335 through Twyford. I provide below the following additional information to emphasise the negative effects; to support my contention that they are avoidable by locating development at other more suitable sites and therefore that the Plan is not justified.

Physical constraints on the B3335 Physical constraints exist on the B3335 Twyford High Street near the Park Lane and Queen Street road junctions. In particular, the bend on that section of road cannot currently accommodate two HGVs passing so any increase in the number of such vehicles will exacerbate the existing problem. I provide annotated maps below and photographs in Appendix A that show traffic queueing to the north and the dangers to pedestrians when traffic is moving in a southerly direction. Please also note that there is an absence of a usable pavement on the west side of the High Street at that location. Children walking to the Junior School from properties to the south of Queen Street must therefore cross the High Street to access the pavement on the east side and then cross again soon after the bend. Neither crossing is assisted although two Pelican crossings exist to the north of the intersection of the High Street by Hazeley Road and Finches Lane.

In response to concerns raised by residents at the Colden Common Annual Parish Assembly about HGVs travelling through Colden Common (and on to Twyford) County Council provided the response at Appendix B stating that no weight or other limitations were possible on the B3335 or B3354. Further information is at Appendix D.

Map of a section of Twyford High Street – Please note the scale

Narrow High Street B3335 and bend causes wide or long vehicles to cross the road carriageway markings

No pavement

Road crossings with traffic lights

Narrow High Street and bend where pavement is absent on the west side of the High Street

Unadopted road without a pavement is a poor alternative as an access route to the north of the village (to prevent crossing the road without assisted crossings)

Increasing numbers of traffic movements Besides carrying all northbound large HGVs the B3354 and B3335 will also carry many other vehicles for access to and the M3 and A34 (and A303 for westbound journeys).

Twyford Parish Council has purchased a Speed Limit Monitoring device that provides an hourly breakdown of the number of traffic movements and its speed. Unfortunately it has not yet been installed just before the Park Lane junction but data will be available prior to the scheduled hearings. Colden Common Parish Council published data from its monitoring device during the period 1st to 14th February 2019: “A staggering 97603 vehicles were picked up by the radar travelling Northbound during this period. Midweek an average of 15,515 North bound traffic movements take place each day.” The published data shows weekday average volume between 7.00am and 8.00am was 1869, equating to 31 per minute or one every 2 seconds; and an average speed of 29.8mph. Data from another location on the B3354 between 15th February and 26th was reported as follows: “Midweek traffic volumes are in excess of 10,000 cars per day.” Some concerns have been raised about the variance which might be attributed to the equipment used, or the school half term or problems with the M3 causing traffic to use alternative routes.

Although the Inspector will have been provided with other traffic data and projections the Inspector is asked to note the above data and the challenge currently faced by school children seeking to cross the Main Road without the benefit of a Pelican Crossing. The addition of more traffic from the proposed development will add to congestion and whilst some lowering of average speed may be a consequence this will not be sufficient to assist persons seeking to cross the road or for vehicles emerging from driveways and side roads to join it. The risk of accidents therefore increases as does pollution. A consequence of congestion is also lost time, as shown below.

Impact of congestion on child safety As a newly elected District Councillor I recently sought an explanation from Hampshire County Council for cancelling use of a bus stop at for students travelling to the Westgate School in Winchester. My children used to catch the bus at that stop at 7.50am. The stop is set back from the Main Road (which at that location has a 50mph limit) and has a bus shelter. Now children must walk along Main Road to beyond the junction with Highbridge Road and cross the Main Road where the speed is also 50mph but the stop is not set back. Also they must contend with traffic accelerating from the junction. The bus now starts from that location, leaving at 7.30am. The map below shows the locations involved.

“Safe” bus stop accessible via

Pelican Crossing, requiring walk of 0.88miles along unlit road and with poor pavements and large puddles

Starting bus stop for The Westgate School

Start time 7.30am

Former bus stop for The Westgate School.

Will not be used because of delay caused by congestion on Main Road.

Map to show the nature of congestion and delays on a normal morning (the date of submission of this statement) The blue location dot shows the approximate location of the Twyford Moors bus stop and that heavy congestion does exist shortly before that stop and on towards Winchester.

Map to show the nature of congestion and delay on the morning of another day.

