TWBUG Response to Transport for the South East’s Transport Strategy for the South East

“The Transport Strategy will do nothing to bring about the type and scale of change that we need, and should be rejected. It is long on hope, short on ambition and does nothing for the climate emergency.”

The Transport Strategy for the South East does not address the urgent need to transform the way that we move people and goods in the region, especially given the climate emergency. Now is the time to re-wire our transport strategies and policies to put people and the environment first, ahead of the supposed need for continual growth.

The strategy persists with the same discredited transport ideology that has led to high levels of pollution and congestion. Its focus on ‘connecting communities’ fails to recognise the primary needs of the area’s residents, the majority of whose journeys are short and local. The strategy is particularly weak on addressing the needs of people in urban areas who suffer most from pollution, congestion and the other negative impacts of our motor vehicle-dominated transport network. Its enthusiasm for road upgrades consigns our population to more pollution, ill-health, conflict and a decline in quality of life.

This is a pity since the strategy has some good points. We welcome the recognition of a need for joined-up thinking and to plan at a regional, not just county level. We also applaud the emphasis in this document on people and places rather than cars. We agree about the need to replace the discredited ‘predict and provide’ approach with a determination to ‘choose a preferred future’ (page viii); and we strongly approve the ambition of reducing the need to travel at all (page x).

But the document does not follow through on these good principles. The emphasis is still on economic growth and jobs based on speeding up motor vehicle traffic.

Instead, we believe, TfSE has a key responsibility to seize this opportunity to give leadership to the county councils which it represents. It should state clearly that high motor vehicle use is unsustainable and that priority must be given to walking and cycling for journeys up to 5 miles (68% of all UK journeys). Removing motor vehicle access to much of our towns and reallocating the space to walking, cycling and public transport is the quickest and most cost-effective way of unlocking the most benefits for the most people.

The plan includes several further flaws; some specific (pages 4-6); others more general (pages 2-3).

“The current approach to transport in the South East is unsustainable. The time for fundamental change is NOW.”

General flaws

1: SMART test failed

The plan has no budget or indication about how obtain funding, and lacks a statement about responsibility for its implementation:

Monitoring and evaluation: A mechanism for monitoring delivery of prioritised interventions, as well as evaluating outcomes related to the strategic goals and priorities, will be developed.

When, by whom and how will it work? Without answers to such questions no plan will be delivered.

2: National constraints not recognised

While having a Transport Strategy for the South East is a welcome step forward from planning at a county level, the lack of an integrated transport policy at national level will provide a handicap, unless power is truly devolved downwards from national level, as well as upwards from county level. e.g. will train operating companies in the region become accountable to this new body? Will responsibility for the strategic road network be devolved from Highways England? etc.

3: Key fact omitted

The strategy fails to recognise the key fact that 2/3rds of all journeys are less than 5 miles. It focusses mainly on long-distance travel and on solutions that improve links between business hubs in the South East – the minority of people’s journeys – rather than measures to improve short journeys within and around urban areas. Achieving modal shift for these journeys requires much lower funding, is easier to achieve and brings more benefits to individuals and the places where they live. Such modal shift would bring significant benefit to the longer distance journeys by reducing congestion at the start and end of many trips.

4: Wrong starting point

Despite the promise at the top of page viii to focus on ‘people and places’ the strategy is primarily about how to get people and goods and services from A to B. Instead, it should be about how to fulfil society’s and peoples’ needs. Here are two examples:

Example 1: in place of the trend of centralising services, which generates additional journeys, we need to consider whether providing services more locally could bring benefits, e.g. rather than thinking about how to get people to a specialist hospital for investigations and treatment, we need to consider how more tests could done locally – cottage hospitals, GPS, or at home – digitally transmitted to a specialist team, and results (especially if benign) communicated directly to the patient rather than a needless personal visit.

Example 2: rather than thinking about how the goods can get from a factory in place A to the port in place B eighty miles away, consider whether, with some changes to rail freight loading systems and some additional railway lines, they (and exportable goods from all the other factories in the vicinity of place A) could be got instead to a port only 20 miles away.

5: Too long and poor drafting

The document includes numerous passages of management-speak, waffle and statements of the obvious, such as…

‘Economic growth, if properly managed, can significantly improve quality of life and wellbeing. However, without careful management, unconstrained economic growth can have damaging consequences or side-effects.’ (page xi) or

‘Motorways are strategic significant roads that move people and goods rapidly over long distances.’ Its length, plus numerous typos, such as ‘unconstrainted’ (page xi) and ‘strategicy’ (page 60), constitute a disincentive for people to read it and take it seriously. It should be cut to a short statement of principles followed by a concise, costed plan with maps, a timetable and responsibilities for implementation, truly a ‘SMART’ strategy.

Specific flaws (a few examples)

Page Text Comment
v Foreword by Cllr Keith Glazier Chair of TfSE The first step on this journey is a simple one; we must make better use of what we already have. Our road and rail networks in the South East may be congested but we know that, in the short-term, targeted investment to relieve pinch-points alongside new technology like digital railway signalling are the best and most effective ways to address short-term capacity and connectivity challenges No. ‘targeted investment to relieve pinch-points’ means schemes such as the Arundel bypass illegally carving its way through a national park and destroying ancient English woodland in order to ‘save’ motor traffic a few minutes. Following this failed policy for the last forty years and building more roads simply brings more traffic. We need to reduce the number of vehicles on the road by dis-incentivising their use, not catering for more of the same. The foreword fails to recognise that 2/3rd of all journeys are under 5 miles (DfT figures) and so comfortably do-able by bike if safe, comfortable infrastructure is in place. Focussing first on more active travel for short journeys as a first step is the single, most effective and low-cost way of reducing congestion and pollution, and improving the residents’ health and well-being.
xi Key principles for achieving our vision This page includes several good principles, but… ‘Transport for the South East has developed a framework that applies a set of principles to identify strategic issues and opportunities in the South East, in order to help achieve the vision of the Transport Strategy.’ …is meaningless waffle
xi ‘Economic growth, if properly managed, can significantly improve quality of life and wellbeing. However, without careful management, unconstrained economic growth can have damaging consequences or side-effects. …patronises the reader with somewhat sanctimonious statements of the obvious, and should be expunged.
xiii Prioritise vulnerable users, especially pedestrians and cyclists, over motorists Yes, but the proposals give no such priority. Otherwise the word ‘bicycle’ would appear more than once in 101 pages and road safety would the top priority. 165 people died on roads in the South East in 2018 and 3,000 were seriously injured, 1/3 of whom were pedestrians or cyclists. Safe, segregated infrastructure will have to be provided and pedestrians, cyclists and other vulnerable roads users cannot be expected to ‘share the road’ with 2 tonne (and above) motor vehicles.
xiv Priorities for investment New roads, improvements or extension of existing ones should be prioritised in the short term but become a lower priority in the longer term. Not even the short term. Such an approach merely increases traffic by ‘induced demand’ and makes the task of reducing traffic more difficult. Better to face the inconvenient truth now. Infrastructure to enable walking and cycling, which once implemented would result in a 15-20% modal shift away from motor traffic for a minimal investment compared with road-building, is not mentioned in the list of priorities for investment. Since 2/3rds of all journeys are under 5 miles it should be the number one priority.
xiv Public transport access to airports is a high priority and, in the case of Heathrow Airport, must be delivered alongside airport expansion. Are we really still planning to expand our airports? Have the authors of this plan not read or understood the IPCC’s latest report?
4 How this Transport Strategy was developed No mention of considering best practice from other countries. Taking evidence from a car-dominated society simply leads to more cars.
46 2.71 In general, many of the long distance footpath and cycle routes in the South East appear to be better suited to supporting leisure journeys (e.g. longer coastal routes) rather than connecting large population centres together. There are some notable gaps in the National Cycle Network (e.g. West Kent and Thanet) and the quality of cycle routes varies enormously across the network. While some sections are well surfaced and clearly lit, many other sections are unsuitable for night-time journeys and/ or would be hazardous to use in poor weather. Furthermore, some Major Economic Hubs are not served by the National Cycle Network at all (for example, the Blackwater Valley). This suggests there is scope to further expand walking and cycling infrastructure to encourage more sustainable forms of transport, particularly within and between the larger urban areas in the South East. Leisure routes are largely irrelevant to the serious matter of transport and this comment should be deleted The sentence “This suggests there is scope to further expand walking and cycling infrastructure” shows a total lack of political will to adopt one of the most important measures to solve the problems of congestion and pollution. Instead the text should read: ‘The South East, in common with the rest of England, has few cycleways which would pass the 12-year-old daughter test. Most journeys require cyclists to share the road with heavy, fast-moving motor traffic with no protection at all. Some have painted cycle advisory lanes which are totally ineffective or mandatory cycle lanes which are largely ineffective. Well-constructed segregated cycleways with priority at side junctions are almost unknown. As a result very few people make even short journeys by bicycle’. At a rough average of £1.45m per kilometre (see 2017 DfT report) we could build 5,000 km of top quality cycleways in and around our urban centres in the South East for £7.25bn, less than half of the DfT’s and the constituent county councils’ annual spend on roads.
78 4.18 Local journeys are short distance journeys that are typically undertaken at the beginning or end of an individual journey to or from a transportation hub or service to a destination. They include first mile / last mile movements that form an important element of other journey types described in this strategy. No. While some local journeys are part of a longer journey, most are short local journeys to go to work, to the shops or to school. It is this misconception that undermines the whole document with its focus on corridors, strategic routes etc, missing the point that 2/3rds of all journeys are under 5 miles in total.

