Initial joint submission from:
The Campaign to Protect Rural England (CPRE)
North West Regional Group,
Friends of the Lake District (FLD)
and the
North West Transport Roundtable (NW TAR)
on the
WEST OF M6 STRATEGIC CONNECTIVITY STUDY
February 2016
INTRODUCTION
WSP/ Parsons Brinkerhoff are conducting a connectivity study focusing on strategic routes west of the M6 and on road access to the Port of Workington on behalf of Cumbria County Council, Cumbria Local Enterprise Partnership and Highways England (HE).
The Campaign to Protect Rural England, Friends of the Lake District and the North West TransportRoundtable – who are represented on the Northern TransPennine Strategic Study being carried out by the Department for Transport (DfT) and Highways England – expressed an interest in this complementary study and have been invited to be part of the ‘Informed Stakeholder Group’ for the West of M6 Study. As such we received a request to make an initial input by responding to a series of set questions. This is our response. Anywhere within it where we say ‘we’ we refer to all three organisations whose submissions this is.
For information: the Campaign to Protect Rural England (CPRE) works to protect and enhance towns and countryside to make them better places to live, work and enjoy. It espouses the ethos of ‘Smart Growth’ which, amongst other things, seeks to direct new infrastructure to previously developed land.
The North West Transport Roundtable (NW TAR) is an umbrella organisation which promotes sustainable transport and land use and healthier lives. It operates under the auspices of the Campaign for Better Transport (CfBT) – formerly Transport 2000 (T2000).
Friends of the Lake District (FLD) is an organisation which was established to conserve and protect the Lake District. However, it also acts as the Cumbria Branch of CPRE and, in that capacity, covers all of Cumbria. It is the only member organisation dedicated to protecting Cumbria’s landscapes.
All three bodies named above – CPRE, FLD and NW TAR – believe that the only sustainable way forward is to pursue policies and introduce measures which reduce the number of car journeys, rather than providing more road space. We would like to see better transport choices, safer roads - especially for walkers and cyclists - and a revitalisation of bus services and the rail system. This being the case, we have all been critical of what we believe to be a misguided return by government to road-building on a grand scale. We would argue that sustainable transport improvements and smart choices/ soft measures ought to always be delivered first in order to achieve modal shift. Better spatial planning would reduce the need to travel and new roads, widened ones and hard-shoulder running on motorways should only be implemented as a last resort and if a very sound case can be made.
LILLIAN BURNS
Acting Chair, CPRE North West Regional Group/Convenor, North West Transport Roundtable
E:
LAURA FISKE
Planning Officer, Friends of the Lake District
E:
Over arching comments on the current consultation
Whilst CPRE, FLD and NW TAR welcome having been invited onto this study and we intend to interact with it as much as we are allowed to, we first of all need to explain the issues we have with this, its first, consultation stage and seek some reassurances.
1)It is apparent from the outset that this is not a multi-modal study but a roads-based one. Is there to be no counter-balancing look at public transport and/or freight on rail at all?
2)Are we able to see the consultants’ brief?
3)Is there a reference case and/or a list of reference documents? How much new technical evidence will be collected as part of this study? Will it include traffic surveys, an origin destination study, an economic impact assessment or an environmental impact study?
4)We are pleased to note the statement that the study will, in the first instance, assess the need for intervention.However, we fear that the test may not be the kind of robust technical evidence we would expect but more a matter of collecting observations from stakeholder groups. We therefore seek reassurance that the study will be following the DfT’s webtag appraisal system. This requires that, following problem identification, a number of possible solutions will be thoroughly explored (not necessarily even all transport ones) and gradually filtered down to a few which are appraised in some depth.
5)We feel we have no option but to complain about the very short consultation period. The outgoing e-mail from WSP/Parsons Brinkerhoff and attachments requesting input was circulated on February 15th, requiring a response by February 26th, ie. no later than the 25th. Just 10 days. This is a poor show. It does not set the scene for a robust study.
6)Assumptions are made that new roads equal economic benefits, despite empirical evidence that there is no automatic connection in a mature economy such as that in the UK. We refer you to the Standing Advisory Committee on Trunk Road Assessment report ‘Transport and the Economy’ (1996) which showed that this is not necessarily the case.
7)Many of the questions are leading ones and there are none asking stakeholders for their opinions about the value they place on the environment.
8)Stakeholders are not provided with any evidence, reports or even electronic links as a starting point (eg. the amount of traffic accessing the Port of Workington), merely a simplistic map which does not show flood plains or historic assets or specially protected sites and which does not depict the latest extensions to the National Parks.
9)Notimeline has been provided for the study and no project manager is named.
10)No explanation is provided of how this study fits with the Northern TransPennine Study currently being conducted by the DfT, HE and Transport for the North and, very worryingly, the Lake District National Park are not listed as a stakeholder.
These are very major and fundamental concerns. We sincerely hope they will be addressed.
Consultation Questions
A Importance of the identified routes
A1 How important are the routes to the day-to-day operation of your organisation?
Most of the routes identified in the study have a major impact on the Lake District National Park. In particular routes 2,3,4,6 and 8 all traverse the National Park. As such it is both surprising and disappointing that the Lake District National Park Authority, as the statutory body responsible for the protection of the Park, has not been included as a stakeholder.
Whilst these routes are not applicable to the day-to-day operation of any of the three organisations represented in this submission, any physical changes – particularly to those routes in or adjacent to the National Park – are of major interest to us. The Lake District National Park offers some of the most spectacular and precious landscapes in England. As champions of countryside protection and sustainable transport, we take action to protect and conserve such a special area. That said, for clarification, we are not direct-action organisations. We make our case through official processes.
A2 If any of these routes became more congested, do you think that this would have an adverse impact on your business/organisation?
Increased traffic congestion produces adverse impacts in terms of noise, air pollution, run-off and severance. The National Park in particular needs to be a tranquil, environmentally enjoyable and healthy area but the issues of sustainability and of poor air quality concern us generically.
We do not believe that the answer to traffic congestion is to build more highway capacity. This merely induces more traffic movements as was demonstrated by the Standing Advisory Committee on Trunk Road Assessment (SACTRA) in their seminal report‘Trunk Roads and the Generation of Traffic’ (1994). The sound answer lies in a whole series of more sustainable measures. Not only improved public transport and better planning but a series of smart measures such as high quality broadband facilities everywhere, very well-honed freight logistics, better co-ordination between tourism and event co-ordinators, safe routes to school and a recognised official network of quiet lanes and cycle routes. And, where necessary, localised highway safety improvements.
B Route reliability
B1 In your experience/knowledge, how reliable are the routes in terms of journey time?
Focusing on the routes located within the Lake District National Park, from our experience we consider that reliability of journey time is generally good on all routes except at very specific times on the A595 due to Sellafield shift changes (which would be helped by more rail rolling stock) and very occasional slow traffic on the A590 due to heavy tourist traffic.
B2 Do you recall occasions on which any of the routes have closed in recent times?
Route 6 was closed due to heavy snowfall in March 2013.
Route 3 northbound is currently closed at Bassenthwaite due to landslips after Dec 5th flooding necessitating a contraflow on the southbound dual carriageway.
Route 4 was closed in November 2015 to remove debris from flooding.
Route 8 where the A591 and A590 diverge has issues with surface water flooding.
B3 Are there reliability issues on any of the routes during adverse weather (high winds, flooding)?
The routes identified as part of the study are susceptible to flooding and investment should be made to increase resilience.
B4 When the routes are closed, does this have a financial impact on your organisation?
No.
C Safety
C1 Are there any particular parts of these routes that you consider to have safety issues?
Whilst we are aware that Route 8 and Route 2 have safety issues and the latter has visibility issues, this is not the way to start a discussion with wider stakeholders on this important topic. We are aware of the ‘CrashMap’ website which provides detailed information of the location of fatal accidents and incidences of collisions involving serious and slight injuries. However, many stakeholders would not be. As the consultants running this study, you should be providing information of where the accident hot spots are, putting forward a choice of possible solutions and also asking for ideas for solving those particular local problems. Quite often, the answers to such problems lie in localised traffic management solutions such as speed reductions and/or the provision of D turns at difficult right-turning junctions. The answer is not always road widening across a length of carriageway.
C2 Which sections of the routes do you consider to be least safe for users?
From a perception point of view, we would flag upRoute 8 at Haverthwaite turning off the A590. There is currently a very short section of dual carriageway at this location which would be safer if it was a single carriageway (which could be achieved by road markings). However, our fuller answer to this question would really be a repetition of that we provided to the previous question.
D Specific Traffic Issues
D1 Where do you consider the main traffic ‘bottlenecks’ to be on these routes?
Here again, stakeholders are being asked to provide answers to questions which will merely amount to personal experiences in many instances. The consultants should be providing the necessary traffic flow information. It might have been more useful to ask stakeholders if their particular journeys could be made at different times or by different modes.
D2 In your experience, are there sections of these routes that have issues with speeding traffic?
The consultants must know, or ought to know, the answer to this question. We are aware that Routes 2,3,4,7 and 8 all have issues with speeding. Routes 2 and 8 are particularly notable for incidences of speeding related accidents. One successful method of controlling speed over distances is to introduce average speed cameras. However, this can present a problemwith visual impacts in special areas. But, with careful siting, it is a possible solution worth exploring. It has proved successful on the A537 near Buxton in the Peak District National Park.
E Wider effects of the routes
E1 For longer distance (UK wide) traffic, to what extent do these routes provide essential connections to the wider strategic road network?
As is well recognised, the A66 and A590 and Routes 1 and 2 are all primary routes.
E2 Do you consider that there are any constraints to making improvements to these routes?
There are significant environmental constraints to making improvements to these routes:
- The Lake District National Park – Paragraph 115 of the National Planning Policy Framework states that:
“ Great weight should be given to conserving the landscape and scenic beauty in National Parks…which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important consideration in all these areas, and should be given great weight in National Parks…”
Routes 2,3,4,6 and 8 are located within or directly adjacent to the National Park. New infrastructure on these routes and an associated increase in user volume would have a significant detrimental landscape impacts, as well as, increases in noise and air pollution.
Route 3 is located within the ‘North Distinctive Area’ of the Lake District National Park as defined in the 2010 LDNP Core Strategy. The route is identified as a functional link between Keswick and Cockermouth. Policy CS04 sets out the approach adopted by the LDNPA for this area. The policy states that the LDNPA ‘will support initiatives that reduce the need to travel’ and protects the redundant railway line between Keswick and Penrith as a sustainable transport route.
The core strategy identifies that there is limited capacity to accommodate change without compromising landscape character in this area and that highway design does not always respect the rural character of the roads. Furthermore the core strategy states that: ‘Improvements to the A66, and other roads, present topographical and landscape impact challenges.’
The vision for this area by 2025 is to:
“Protect the distinctive character of the North, and conserve the integrity of the diverse patchwork of habitats, historic landscape and character of the vernacular built environment.
Protect visual amenity including views in to and out of the area.
..to reduce traffic growth and protect Environmental quality through traffic management schemes….this incudes finding solutions to the relatively high traffic volume and speed on roads over the high fells.
To encourage others to provide demand-responsive transport services”.
Route 4 is located within the ‘East Distinctive Area’ of the Lake District National Park as defined in the 2010 LDNP Core Strategy. Policy CS05 sets out the approach adopted by the LDNPA for this area.
The policy states: “We will support initiatives that strengthen the sustainable transport links between settlements in the East area with Penrith, and that reduce non-essential travel especially by car-based visitors between the East and Central/South area. We will work with others to improve public transport and community transport services across the East Distinctive Area”.
Issues identified for this area include the volume of traffic on the A592 and the A66 and that traffic on these busy roads detracts from the general tranquillity of the area.
The vision associated with this area by 2025 states that the “A66 will continue to provide the main access to the North distinctive area but, some of the road-based traffic will have shifted to rail”.
Routes 6 and 8 are located within the South Distinctive Area. Issues identified within this area include the potential for further dualling of the A590 to have significant adverse impacts on the character of the surrounding landscape and a high sensitivity to noise and light pollution. This could result in a loss of tranquillity which is a key feature of the area outside main settlements.
- Natura 2000 designations, particularly Special Areas of Conservation –
As well as the considerations relating to the National Park designation there are a number of Special Conservation Areas (SACs) throughout the Lake District. SACs are areas which have been given special protection through the European Habitats Directive. Many of the routes identified in the study are adjacent to SACs which would constrain development. eg. A66 adjacent to River Derwent and Bassenthwaite Lake SAC, A590 adjacent to the Morecambe Bay SAC and the Witherslack Mosses SAC and A595 adjacent to the Drigg Coast SAC.
- Topographical constraints
The nature of the geography of Cumbria means that the routes are subject to topographical constraints. As previously highlighted route 3 is identified as having topographical challenges in the LDNPA core strategy. Route 6 is also particularly constrained topographically especially in the area around Duddon Bridge and Broughton in Furness as well as at Muncaster and Ravenglass as is route 7 and 8 at Greenodd, route 3 at Bassenthwaite and route 4 between Scales and Keswick
F Economic Growth
F1 Do you consider upgrades to these routes will be needed in the future and why?
F2 Do you feel that upgrades to any of these routes would be beneficial for the Cumbrian economy?
Road upgrades may provide some temporary benefits for some businesses operating within Cumbria. However, because new road capacity leads to an increase in traffic, any benefits are short lived. The key role of tourism in the Cumbria economy could be undermined by such upgrades due to the potential adverse impacts on landscape and tranquillity, two of the special qualities underpinning the tourism sector in the national park.
HThe Need for Intervention and Potential Solutions
H1 In your view, is it necessary for any of these routes to be upgraded? What are your reasons for this view?
Any future upgrades should only be considered as a last resort and should be designed within, and appropriate for, the landscape in which the road network sits. As such we do not consider that further dualling of routes or the development of major new roads infrastructure would be appropriate.