Hampshire County Council has said the Twyford Moors stop cannot now be used because the bus would need to travel into Colden Common and the time incurred along Main Road (from the New Road junction) to the current bus stop would take too long. The full correspondence is at Appendix C. If this shows the current adverse effect of rising traffic volumes and the willingness of the County Council to increase the risk to children by cancelling use of the Twyford Moors bus stop, what further negative impact will arise if the proposed development is approved? How much worse will congestion (and attendant pollution), and lost time become? The studies prepared for the Local Plan pay insufficient attention to the impact on residents of Winchester City Council. In this context, please note that whilst cars might use the new route of the link road to Allington to reach the M3 to travel north, this will not occur unless and until the final phase is completed. Therefore the B3354 and B3335 will face to full impact of development for many years before any mitigation occurs.

Traffic speed and accident risk Residents living on Main Road are concerned about the speed of traffic and risk of accidents (several serious accidents are recorded on CrashMap – see below).

Besides the above history of recorded accidents there is local information available concerning unrecorded accidents, two this year on Main Road each involved three vehicles and another on Twyford High Street near the Park Lane junction involved two. Hampshire County Council does not recognise data concerning accidents that do not result in personal injury (or accounts of near misses). Furthermore the County Council does not accept requests by parish councils to reduce speed limits (stating they had previously been invited to make requests so HCC is satisfied no further changes are needed). The current Hampshire County Council policy is reproduced at Appendix D.

Pavements and Cycleways The above (and the appendices) I hope reflect the major concerns that exist in Colden Common and Twyford about the current road infrastructure. Residents are further dismayed at the poor condition of pavements adjacent to Main Road (see Appendix A) and the absence of any safe cycle routes from Colden Common and Twyford to Winchester and its new Sport and Leisure Centre (scheduled to open next year). At the Twyford crossroads cyclists are encouraged to leave the Main Road B3335 and use a signposted cycle route away from the floor of the to Shawford and Compton and along the Road. The alternative route is considerably longer and involves two significant hill climbs. A shared cycle path could easily be provided along much of Main Road from the new development, but it appears that studies have not considered this. SGO022 refers to cycle routes to Eastleigh and south to Southampton, but is sadly silent about routes north into Winchester or Twyford and the western gateway to the South Downs National Park.

Conclusion In conclusion, the proposed new developments will give rise to increased traffic not only from residents but also all vehicles from additional businesses and services serving them and hence increased congestion, pollution, delays and risk of accidents. These negative impacts on communities to the north of the new development will not be wholly mitigated by the proposed link road which must also be completed before any benefits are available.

The appendices show the reality and nature of existing risks and the current attitude of Hampshire County Council (it attributes its difficulties to funding problems and shows no commitment to addressing them in the near or foreseeable future). It is therefore imperative that the effect of the Plan on the neighbouring Winchester District Council’s residents is not overlooked when considering the Plan. It is contended that Sustainability is not achieved, questioned whether the Inspector can be “reasonably satisfied those [traffic] movements can be accommodated” and contended that reasonable alternatives have not been considered and adopted to avoid these effects [negative or minor negative]. Therefore the Plan is not justified and the suitability of alternative sites to the south with good access to the M27 and the Eastleigh/Portsmouth railway line should be further investigated.

Appendix A

Cyclists use the pavement when the B3335 is heavily congested

Pedestrians must take care when traffic travelling south out of Twyford ties to pass through the narrow bend of the High Street near the Park Lane junction

Pavement along Main Road B3335, showing sufficient width to create a shared path, but also how the road drainage cannot cope and how vehicles mount the pavement to pass traffic waiting to turn right into Highbridge Road (continuation of B3335) Appendix B Email concerning weight or other limitations on the B3335 or B3354

Extra from a Parish Councillor email to Hampshire County Council:

“Warwks CCs web site clearly states the process for PCs to request a review and survey of roads: but of course that is dependent on a county council being willing to entertain the idea. It would be really helpful if you could please confirm that HCC will not consider placing weight restrictions on the B3354.”

Extracts from response from Hampshire County Council:

“We are aware of some ongoing local concerns about HGV’s using Main Road and this was mentioned at the recent Colden Common Parish Assembly …. At the Assembly we stated that any restrictions on HGV’s on this route were not practical, being a B-class road and main distributor route.

In recent years there have been similar concerns raised by residents of other Parishes all along the route between Twyford and Wickham and between 2012 and 2014 our Strategic Transport team carried out some ‘origin & destination’ traffic surveys, which comprised various survey points along the route. The main conclusion from these surveys was that the majority of HGV traffic using the B3335/B3354 had origins or destinations local to the Bishops Waltham, Fair Oak and Colden Common areas and was not using this route as an alternative to the M3/M27 corridor, which had been suggested by many residents. A total of 86% of HGVs passing through Twyford on the B3335 had journey origins or destinations to the east (towards Bishops Waltham) or within the study cordon (B3354 corridor).

Since then, as explained at the Parish Assembly, our reduced Traffic & Safety resources have been targeted at casualty reduction and we prioritise sites with treatable patterns or clusters of reported injury accidents. With no recurring reports of HGV-related injury collisions throughout this route, and bearing in mind the outcome of the surveys mentioned above, there is no justification for HCC to consider any weight restrictions or other similar measures at present.”

Appendix C

Extracts from Hampshire County Council statement about the Twyford Moors bus stop

“Now having had the opportunity to fully investigate this issue I am now in the position to provide a full response to your query.

The additional costs that the bus company want to cover the additional journey down to Colden Common to turn the bus in the right direction is not based on mileage, but more on the time it will take to get back from Colden Common due to the slow moving traffic heading towards Twyford, of which I’m sure you are familiar with. The company are concerned that due to the volume of traffic it would make the current timetable very unreliable which could impact on students further along the route in Twyford.

The route has previously been a public bus service with both Brijan then Stagecoach which came from Fishers Pond so was passing the stop South of Woodland Drive, when HCC tendered for the school contract it was from Twyford Post Office to Westgate School only. We requested the pick up at the junction on Highbridge Road at a later date so pupils did not have to walk 0.88 miles to post office.

This obviously means that for students from Woodland Drove and Main Street the nearest stop to use the stop remains just past the junction of Highbridge Road and Main Road. I do note your concerns over crossing the road to access the bus stop, so after looking at alternative stops further along the route the stop in Twyford Village opposite the Post Office is a viable option. The distance from the students’ home to the stop in the village centre is within the mile maximum distance that students are expected to walk to a pick up point, and they can safely cross the road by the lights in the village centre.

The families on Highbridge Road who access the stop just past the junction of Highbridge Road and Main Road are very keen to carry on accessing the bus at this point. We will work with colleagues in Highways, who I understand you have previously raised the issues of drainage with, to improve the hard standing available at the stop.

I trust this email clarifies the situation, but please let me know if you need any further information.”

Operations Team Leader (Home to School Transport)

Appendix D

Extract from Hampshire County Council Policy

“A number of speed limit changes have previously been delivered through the annual traffic management programme. In addition, a number of large scale reviews have been progressed in recent years or are nearing completion, which will have produced a considerable number of lower speed limits across the whole of the Hampshire road network.

These reviews comprise the Village 30 project, which provided an opportunity for any village in Hampshire to bid for a 30 mph speed limit where appropriate, a review of speed limits on all A and B class roads, which carry the majority of all traffic and have the greatest potential for casualty reduction, and the Residential 20 pilot project, which followed the Department for Transport (DfT) relaxing its regulations relating to the implementation of 20 mph speed limits. There has already been a policy decision that no further 20 mph speed limits will be progressed until the effectiveness of the pilot schemes has been assessed.

The Village 30 project resulted in around 130 villages throughout the County being provided with new speed limits. The completion of the A and B Road Speed Limit Review will result in approximately 50 speed limit changes, while a total of 14 pilot 20 mph speed limit schemes have either already been implemented or are being progressed.

Taking into account these reviews, which have resulted in approximately 190 speed limit changes, it is considered that speed limits are broadly set at the correct level across the Hampshire roadetwork. Changes to speed limits will still be implemented if justified on injury accident grounds as part of a casualty reduction scheme.

(ii) Heavy Commercial Vehicle (HCV) restrictions and width restrictions on environmental grounds:

The County Council’s policy on HCV access restrictions and width restrictions have clear criteria in determining whether or not to impose such restrictions. However there is a disproportionate cost of carrying out surveys, for example to gauge the level HCV movements, in particular through-journeys, which more often than not confirms an initial assessment that the criteria are not met.

It is therefore proposed that environmental weight and width restrictions will only be considered where such measures would aid casualty reduction. This change of policy will not extend to weights limits that are required for structural reasons such as for weak bridges. https://documents.hants.gov.uk/transport/Futuretrafficmanagementpolicy.pdf

Whilst the document is dated 19 May 2016, it still forms the basis for current responses.