TWBUG response to the A21 NMU to Tonbridge Station Pedestrian/Cycle Route

Text for question 3a of the consultation response questionnaire about the proposed pedestrian/cycle route from A21 Pembury Road to Tonbridge Station

The Tunbridge Wells Bicycle User Group has studied the plans carefully. We believe that with good links to Tunbridge Wells and Tonbridge town centres the A21 NMU could enable large numbers of bicycle journeys per month, many of which might replace car journeys, reducing congestion and pollution. We refer particularly to journeys to school, to work, to local shops and to the station. If done well this route could also enable many Tonbridge residents living in the adjacent area to cycle rather than drive into the town centre, again reducing traffic and pollution whilst increasing public health.

The A21 NMU is a high quality largely segregated cycle way and the links at either end need to be designed to the same high standards or the investment made by Highways England will at best be compromised or at worst wasted.

We do not believe that the proposed plans provide a safe, attractive or sufficiently high quality route to be effective in enabling the journeys mentioned above.

The route has no grade separated crossings. It includes no sections of dedicated cycle path (all shared use with cyclists obliged to slow down and stop at every side turning. It also crosses the A21 South bound exit slip road and Pembury Road with no protection. Frankly it is far below the standard required and that which would be meet the requirements of the London Cycling Design Standards (LCDS) or Highways England IAN195.

In the London Cycling Design Standards section 1.1.5 shows the six design outcomes for a cycle route in that it should be: Safe, Direct, Comfortable, Coherent, Attractive and Adaptable. The proposed designs are none of these things.

Creating a high-quality route will require a full traffic management plan for this section of Tonbridge to enable the closing of roads to through traffic or re-routing motor traffic to improve the quality of life for local residents and creating a subjectively safe cycling and walking environment.

The proposed design is stop/start/non-continuous, dangerous and is in our view not a serious attempt at a quality cycle route.

Here are our specific comments and suggestions:

The A21 exit into Vauxhall Lane – this is a high speed unsighted corner for motorists. