Posted at 12:24 PM in Current Affairs | Permalink | Comments (0)
Kent County Council has begun drafting a new transport policy for the next 15 years. LTP4 isn't much different from LTP3 -- the road section is built around the assumption that the motor car is still king, with no awareness of the need to change policies to cope with global warming, the threat of air pollution and the rise in obesity and diabetes.
That's no surprise. What interests me most is what will happen in Sevenoaks, already strangled by traffic. Can the district council finally get over its obsession with cars and car parking and promote sustainable transport for our gridlocked town and district? There are mixed messages. At the very last moment, SDC seems to have included cycle infrastructure in its wish list for the future, after telling me in a lengthy exchange of letters that it could do no such thing.
Reading closely the district council's response to LTP4, I have been struck by the level of confusion and contradiction over transport policy. Apart from more car parks, Sevenoaks seems to be clueless about what it actually wants for the next 15 years. I have written to the Chief Planning Officer Richard Morris in the hope of provoking some joined-up thinking.
Here's my letter:
Dear Mr Morris
I welcome the last-minute change of heart at SDC over inclusion of cycling infrastructure as a ‘future scheme’ in the district’s wish list for Kent’s LTP4. I would like to point out, however, that if your department had agreed to this initially in response to my letter of 13 July to Dr Ramewal, then a lengthy and time-consuming correspondence could have been avoided.
After examining the SDC response to the LTP4 consultation, I have a number of questions about the district’s approach to transport planning, which seems confused and contradictory. My concern is increased by the paper you prepared for the Health Liaison Committee meeting today 9 November.
Let me first deal with cycling. You say the district council ‘has had its Cycling Strategy in place since 2012’ as if this was something to boast about. In March 2017 the Strategy will mark five years since its approval, during which time no progress at all has been made towards implementation of the safe routes promised. Not a single cyclist has benefited from the hard work carried out by KCC, SDC and the Cycle Forum to draft this document. In our view this is primarily the fault of the district council, which has been happy for the Strategy to gather dust and has never pushed KCC to make it a reality. In arguing over and over again without success for S106 and other funding for the Cycle Strategy at JTB meetings over the past five years, I have found SDC councillors (with one notable exception) either indifferent or openly hostile. Since the afterglow of the Olympics and Paralympics faded, we have had no political support from SDC cabinet members at all. Sevenoaks still has the worst level of cycle infrastructure in Kent with no safe routes, while other districts such as Tunbridge Wells, where the local authority is more enthusiastic, are developing new plans. I refer you to the latest consultation on the KCC website for improved cycle infrastructure on the A26 through Southborough. I would like you to take the opportunity of the upcoming five-year review of progress on the Cycling Strategy to promise that implementation will have the full and enthusiastic support of SDC planners in future, so that the district can catch up with the rest of Kent.
There is a much more fundamental contradiction which emerges from your response to LTP4. While ostensibly supporting better air quality and lower congestion, SDC is actively pursuing transport policies which encourage the opposite. The 2010 Transport Strategy for the district included commitments to reduce private car use, but these have been abandoned in favour of expanding car parks in Sevenoaks town. It is accepted by all traffic planners that multistorey car parks are massive trip generators in their own right and lead to an increase in vehicle movements. In places such as Sevenoaks town centre, peak congestion is already worse than in many parts of central London. Bus operators say they cannot get school pupils to school on time. I hope you will agree with me that the argument put forward by some councillors that congestion is caused by motorists driving around looking in vain for parking spaces, has no basis in reality.
May I ask you to reaffirm that the district is still committed to the objectives set out in the 2010 Transport Strategy, which include a reduction in private car use? None of these objectives will be reached by building more car parks.
Your response to LTP4 is supportive of the idea of active travel (cycling and walking), but the reality is the opposite. The response makes clear that you only support the idea of active travel ‘within new developments’, implying that private car use will remain the preferred option everywhere else. Active Travel is not an add-on to existing obesogenic transport policies, but requires that they should change fundamentally in the interests of improved public health for everyone. This point seems very poorly understood at all levels of local government in Kent. You may not be aware that KCC’s Active Travel Strategy has been rejected as inadequate and weak by cycling organisations in Kent, including Sevenoaks Cycle Forum. We called without success on KCC to withdraw the initial draft and rewrite it.
The failure to understand active travel and the priority given to the private car have practical consequences for the decisions you take as planners. As an example, I note that one of the district’s priorities is ‘improvements’ on the High Street/Pembroke Road junction. This is no doubt linked to the forthcoming renewed planning application for the Buckhurst 2 multistorey car park, which was blocked in 2014 as unsustainable by Kent Highways because the junction was already over capacity. You will no doubt recall that SDC argued for the removal of the pedestrian green phase at this junction to speed up the flow of cars to the new car park. It appears that KCC has now dropped its objections. Will you please reassure me in your role as Chief Planning Officer that you will not recommend or accept any changes to this junction that will increase traffic flows at the expense of pedestrian safety?
My impression on reading your list of ‘transport issues’ is that you are aware of congestion and poor air quality, but you are unable or unwilling to accept that these are largely the result of the district’s own policies, rather than of divine intervention from on high or mistakes by Kent Highways. If you really want to tackle congestion and ‘parking concerns’, you have to seek alternative transport solutions that will reduce the need for private car use and reduce demand for parking spaces, rather than just increasing supply. If you are aware of developments elsewhere in the UK, you must know that many councils are demolishing their old multistorey car parks and switching to smarter and more sustainable travel solutions. The idea that town centres must encourage car use in order to be ‘vibrant’ is a myth, whatever retailers in Sevenoaks may think. Towns that manage to reduce congestion and provide a pleasant shopping environment for pedestrians and cyclists thrive, while those like Sevenoaks that are strangled by motor traffic risk decline. You appear to acknowledge this risk of gridlock in the passage about Westerham, but I would like you to explain why it is not seen as a similar problem for Sevenoaks town. It is apparent to me that SDC’s ambition to generate more revenue from parking, while understandable, has distorted its transport priorities against sustainability, carbon reduction, air quality and active travel. You cannot have it both ways.
It is no doubt correct to complain about a historic lack of investment in West Kent. However, my experience as a regular attender of JTB meetings for the past six years suggests that Sevenoaks gets a small slice of the cake largely because it has put forward no coherent ideas on transport policy. Other Kent districts do better in attracting funding because they have a clearer idea of what infrastructure they want.
In the final section, the references to air quality as an issue are welcome, but it seems out of place for SDC to complain to KCC about this when air quality is its own statutory responsibility, rather than that of the county. Councillors are mostly poorly informed on the current state of the scientific debate on air quality and the rising concern about the threat to health in the very young from fine and ultrafine particles. There has been a tendency to say as little as possible about the poor air quality in Sevenoaks. SDC failed to even publish its annual air quality monitoring report between 2009 and 2015, and finally did so only in response to a complaint from me. There is a mistaken view among councillors that poor air quality comes from elsewhere, and that the district can do nothing about it. My examination of the data from Sevenoaks town leads to the opposite conclusion: background air pollution from the motorway network and other HE roads is moderate (below 20 microgrammes of NO2 per cubic metre at Greatness) while it rises to up to 55 at some roadside and kerbside monitoring sites in the town centre. (pp29-38 of the USA monitoring report 2015). The AQMAs in Sevenoaks town where NO2 emissions exceed the EU limit of 40 microgrammes have been declared because of emissions from local traffic on the major roads through the town centre, the A25, the A224 and the A225, not because of pollution from motorways.
You must be aware that when I and others raised air quality concerns over the Bradbourne Park Road car park planning application, our concerns were dismissed by the Environmental Health officer and by your planning officers on the grounds that the site was ‘not in an AQMA’. Technically, this is correct, but it is irrelevant. For residents worried about the health problems posed by emissions and threatening their children, the question is not the precise siting of new developments, but how many extra vehicle movements through the existing AQMAs will be generated. On the A224 London Road, the new hotel, the multistorey Bradbourne Park Road car park and the refurbishment of the Tubs Hill flats will when complete together generate several hundred more vehicle movements a day. As the area is already congested, with NO2 levels just below the threshold of 40 microgrammes, the result may be to create yet another extension to the AQMAs on the A224 London Road.
The previous planning application for the Buckhurst 2 car park also used the argument that the site was ‘outside’ the nearest AQMA, ignoring the fact that every single vehicle using the multistorey would have to travel through the AQMA covering the High Street/Pembroke Road junction, adding extra pollution. Can you please reassure me that, whatever the Environmental Health Officer says, SDC planners will not accept this misleading argument again when the application is resubmitted?
This lack of joined-up thinking at SDC on transport and health is also evident in the paper you have presented to the Health Liaison committee on November 9. I am astonished to read a policy statement on planning and health which is so weak and poorly researched. It fails completely to consider the twin threats to public health from transport. You do not seem to be aware that the first of these is poor air quality, which is estimated to cause more than 50 premature deaths annually in Sevenoaks district. The second is the rising cost to the NHS of physical inactivity and obesity, which is linked to a high level of private car use and a failure to encourage walking and cycling. This paper shows that whoever has drafted it is not up to speed on any of the recent academic research on active travel, health inequalities and transport. I know that local councillors are generally poorly informed on these issues, but I do not see how they can have an informed debate when they are given briefing papers like this one.
With the possible exception of the health threat from diesel particulates, all the above issues were addressed in the 2010 Sevenoaks district transport strategy, which contains several recommendations on modal shift that could usefully be followed today, including car-journey sharing and a reduction in travel levels and traffic speeds, and reallocation of road space to other modes. The sections on walking and cycling are also still relevant, as is paragraph 17.3 which argues for a balanced approach to parking management.
I look forward to your explanation of how these contradictions will be resolved in the new Sevenoaks Local Plan.
Yours sincerely
John Morrison
Posted at 12:32 PM in Current Affairs | Permalink | Comments (0)
Here's my comment objecting to Sevenoaks District Council's Sennocke car park scheme by the station on grounds of increased congestion and damage to air quality:
Sennocke Hotel Development: Objection by John Morrison 19 Bayham Road Sevenoaks TN13 3XD
This is the third planning proposal for a major development by SDC where no proper air quality assessment has been offered. Until the air quality impact of the extra traffic generated in nearby AQMAs is properly estimated, this development should not be permitted.
If it is permitted, then one of the conditions attached should be implementation of the planned cycling routes to Sevenoaks station set out in the 2012 District Cycling Strategy, in order to mitigate the impact of increased traffic around the station.
Posted at 12:03 PM in Current Affairs, Travel | Permalink | Comments (0)
I have written to Richard Morris, head of planning at Sevenoaks District Council, about the flawed figures for traffic movements he has endorsed in his report on the proposed Bradbourne Park Road multistorey car park. This scheme is likely to get the green light from SDC's Development Control Committee on June 16 unless enough Tory councillors show independence and oppose it. There have been hundreds of objections from local residents and the town council has voted against it; I think there will be much wider effects on congestion and air quality across Sevenoaks Town if it goes ahead. Here's my letter (apologies for the length but air quality is complicated):
Dear Mr Morris
I write in connection with the planning report you have signed off for the Bradbourne car park in advance of the Development Control committee meeting on June 16. In my view your assessment seriously underestimates the increase in vehicle movements that will be generated by this development and fails to assess adequately the serious air quality problems that will result.
There are methodological flaws in the Transport Assessment and the initial application which KCC does not seem to have detected. In particular, the figure of 65 additional parking spaces has been used to predict additional traffic movements.
This figure is not a reliable baseline guide to future movements of vehicles in the area. It rests on the assumption that all the commuters with permits displaced by the proposed reduction in on-street parking will obediently move into the new car park. However it is not credible that all of them will meekly accept a 45% increase in their annual parking charge. Those who do not will still drive into Sevenoaks and seek to park elsewhere. The places in the new car park will be bought by a new cohort of commuters – those on the waiting list for a season ticket – who can afford it. The result will be a far higher number of total commuter vehicle movements towards the station, which will exacerbate parking problems in other residential streets.
The statements made on the proposed changes in on-street parking are inconsistent. It is stated that 70 spaces will be removed out of 300, and that 70 commuter permits will be withdrawn, but it is also stated that the changes will free up space for residents and short-stay users, implying that the 70 spaces will remain in use with different restrictions. This switch to short-stay use has implications for total vehicle movements in and out of the area, which will increase. Nowhere in your assessment do you examine this.
I appreciate that planning law obliges you to focus on the movements in and out of the car park rather than over a wider area. However even these narrow calculations are flawed and misleading. All the estimates given for traffic movements are based on one peak hour in the AM and one peak hour in the PM which include just a fraction of total movements over a 24-hour period. The result is a considerable underestimate of the numbers and thus of the environmental impact, particularly on air pollution.
It is completely unacceptable to state that no air quality impact assessment is required for this development because it is technically not in an AQMA. Virtually every vehicle accessing the site will have to travel through an AQMA. The vast majority of the commuters using Sevenoaks as a railhead drive a considerable distance, using the A25 through Seal or Westerham and the junctions at Bat and Ball and Riverhead, or drive from the south through the High Street and London Road. All of these routes are AQMAs, which means that NO2 emissions exceed the permitted level of 40 microgrammes per cubic metre. As you are no doubt aware, this figure is measured once a month and produces an annual mean. It is based on total daily emissions measured by diffusion tubes, not on a peak hour snapshot.
If you look in detail at the SDC Air Quality 2015 USA Report, there is a break in the continuous AQMA line along the A224 in the vicinity of Sevenoaks station. This is because there is no monitoring at that point, which is around 200 metres from the car park site. If there was, it is highly likely that the average reading would exceed the permitted level.
The break between AQMAs starts on Amherst hill to the north and ends just before Eardley Road to the south. Readings for NO2 from these sites near Eardley Road are only just below the critical level:
DT51 (130 London Road) 39.2 microgrammes per cubic metre
DT52 (142 London Road ) 39.6 microgrammes per cubic metre
A few hundred yards to the north, the equivalent reading already exceeds the objective:
DT77 (Montreal Road) 42.8 microgrammes per cubic metre
It is fair to assume that if NO2 levels were measured at the traffic lights by Sevenoaks station, the readings would be higher because of congestion at this junction. It is also fair to assume that the additional traffic movements generated by a multi-storey car park in the immediate area of the station will raise emissions further and lead in due course to an extension of the AQMA along this entire stretch of the A224. This outcome does not meet any definition of sustainable transport, nor the district council’s obligations to improve public health.
My research leads me to question the complacent report on air quality issues by your Environmental Health officer, who concluded that the impact will be minimal. In a situation where almost half of the kerbside and roadside monitoring points in Sevenoaks urban area – many of them close to schools -- exceed the national air quality objective for NO2, then every extra vehicle movement producing emissions is by definition excessive. I would like to remind you that more than 50 people die early in Sevenoaks district each year because of poor air quality.
Before ending this letter I would like to refer to condition 15 which concerns a requirement to promote alternative transport links to Sevenoaks station. As joint co-ordinator of the Sevenoaks Cycle Forum and one of those who drafted the 2012 Cycle Strategy for the district, I have to remind you that this included a number of safe cycling routes to improve commuter access to Sevenoaks station. Over the past four years SDC has shown zero interest in implementing any of these safe routes, which its planners helped draft; nor has it shown much interest in improving bus travel to the station.
The Bradbourne car park scheme on its present scale seems to be motivated above all by the council’s desire to maximise revenues from parking by increasing supply, which can only happen at a high environmental cost. Instead of reducing private car use as most local authorities are seeking to do, Sevenoaks seems determined to increase it in the mistaken assumption that a congested town centre full of cars is more ‘vibrant’ than one that welcomes pedestrians and cyclists. The latter do not boost the council’s parking revenues, but neither do they emit NO2. Bringing in yet more rail commuters who contribute nothing to the Sevenoaks economy apart from buying a morning coffee is pointless when peak hour Southeastern trains to London are already over capacity.
My advice to you is to scale back this scheme and make it a decked two-storey car park, which would roughly replace the spaces lost from the Sennocke redevelopment without causing a large increase in traffic movements. I look forward with interest to your presentation on June 16 and I hope you will address in detail the points I have raised.
Yours sincerely
John Morrison
Posted at 11:10 AM | Permalink | Comments (1)
Kent County Council’s draft Active Travel Strategy, presented to the Environment and Transport Committee on May 4th 2016, is the weakest and most inadequate paper I have ever come across in more than 45 years of reading public documents as a journalist. Sevenoaks Cycle Forum got together with other cycling organisations in Tunbridge Wells (TWBUG), East Kent (SPOKES) and groups campaigning for 20sPlenty to tell councillors it should be withdrawn and rewritten. Needless to say, our views were ignored and the 'strategy' has now gone out to public consultation. You can use this link to send in your views.
So why are we so critical?
The document is woefully under-researched and appears to have had no meaningful input from the county’s Public Health team. It is not clear if their advice has been rejected, or if they had nothing to contribute. It does not analyse the overwhelming positive economic case for active travel, and it ignores experience from other local authorities who have years of experience in implementing Active Travel policies. The paper does not reflect adequately the rising public concern over air quality, which is moving fast up the agenda for authorities addressing public health. It fails to crunch the numbers on how pupils travel to school across the county. Extensive information about Active Travel is available from academic experts such as Danny Dorling and Nick Cavill (Oxford University) and from charities and informed groups such as 20sPlentyforus, Brake, Living Streets and Sustrans. Experts agree that the single policy shift needed to bring about an increase in cycling and walking is a reduction in traffic speeds , and in particular, the widespread introduction of area-wide unsigned 20 mph limits (not zones) in all urban areas. KCC’s paper omits these 20 mph limits altogether, ignoring what the medical profession universally recommends as the essential core of any Active Travel policy.
This document is a collection of meaningless platitudes and aspirations which does not merit the title of ‘Strategy’. It lacks any targets and any funding mechanisms, and it is clear the authors have not understood that some existing KCC policies are incompatible with Active Travel and will have to be changed to bring it about.
These existing policies are deeply ingrained and will require an overwhelming and self-critical culture change within Kent Highways and among councillors, including a willingness to abandon the complacent idea that ‘Kent knows best’ and learn from experience elsewhere. KCC is one of the few local authorities that still gives priority to the needs of motorists, in particular cutting their journey times, over sustainable transport and the needs of vulnerable users. A complete reversal of this mindset is needed. Active Travel policy is primarily a public health issue and is too important to be left to the wisdom of traffic engineers whose primary training is in moving vehicles around the road network as expeditiously as possible.
The idea that this document might establish Kent as a ‘pioneering county for active travel’, as suggested in the introduction, is just laughable. Councillors must recognise that KCC is lagging years behind other local authorities in its understanding of sustainable transport and its links with public health, and has a long way to catch up. This paper suggests that joined-up thinking at KCC has yet to get under way.
The existing KCC policy on 20 mph limits, approved in 2013, should be withdrawn and rewritten as it opposes area-wide limits and places a series of obstacles to introducing them across the county, including erroneous unsourced estimates of their excessive cost. Until this happens no Active Travel Strategy will be achievable.
The other major policy document that has to be revised is the 2014 Casualty Reduction Strategy, which is failing to achieve results, even in the narrow terms in which it is written. Kent’s disastrous road casualty record is getting worse, and compares very badly with that of other shire counties in England. For more details, see earlier posts on my blog.
Casualty reduction, while important, is a limited approach to road safety and conflicts with the goal of Active Travel, which has to be based not on reacting to crashes and casualties but on reducing road danger. The route to Active Travel is incompatible with the current KCC road safety doctrine of CRM (Crash Remedial Measures) and requires a different approach. Under CRM a road avoided by cyclists and pedestrians is likely to have zero cycling and pedestrian casualties, and therefore a ‘good’ safety record. Active Travel policy means removing the barriers which prevent people making journeys on foot and by bike. Research shows that perceptions of safety improve with the existence of dedicated infrastructure such as cycleways and pedestrian crossings. Where these are not possible, reducing traffic speeds is essential.
My experience of three years leading a Community Speed Watch group in Sevenoaks has taught me that KCC does not see speeding as a priority problem, although lip service is paid to reducing it through propaganda and education. The lack of meaningful enforcement currently means that speeding drivers can break the limit with impunity. A change in policy has to involve the police, but more importantly a greater use of safety cameras. Active Travel requires a change in policy at the Kent and Medway Safety Camera partnership to permit the installation of fixed cameras at more sites, particularly in urban areas. At present the policy is that cameras cannot be sited unless there is a serious record of injury crashes over a three-year period. This in effect makes it impossible to site new cameras in urban speeding hotspots. The message to speeding drivers seems to be that they can continue, providing they do not crash. If Active Travel is to become a reality in Kent, then this indulgent attitude to speeding on 30 mph roads where people live and work has to change.
Although KCC's committee allowed Adrian Berendt of TWBUG to address the meeting, the subsequent debate was very disappointing. Nobody seemed to grasp the essence of what active travel is about, or the fact that it requires a change in existing transport policy. An active travel policy for Kent is essential, but KCC's current attempt to create one will go nowhere.
I attach a list of references to a small fraction of the existing mainstream literature on Active Travel, most of which the authors of this paper have apparently failed to find.
http://www.brakepro.org/library/road-safety-research
http://www.livingstreets.org.uk/
http://www.20splenty.org/foundation_for_active_travel This is one of many briefing papers on the website
http://www.20splenty.org/briefings
http://cycletoworkalliance.org.uk/news_43_1470779177.pdf Report on the health benefits of cycling to work, written by a Sustrans expert
https://www.gov.uk/government/publications/future-of-cities-active-travel
http://www.bma.org.uk/working-for-change/improving-and-protecting-health/transport British Medical Association study
http://www.fph.org.uk/uploads/Take_action_on_active_travel.pdf Federation of Public Health paper
http://www.apho.org.uk/resource/view.aspx?RID=90297 (This is the Active Travel Strategy issued by the last Labour government shortly before the 2010 general election)
https://tfl.gov.uk/cdn/static/cms/documents/jta-active-travel.pdf Transport for London’s strategy for Active Travel
http://www.cyclingscotland.org/partners/active-travel-active-scotland
http://slideplayer.com/slide/8767112/ Presentation to local authorities by Dr Nick Cavill on increasing cycling and walking
http://www.britac.ac.uk/policy/Health_Inequalities.cfm This is a link to Professor Danny Dorling’s influential lecture on the social and health benefits of a shift to 20 mph area-wide limits.
http://www.nwatn.org.uk/march-2013-seminar/ One of a series of conferences on active travel held in the North West of England
http://blackpig.typepad.com/kent_road_safety/2015/09/index.html Comparative analysis by John Morrison of Kent’s road safety record with that of other similar counties. Kent’s record deteriorated in 2014 for the third year in a row.
Posted at 01:09 PM in Current Affairs | Permalink | Comments (0)
I have sent in my objections to the plan, largely based on traffic considerations. It should be fairly obvious that a big multistorey will worsen congestion and damage air quality. SDC's ambition is to maximise parking revenue at the expense of the health of the children of Sevenoaks town. It has refused to consider any alternatives to expanding private car use.
I object to the proposed car park development on the following grounds:
The summary states that the car park is ‘unlikely to generate significant additional levels of traffic’ because a large proportion of predicted users will already be parking elsewhere in the town’s short stay car parks. If they are rail commuters to London, they cannot use the short stay car parks without incurring heavy penalties. It is more probable that the expanded car park will be a trip generator attracting more rail commuters to Sevenoaks from outside the town, with a negative impact on air quality.
Local authorities have a legal duty to take air quality into account when determining planning applications. Failure to do so can lead to a planning decision being subject to judicial review. Air quality readings for NO2 show that local traffic levels in Sevenoaks already exceed the legal limit of an annual mean of 40 microgrammes per cubic metre. Public health data show an estimated 57 early deaths every year from poor air quality across the district. Sevenoaks does not at present monitor pollution from particulates, which are believed to be the most dangerous pollutants from road traffic. Where legal limits are already being exceeded, ANY increase in pollutant levels from traffic generated as a result of development must be regarded as excessive. It is therefore unacceptable to avoid doing a full air quality impact assessment and opens the decision to potential legal challenge.
While motorists wanting a parking place have their needs prioritised, the needs of cyclists for safer routes to Sevenoaks station have been completely ignored. There is no mention in the Transport Assessment of the 2012 district Cycling Strategy, which includes a proposed route for station commuters along Bradbourne Park Road. This route, like all the others in the strategy, has not been implemented, despite commitments made by SDC as far back as 2010 in the district strategy for transport (quoted in para 4.6 of the TA). The key paragraph 4.6.2 in this strategy states that new parking places “need to be balanced with the provision of improved accessibility by public transport, walking and cycling”. This requirement for balance in transport planning is also built in to Kent County Council’s LTP3 Chapter 11, which includes carbon reduction and Smarter Travel, and is based on reducing private car use. The SDC policy of meeting commuter demand for more parking spaces, thus encouraging more private car use, is diametrically opposed to these objectives and principles. The test set out in the NPPF of whether “opportunities for sustainable transport have been taken up” (TA para 4.1.2) has therefore not been met in the case of this planning application.
In section 5, it is assumed that all the trips made by vehicles currently using the 70 on-street parking bays due for removal will transfer to the new car park. This is not backed up by any evidence. The on-street parking bays in Hitchen Hatch Lane, Bradbourne Park Road and Mount Harry Road are mostly used in the daytime by permit holders for long-stay parking. The current annual cost of a non-resident permit for this area is £765. No figure has been given for the annual cost of a season ticket for the proposed multistorey car park, but it is unlikely to be less than the current £1,110. It is far from certain that all these drivers will want to pay the 45% extra, and the rationale for making them move appears to be purely financial. The displaced commuters are more likely to compete for the remaining 230 on-street bays, or move to residential streets further away where parking is currently not controlled. This means that the extra spaces in the new multistorey park will draw in a new cohort of rail commuters numbering far more than the predicted 50. The net level of vehicle movements through the congested AQMAs into Sevenoaks will therefore be higher than predicted in the TA.
The definition in para 5.2.2 of a ‘peak hour’ in the afternoon between 1600 and 1700 in which only 25 vehicles currently leave the Bradbourne car park is unreliable. Anyone familiar with Sevenoaks station knows that the peak hours for commuters returning from London are between 1700 and 1900. This is also the peak hour for congestion on the A224 northbound as workers drive home from the town centre past the station. It seems unlikely that the PM departures from a car park with more than 200 spaces can possibly peak at an hourly figure of only 25 when the arrivals in the morning peak are 70. Unfortunately, all the subsequent calculations of traffic movement are based on this figure and on the 1600-1700 time slot. It appears from the car park beat survey (Appendix F) that no measurements of vehicle movements were taken after 1830.
This leads to a more serious methodological problem with the figures on vehicle movements. Appendix J is supposed to give a summary of total vehicle movements in and around the site. But it is not a total, just a summary for the 1600-1700 period. Appendix F shows that at 1710 the car park still has 187 spaces occupied out of 215, so most vehicle movements are taking place much later.
It is highly misleading therefore to use these figures as the basis of a model for total vehicle movements and total vehicle emissions. Pollution levels from NO2 are generally calculated on a 24-hour mean, so there is no foundation for using partial data for a single hour in the morning and a single hour in the afternoon to say there will be no significant impact on air quality. These calculations must be revised.
CONCLUSION
For the reasons outlined above, this planning application needs amendment and should not be allowed to proceed without:
A compromise solution would be to add only one level rather than two to the Bradbourne car park. This would add a maximum 100-125 spaces to compensate for the 80 spaces lost at Sennocke and the estimated 20 needed to serve the new hotel. Removing 70 or more on-street parking spaces is likely to lead to unpredictable outcomes, and requires further study.
Posted at 06:32 PM in Current Affairs | Permalink | Comments (0)
Air Quality Issues in Sevenoaks November 2015 Updated Jan 2016
John Morrison November 2015 / January 2016
Posted at 12:18 PM | Permalink | Comments (2)
Last Tuesday's meeting of the Sevenoaks Joint Transportation Board delivered a brutal slap in the face to anyone in the town who wants to get out of their car and get around on foot. District and county councillors sent out an unequivocal message that they don't give a hoot about pedestrian safety. For some of them, it seems walkers have no right to be on the road at all in our increasingly congested town.
So what exactly happened?
Hollybush Residents Association got together earlier this year to get up a petition to slow down the traffic in Seal Hollow Road to allow people on foot to cross in greater safety through the 'Hole in the Wall' door into Knole Park. This route is used by hundreds of people a day -- jogging, exercising their dogs, pushing toddlers in pushchairs, leading their children on bikes or just going for a walk in the park. It's the only pedestrian route into the park from the northern part of town, and its status as a public right of way goes back many decades. There are regular jogging groups who use it every week, including pupils from nearby Walthamstow Hall School.
I helped collect signatures from the people passing through the solid oak door, most of whom told me they felt they were taking their lives in their hands. We collected more than a thousand signatures (this wasn't an online petition), and we got almost 100 per cent support from local residents when we knocked on their doors. Many householders in the Hollybush area told us they felt the route into the park was now so hazardous that they had stopped using it. This was particularly true of parents of young children, and of the elderly and less mobile.
So what's the problem with Seal Hollow Road? Why do residents see it as unsafe? The volume of traffic on this historic B road has grown sharply over the years, and it is now the main eastern route in and out of Sevenoaks town from the A25. There's a 30 mph limit which is widely ignored on the straight stretch (I know this as leader of a Speed Watch team), but at the crossing to the Hole in the Wall the road gets narrow and the mean speed drops to just under 30. Of course, some vehicles drive much faster than that. The danger to pedestrians in this twisting narrow section of road comes above all from poor visibility; on one side is the ragstone wall of Knole Park, and on the other a steep bank of vegetation; the pavements are less than a metre wide and taper to almost nothing at the crossing point. There are two warning triangular signs 150 metres away from the crossing, but there are no signs on the spot and anyone waiting to cross on foot is invisible to motorists from more than 20 metres away. Pedestrians have to listen hard for oncoming traffic becase they cannot see it coming. And these pedestrians include mothers walking their children to primary school.
There is no room here for a zebra crossing, so we asked for another way of slowing down the traffic, possibly through warning lights or, as an absolute minimum, through improved signage. My personal view is that there is a strong case for going much further with a 20 mph limit, backed up by some kind of vertical calming, along the entire length of the stone wall, between the Knole golf club and the Vine cricket club. This would enhance the safety not just of pedestrians crossing into the park to access the public right of way but also of those using the narrow footway to and from the town centre. This would probably require the road to be declassified -- it would lose its status as a 'B' road. Motorists might find their journeys taking 20-30 seconds longer, but they would be safer too.
The petition was presented by HRA chairman Jim Purves at the September 2014 meeting of the Joint Transportation Board, which brings together a dozen or so councillors four times a year to coordinate transport issues between Kent County Council, which is the highway authority, and the district council. We were cautiously optimistic, hoping that at the very least, engineers would visit the site with us and we could debate possible solutions. After all, 2014 is the year KCC is officially launching an Active Travel policy aimed at getting people to walk more and drive less for the sake of their health.
In the event, our hopes were completely dashed. Senior highways officer Tim Read wrote to the JTB to say the worries about pedestrian safety were not worth investigating; there was no speed problem and they couldn't find any record of casualties, so no funds would be available to do anything. Case dismissed, end of story. We hoped that at Tuesday's meeting the assembled councillors might question this, or at least insist that KCC engineers leave their desks in Maidstone and carry out an on-the spot assessment of pedestrian safety. Jim Purves asked councillors to remember that this petition had been signed by more than a thousand people. Were they all wrong? I backed him up and Liberal Democrat Councillor Elizabeth Purves also spoke from the floor, asking whether the JTB wanted to wait for a pedestrian to be run over before acknowledging the problem.
Well, our arguments cut no ice at all. There wasn't even a shadow of a balanced debate. KCC Councillor Richard Parry said nobody was forced to use the crossing, implying that pedestrians should either stay at home or use their cars. And he accused Jim Purves and me of waging a party-political campaign. For the record, neither of us is a member of any political party, and the Hollybush Residents Association has a long tradition of strict political neutrality. Our local KCC member Margaret Crabtree tried to sound sympathetic, but crucially failed to offer explicit support, although she had agreed to fund a speed survey at the site. KCC's deputy cabinet member for transport Clive Pearman told the meeting he knew the route along Seal Hollow Road well as he used it several times a week. In his car, naturally. He also declined to give us any support and said our request for safety measures was not feasible. No district councillors on the JTB spoke. For the record, this is a committee on which only one political party is represented, reflecting the overwhelming Conservative majority in KCC and more locally in Sevenoaks. Our mostly car-bound elected representatives seem to share a consensus view that no motorist should ever be inconvenienced by a mere pedestrian. For them, 'Active Travel' means getting a firm grip of the steering wheel.
We have a pedestrian safety issue which everyone in the northeastern part of Sevenoaks knows has to be tackled. The only people who disagree are Kent Highways and our local councillors. At the root of this failure to protect pedestrians lies Kent's long-standing road safety policy, based on the outdated idea that the only way to measure safety is to count up casualty figures. If there are no casualties, the road in question is obviously 'safe'. Seal Hollow Road is a classic example of why this policy leads to a built-in bias towards motorists. Until councillors understand that roads in urban areas are for everybody, not just motorists, vulnerable users such as pedestrians and cyclists will continue to lose out. Or we choose a different set of councillors who show less disregard for the local residents who elect them and pay their council tax.
Posted at 09:14 PM in Current Affairs | Permalink | Comments (0)
Government figures on road casualties in 2014 show Kent trailing at the bottom of the class in casualty reduction behind other local authorities in England, with pedestrians and cyclists increasingly at risk.
Figures released on September 24 by the Department for Transport showed road casualties in England rose in 2014 over the previous year, but most local authorities still recorded fewer casualties than in 2005-9.
The only big English county in the south of England to fail to match the overall downward trend over a decade was Kent, with a paltry 1% fall in casualties from the average for 2005-9. Only neighbouring Medway did worse, with a 7% rise in casualties.
The average fall in casualties in the Southeast between 2005-9 and 2014 was 13%. In England as a whole the fall was 20%. Neighbouring Surrey reduced casualties by 14%, West Sussex by 9% and East Sussex by 13%. Some counties managed to cut casualties by nearly a third over the past decade, with Buckinghamshire down 32% and West Berkshire 25%. Counties in the Southwest did even better
Kent, as the largest county in the Southeast, recorded 6,303 casualties in 2014, compared to 5,830 in 2013. The local authority’s casualty record has now deteriorated for the third year in a row.
Kent and Medway also scored badly against other local authorities when casualty rates per billion vehicle miles were measured. The casualty rate for Kent showed a fall of only 2% in 2014 over the rate for 2005-9, while Medway recorded a 3% increase. Overall, the Southeast showed a 12% drop in casualty rates using this yardstick. The average improvement in England was 20%.
The DfT statistics suggest Kent residents are at higher risk of becoming road casualties than elsewhere. The casualty rate per million population in Kent was 4,600 in 2014 compared to an average for the Southeast of 3,526 and an average for England of 3,222. However Surrey scored even higher with a casualty rate of 4,772 per million.
Kent’s record for reducing child casualties was no better. While England as a whole cut child road casualties by 29% between 2005-9 and 2014, Kent managed only a reduction of 10%, the lowest of any county in the south of England. The southeast as a whole achieved a reduction of 23%.
Cyclists and pedestrians appear to be disproportionately at risk in Kent. The county recorded 673 pedestrian casualties last year and 478 cycling casualties, second only to Surrey with 647.
The detailed figures for Kent alone in 2014, released at the end of August by KCC, show that in some areas, notably pedestrian and cycle safety, the county is recording sharply increased casualties compared to a decade ago, despite safer vehicles and more advanced NHS accident and emergency treatment.
The total number of KSI jumped by 11% from 2013 to 2014 -- an increase for the second year in a row. 658 people were killed or seriously injured. This means the county is now 33% above its 2020 target of a reduction to 495 casualties. Deaths rose from 48 to 49.
Collisions were up 7% despite non-stop road safety campaigns by Kent Highways telling drivers to be more careful. Motorcycle collisions rose from 547 in 2013 to 601 last year.
Collisions involving cyclists rose from 441 in 2013 to 480 in 2014, which is 126% above the benchmark average of a decade ago. Kent uses an average from 2004-2008 to measure progress in casualty reduction -- which now seems to have gone sharply into reverse. Cycling casualties are now running high above the level of 2004-2008, though part of this may be due to increased numbers of cyclists. Child casualties are also going up, though are still below the level of a decade ago. Half of the under-16 KSI casualties were children on foot.
Most of the collisions were on urban 30 mph roads. Kent has refused to follow other local authorities, including many UK cities, in lowering speed limits on residential streets to 20 mph. It has also said no to 20 mph limits outside all schools.
When the figures are broadened to include slight injuries, the picture is just as bad; Kent recorded 6303 casualties in 2014, compared to 5830 in the previous year and 5755 in 2012. Slight injuries to pedestrians went up to 673 in 2014, a rise from 631 in 2013 and 623 in 2012. Motorcycle injuries rose even more steeply, but injuries to car users also rose. Child casualties jumped to 570 (481 in 2013 and 502 in 2012).
The only improved statistic was a slight fall in the number of casualties among drivers aged 17-24, who have the worst crash records of any age group.
Kent's two major targets for 2020 are a reduction of 33% in overall KSI and a reduction in the number of children killed or seriously injured of 40%. To achieve the latter target, child casualties would have to fall to 39, a reduction of a third. Instead, they appear to be rising fast. The number of seriously injured children jumped from 45 in 2013 to 61 last year.
The 2014 Casualty Reduction Strategy drew criticism from cyclists and other groups for being too narrowly based and ignoring wider measures of road safety. The latest figures suggest that measured by its own chosen yardstick, the county is going to miss its 2020 targets.
Kent's data look particularly bad in a GB national context. Its 11% rise in overall KSI compares to a national 5% rise last year. However, the county says the long term trend is still for casualties to fall compared to the benchmark of the previous decade.
The figures seem to show that pedestrians in Kent are disproportionately at risk . While the the number of killed and seriously injured pedestrians rose 2% in Great Britain as a whole, the equivalent rise in Kent was 18% in 2014.
This analysis uses two sets of data – the DfT’s national Stats 19 release from 24 September, and KCC’s data set released at the end of August, which does not include any county-by-county comparisons.
The comparisons show clearly that other counties in the south of England are doing far better than Kent in reducing casualties.
Here’s a league table from the RAS30038 dataset published by the DfT, giving reported road casualties (killed, seriously injured and slightly injured) in each English local authority. It starts with the 2005-2009 average for all casualties, then gives the figures for 2010 onwards, and finally the percentage change between 2005-9 and 2014. To give a fair comparison, I have left out urban authorities and used 18 shire counties in the south of England. This table shows the best performing local authorities at the top and the worst at the bottom.
Local Authority Percentage fall/rise in casualties
Gloucestershire -44
South Gloucestershire -43
Bath/NE Somerset -37
North Somerset -34
Buckinghamshire -32
Somerset -32
Dorset -30
West Berkshire -25
Cornwall -25
Devon -25
Hampshire -18
Oxfordshire - 16
Surrey -14
East Sussex -13
West Sussex -9
Wiltshire -7
Kent -1
Medway +7
Posted at 09:50 PM | Permalink | Comments (0)
The number of killed and seriously injured on Sevenoaks district roads climbed again last year to 73, higher than a decade ago, with 7 deaths, more than any other part of Kent.
Road safety data for Kent and its districts published at the end of August showed an alarming overall 11% jump in killed and seriously injured (KSI) across the county. In Sevenoaks no children died on the roads, but there were 6 serious and 42 slight child casualties in 2014 -- higher than in the previous three years and above the baseline average of 2004-2008.
Most of the deaths, and the steepest rises in casualties in the district occurred on Highways England roads such as the M25 and M26 and strategic roads such as the dual carriageway A21, rather than on roads maintained by Kent County Council.
Altogether Sevenoaks recorded 547 road casualties last year, resulting from 385 collisions -- more than one for each day of the year. The district's 73 KSI casualties put it level with Ashford, just behind Maidstone, which recorded the county's highest figure of 74.
The district showed a slight fall in the number of collisions involving cars recorded in 2014 to 335 from 342 the previous year. Ashford and Dover recorded steeper falls, but in some other districts the number of collisions rose sharply.
But more car occupants were injured in Sevenoaks last year -- a total of 399 compared to 379 the previous year. The figure is still 7% lower than the average for 2004-2008, despite the recent year-on-year increase.
Motorcycle collisions in Sevenoaks fell last year from 52 to 47, a drop of 6%, while the overall number for the county jumped from 547 to 601. Serious motorcycle casualties totalled 19, the same as in 2013, but this was higher than the 2004-2008 average.
The district recorded a fall in the number of collisions involving goods vehicles in 2014.
The number of collisions involving pedestrians in Sevenoaks stayed roughly stable in 2014 at 32, after 34 in 2012 and 29 in 2013. Pedestrian casualties showed a similar pattern.
Cycle collisions, which rose across Kent to 480 last year, fell back in Sevenoaks to 37 after a sharp spike to 47 in 2013 from 14 in 2012. Cycle casualties also rose in all Kent districts except Dover, with Sevenoaks recording 38 injuries, 13 of them serious. The average rate of serious injuries in the district from 2004-2008 was only 2.
