Arundel SCATE response to Highways England consultation on options for the A27 Arundel Bypass – October 2017
Arundel SCATE is group of residents and businesses looking for more advanced and less destructive transport choices for Arundel and the surrounding area. We want to see improved access through a mix of measures including road improvements, walking and cycling infrastructure, better public transport and intelligent planning measures.
Arundel SCATE believes infrastructure measures are needed to address traffic congestion at Arundel and along the south coast.
It also believes that wildlife and the landscape around Arundel and the wider area must be conserved for future generations.
Arundel SCATE is wholly opposed to option 5a and option 3, both of which cut across areas within the South Downs National Park.
- Option 5a will irrevocably damage historic Binsted, its lively community and its rich wildlife. It is at the HE budget limit even before addressing key environmental impacts.
- Option 3 will destroy a major part of the most significant area of irreplaceable ancient woodland on the south coast. It also exceeds the agreed budget.
- Both options will wipe out populations of rare and protected species, destroy valuable woodland and damage part of an important wetland area
- Both are costly and at the limits of the budget
- Both will increase traffic levels in the area on the road and in surrounding local roads
- Both are likely to induce and accelerate traffic which will exacerbate congestion issues at Chichester and Worthing
- Both will seriously damage important local amenities and destroy local independent businesses. We believe these options will destroy town centre trade by taking traffic further away from town and through attracting retail development outside of the town
- Both impact heavily on the historic village of Tortington, which includes a 12 century church and a valuable hedgeline.
- Both will stimulate ‘infill’ development and impact adversely on the South Downs National Park and damaging the unique nature and setting of Arundel
We are encouraged to see the inclusion of option 1, a shorter, near-offline, 40mph road, in the public consultation. The route is in alignment with the single carriageway ‘New Purple’ proposal (see www.Arundel27Forum.org.uk) which Arundel Scate supports, and also provides the best value for money.
As a dual carriageway, option 1 is unacceptable in its current form due to increasing the barrier to connectivity, its large footprint, intrusive junction and capacity generating traffic.
We seek the adoption of the alignment of option 1, amended to a wide single carriageway (WS2) design with improved cross-town connectivity as identified by the New Purple proposal.
Quality of data quality used in the consultation
Highways England’s (HE) final decisions must be fully evidenced on need, impacts and cost benefit with accurate data. We are concerned that the data HE has presented so far is inadequate, with significant inaccuracies and lack of reliability. This data was presented in sophisticated formats, ostensibly to enable stakeholders and the public to make informed assessment of proposals in the HE consultation period. We believe the quality of the data was so poor on key factors that consultees would be unable to make a fully informed judgement with the data provided. The following are selected areas of concern.
1 Environmental Impact Assessment
It is understood that the environmental report provide was preliminary work as required by the Deparrtment for Transport at this stage of scheme identification. However, the desktop study was outside the required time limit for EIAs, as its historic data was more than two years old and the supporting site survey was carried out in January over a period of two days. The time of year, limited locations and time spent undertaking the survey are glaringly insufficient.
The Mid Arun Valley Environmental Survey (MAVES) group carried out a more detailed and recent survey of the relevant area. This was prepared and verified by professionals to internationally recognised standards and submitted to Highways England. This information has not been used.
HE staff have justified excluding the MAVES data as being provided too late – March 2017 – when the Environmental Report was put together in 2016. This means that the HE report was presented to the public when HE knew it was incorrect. Even headline data was not amended. This is not acceptable.
HE has missed important sites, habitats and species which would require appropriate and costly compensation if either option 3 or 5A were to be implemented. Further, since there can be no mitigation of loss of rare and seriously threatened species and habitats (which have been shown to occur in the study area), public judgement may well be that their loss is unacceptable under any circumstances, but this information was not made available to the public for the consultation.
We refer to Review of the A27 Arundel Improvements Environmental Study Report 2017, Thompson J, 2017, sent to HE during the consultation period.
2 Traffic predictions and time savings
We believe the traffic predictions for the A27 and routes around Arundel cannot be justified.
If the dramatic and unpredicted technological advances and changes in work, recreation and commercial activity over the last 15 years are considered, todays predictions for traffic and time savings over a future 25 year period cannot be considered reliable. All the traffic flows in the HE consultation brochure were those predicted for 25 years’ time, with no hint of uncertainty. This assumption of confidence is unacceptable.
Shorter term predictions also cannot be regarded as reliable. Comparisons can be made with predicted and actual traffic flows from the SoCoMMS detailed studies of 15 years ago, which used similar predictive tools (as confirmed by Colin McKenna of WSP). The 2002 study predicted a 33% growth in traffic between 2000 and 2015 on a ‘do nothing’ premise. During this period 7000 new homes were built (Arun DC data) and the economy of SW West Sussex grew by a third (ONS). The 2015 baseline traffic flow for WSP’s predictions is the same as the Halcrow SoCoMMS baseline in 2000 at around 30,000 AADT, ie without a new road, traffic has not increased.
This throws serious doubt on the WSP traffic predictions and therefore estimated time savings and consequently the stated economic benefits – for which time savings contribute a significant element.
3 Value for money
Arundel SCATE is concerned how the benefits estimated for both options 3 and 5A can have increased so significantly between 2015 and 2017 reports.
The explanation provided for increasing the BCR for option 5A from 1.7 to 2.6 (70% increase in benefit) is 0.45km decrease in length and separated junction with the existing A27, improving flow. Including the concomitant increased costs of the junction, it is hard to see how this could justify such a huge leap in benefit.
No explanation was given for no change in the BCR of 2 being given for option 3 despite no change in its proposal, but a 38% increase in costs (due to expected mitigation requirements).
It is felt that information provided on value for money is unreliable.
Highways England Aims for A27 at Arundel
We believe that Highways England aims for the project cannot be realised with the three current options. These aims are:
- Enabling economic growth
- Reducing congestion
- Improving safety
- Improving accessibility to local services
- Minimising environmental impacts
- Respecting South Downs National Park
a) Enabling economic growth
There is insufficient evidence that building an A27 dual carriageway at Arundel is needed to deliver economic growth.
The 2002 government-commissioned South Coast Multi-modal Study report said: ‘There is very little commercial or social interaction between Coastal towns that are over 50 kilometres apart. This is illustrated by the fact that the average car journey is less than 25 kilometres. Most congestion problems are currently confined to the peak periods’.
The 2015 HE A27 Feasibility Study stated ‘little change in travel patterns between 2001 and 2011.’ Department for Transport figures show overall levels of traffic are little changed since 2000 despite significant economic and population growth in Arun. The only vehicle type to increase is local delivery vans, due to internet shopping.
The A259 is the route of more economic importance, providing access for many more businesses, industrial sites and retail parks than the A27, as well as serving far more of the local population. This road has recently been upgraded by West Sussex County Council (WSCC) with the Felpham and North Bersted relief roads. WSCC is also planning improvements to other parts of the A259 between Bognor Regis and Worthing to reduce traffic demand on the A27.
Additionally, Arun District Council plans for housing development (Bognor Regis and Littlehampton) and locations for employment (Chichester, Worthing and Crawley) do not rely upon the A27 around Arundel for commuting to key employment locations.
Economic benefits derived from time savings cannot be relied upon as discussed above.
b) Reducing congestion
There is abundant research evidence demonstrating that building new road generates new and longer journeys, bringing more traffic and with it more congestion. Even if the A27 at Arundel is free-flowing for a period of time, traffic hold ups will increase at Worthing and Chichester due to additional journeys being made.
Highways England does not appear to take account of induced traffic attracted to a dualled A27 from other areas (urban and village) which will increase traffic, congestion and parking demand in those other areas and negatively impact on local business and residential streets.
c) Improving safety
We accept that the options have potential to directly reduce the number of road accidents. However, we suggest that this will partly be due to the inevitable increase in a population modal shift to cars and reduced active travel (cycling and walking).
The HE safety assessment omits indirect impacts of more pollution caused by induced traffic, reduced mitigating effects due to loss of local trees and less physical human activity as a result of more individuals driving rather than walking or cycling. The overall public health impact will undoubtedly be negative.
d) Improving accessibility to local services
We do not accept options 3 or 5a improve accessibility to local services as offline routes take traffic away from Arundel. This is likely to cause loss of local services as local facilities are undermined by increasing the ease of car access to bigger facilities further away and services locate away from the town to where the bigger roads are. They are many examples locally of supermarkets and other retail businesses setting up along the A259 and A27 at Worthing and Chichester, away from the town centre where people can walk and cycle to.
All options favour the car driver. These discriminate against those without access to a car and with the most challenges in accessing local services, i.e. young, elderly, people with disabilities, those on lower income (who cannot afford a car) and non-drivers (either by choice or circumstance). Bus services have recently been cut, isolating non-car drivers, and this will be exacerbated by expanding roads away from the town.
e) Minimising environmental impacts
The HE reports makes clear that all of the three route options have significant adverse environmental impact. However, the limited EIA undertaken by HE, to minimal DMRB standard, barely begins to show the major loss and damage that routes 3 and 5A cause.
The most that Highways England would be able to do is attempt to compensate for the serious damage caused. It ignores that for some factors, such as unique habitat (ancient woodland, chalk springs, unique hedgelines and wetlands) and rare species loss (bats, crested newts, dormice, badgers, butterflies), there is no possibility of genuine mitigation. All measures will be costly to the taxpayer and will not adequately compensate for the loss and destruction.
We also have concern over the impact that embankments and foundations of the raised routes Options 3 and 5a on the flood plains will pose to flood defences for Arundel and the surrounding communities and areas upstream within the SDNP.
HE’s own reports highlight uncertainty of the geology and MAVES reports identify serious geological issues around the 5A route.
f) Respect South Downs National Park
We oppose major road building through the South Downs National Park, and do not accept building a dual carriageway through parts of it respects this area of national importance. We are not aware of any major dual carriageway built through a National park in the 21st century.
A new Arundel bypass taken on its own, as it has been identified as a standalone scheme, despite its association with Worthing and Lancing improvements, would have no discernible impact on traffic at Storrington. Rat running traffic takes this route largely to avoid Worthing/Lancing congestion and much traffic in Storrington has been identified by Horsham District Council as resulting from people travelling to busy town from surrounding villages.
We cannot see that full direct impacts of induced traffic on the National Park have been taken into account and believe that indirect impacts of induced traffic amount to modal shift to cars and undermine the SDNPA strategy, along with that of WSCC, for achieving modal shift away from cars and towards active travel.
In addition to irreversible damage caused, further costs to the taxpayer will be required in mitigation.
New Purple – Alternative Proposal (see attached documents)
The ‘New Purple’ route is a near-offline, 40MPH, wide single carriageway (WS2) with enhanced connectivity and an associated package of sustainable transport elements. It resolves most traffic issues in and around Arundel, minimises impact on the natural environment and is the best value solution. See www.arundela27forum.org.uk for more information.
Existing A27 problems
There are six ‘pinch points’ causing traffic to slow or stop on the A27 at Arundel.
- Crossbush junction traffic lights
- Railway bridge
- Bus stop opposite station
- Pedestrian controlled traffic lights by the railway station
- Causeway roundabout
- Ford Road roundabout
Hold ups at these pinch points cause traffic to back up on the existing bypass/relief road and on the westbound Worthing Road approaching Crossbush.
Further flow and access problems occur at other points, including turnings to: Burpham and Warningcamp, Batworth Park, Beefeater/Premier Inn, Crossbush village, Arundel railway station, builders merchant, Causeway houses.
Queues are rare westbound on the single carriagewlay Chichester Road or eastbound after the Burpham turning. Outside peak times, flow is generally good.
New Purple route
The wide, single carriageway ‘new Purple’ proposal means:
- significant improvement of traffic flows (by avoiding pinchpoints)
- meeting HE estimated traffic volume requirements (CRF of 42k)*
- improved safety as wide single lanes permit visibility and better access in case of incidents;
- improved access to and from Arundel railway station;
- safe access to villages, Burpham, Warningcamp, Crossbush;
- relief of the old railway bridge and replacement on the section of A27
Ford Road roundabout remodelled
A locally designed, innovative proposal for a major remodelling of the Ford roundabout has been presented by John Wheatley RIBA (2017). Attached. It removes the last traffic pinchpoint, provides continuous traffic flow, significantly improves pedestrian and cycling connectivity across the town, and restores a sympathetic streetscape. Attached.
* David Wills, ‘The Missing Link’, 2016, submitted to HE.
Further benefits of the proposal in comparison to Highways England options
- no loss of housing or business
- no loss or division of ancient woodland, or significant wildlife habitat
- limited impact on the landscape of the Arun Valley and SDNP (some NP impacts with raised road on eastern end of site, but likely to be acceptable to SDNPA)
- no new or significantly expanded road in the South Downs National Park
- no further severance of villages or communities and continued linkage to the National Park
- no loss of amenity, including popular walks
- reduced flood management issues
- sufficient capacity, minimal induced traffic
- moderating effect likely to reduce impact on pinch points at Chichester and Worthing
- no loss of passing trade to Arundel
- significantly lower costs than other HE route options
- achievable in the timescale, especially with complementary WSCC local road schemes schedules, eg.Lyminster bypass and A259 improvements
Arundel Scate position statement on Highways England options for the A27 Arundel Bypass
Arundel Scate believes infrastructure measures are needed to address traffic congestion at Arundel and along the south coast. It also believes that wildlife and the landscape around Arundel and the wider area must be conserved for future generations.
Arundel Scate is wholly opposed to Option 5a and Option 3, both of which cut across sections of the South Downs National Park.
- Option 5a will irrevocably damage historic Binsted, its lively community and its rich wildlife.
- Option 3 will destroy part of the most significant area of irreplaceable ancient woodland on the south coast. It also exceeds the agreed budget.
- Both options will wipe out populations of rare and protected species, destroy valuable woodland and damage part of an important wetland area. Both are costly. Both will increase traffic levels in the area and exacerbate congestion issues at Chichester and Worthing. Both will seriously damage an important local amenity and businesses. We believe these options will also destroy town centre trade and attract retail and housing ‘infill’ development, as has happened elsewhere.
We are encouraged to see the inclusion of Option 1, a shorter, near-offline, 40mph road, in the public consultation. The route is in alignment with the single carriageway ‘New Purple’ route which we have long supported, and also provides the best value for money. However, we are opposed to the dual carriageway design of Option 1 as being detrimental to the town, causing unnecessary countryside damage and generating excessive traffic.
Option 1 is unacceptable in its current form. We therefore seek the adoption of the alignment of Option 1, amended to a wide single carriageway (WS2) design with improved cross-town connectivity.
We believe the final decisions should be fully evidenced on need, impacts and cost benefit.
The ‘New Purple’ route is a near-offline, 40MPH, wide single carriageway with enhanced connectivity and an associated package of sustainable transport elements. It resolves most traffic issues in and around Arundel, minimises impact on the natural environment and is the best value solution. See http://arundela27forum.org.uk for more information.