The district's 2014 total of 48 child casualties was sharply up on 2013, when only 27 children were injured, and on 2012, when only 22 were hurt on the roads. In Kent as a whole, 54 children were injured while cycling and 201 on foot. No breakdown of the figure by district was available.
The number of collisions affecting those aged 17 to 24, the peak age group for road casualties, fell in Sevenoaks, with 73 collisions compared to 88 the previous year and 113 in 2012. Casualties in this age group fell in Sevenoaks in 2014 to 84 from 103 the previous year and 133 in 2012. The peak was among 19-year-olds.
But within this age group across Kent there was a rise in injured cyclists to 77 from 67 the previous year and 48 in 2012. Motorcycle casualties were also up steeply to 217 from 163 the previous year and 173 in 2012. Injuries to car drivers and passengers fell.
Among the over-65s, collisions in Sevenoaks rose to 51 in 2014, which was 8 more than in 2013 but 5 below the number in 2012. The number of over-65s involved in collisions in the district was 29% higher than the 2004-2008 average. Those injured numbered 58, 12 of them seriously. The equivalent figures for 2004-2008 were 46 and 4. The rise in elderly casualties was uneven across Kent, with Sevenoaks close to the average. In the county as a whole, more elderly cyclists were injured in 2014 than in 2013, a rise from 21 to 31, while the number of elderly pedestrians hurt rose to 104 from 84 the previous year.
The three top wards in the district for collisions and casualties were Brasted, Chevening and Sundridge; Seal and Weald; and Swanley Christchurch/Swanley Village.
Posted at 07:18 PM in Current Affairs | Permalink | Comments (0)
Kent County Council has used the August bank holiday to sneak out -- four weeks later than scheduled -- a disastrous set of road casualty statistics for 2014; almost every set of data shows the roads in our county are getting more dangerous, not less.
This is despite a much-heralded 'Casualty Reduction Strategy' approved early last year, which was supposed to put the county on track to meet new lower targets in 2020 for people killed and seriously injured (KSI).
Road casualties are rising across much of the UK, partly because of reduced police and camera enforcement, but Kent seems to be doing particularly badly.
The figures for 2014 show that in some areas, notably pedestrian and cycle safety, Kent is recording sharply increased casualties compared to a decade ago, despite safer vehicles and more advanced NHS accident and emergency treatment.
The total number of KSI jumped by 11% from 2013 to 2014 -- an increase for the second year in a row. 658 people were killed or seriously injured. This means the county is now 33% above its 2020 target of a reduction to 495 casualties. Deaths rose from 48 to 49.
Collisions were up 7% despite non-stop road safety campaigns by Kent Highways telling drivers to be more careful. Motorcycle collisions rose from 547 in 2013 to 601 last year.
Collisions involving cyclists rose from 441 in 2013 to 480 in 2014, which is 126% above the benchmark average of a decade ago. Kent uses an average from 2004-2008 to measure progress in casualty reduction -- which now seems to have gone sharply into reverse. Cycling casualties are now running high above the level of 2004-2008, though part of this may be due to increased numbers of cyclists. Child casualties are also going up, though are still below the level of a decade ago. Half of the under-16 KSI casualties were children on foot.
Most of the collisions were on urban 30 mph roads. Kent has refused to follow other local authorities, including many UK cities, in lowering speed limits on residential streets to 20 mph. It has also vetoed 20 mph limits outside schools.
When the figures are broadened to include slight injuries, the picture is just as bad; Kent recorded 6303 casualties in 2014, compared to 5830 in the previous year and 5755 in 2012. Slight injuries to pedestrians went up to 673 in 2014, a rise from 631 in 2013 and 623 in 2012. Motorcycle injuries rose even more steeply, but injuries to car users also rose. Child casualties jumped to 570 (481 in 2013 and 502 in 2012).
The only improved statistic was a slight fall in the number of casualties among drivers aged 17-24, who have the worst crash records of any age group.
Kent's two major targets for 2020 are a reduction of 33% in overall KSI and a reduction in the number of children killed or seriously injured of 40%. To achieve the latter target, child casualties would have to fall to 39, a reduction of a third. Instead, they appear to be rising fast. The number of seriously injured children jumped from 45 in 2013 to 61 last year.
The 2014 Casualty Reduction Strategy drew criticism from cyclists and other groups for being too narrowly based and ignoring wider measures of road safety. The latest figures suggest that measured by its own chosen yardstick, the county is going to miss its 2020 targets for casualties to car occupants, motorcyclists and cyclists.
Kent's data look particularly bad in a GB national context. Its 11% rise in overall KSI compares to a national 5% rise last year. However, the county says the long term trend is still for casualties to fall compared to the benchmark of the previous decade.
The figures seem to show that pedestrians in Kent are disproportionately at risk . While the the number of killed and seriously injured pedestrians rose 2% in Great Britain as a whole, the equivalent rise in Kent was 18% in 2014.
So that's my summary of the figures; I shall be poking around in the national statistics for 2014 when time allows, looking more closely at how Kent compares with other local authorities.
But there is enough evidence here to suggest an appalling and predictable level of failure. Some of us argued when the Casualty Reduction Strategy was out for consultation that it was not fit for purpose, but our views were brushed aside.
Kent's previous cabinet member for transport David Brazier, who introduced the new strategy, has handed what amounts to a hospital pass to his successorMatthew Balfour. But a lot of the blame has to be shared by senior Kent Highways officers who wrote the policy and the councillors on KCC's transport committee who failed to question it.
The Casualty Reduction Strategy urgently needs to be rewritten, with a fresh emphasis on speed enforcement. KCC must rethink its fanatical opposition to 20 mph limits and concentrate on lowering traffic speeds rather than cutting motorists' journey times.
Why does one of the biggest local authorities in the country seem so backward? I can't help wondering what role has been played behind the scenes in this debacle by KCC's leader Paul Carter, who is well-known as a car enthusiast and competitor in the Paris-Dakar rally.
Posted at 10:28 PM in Current Affairs | Permalink | Comments (0)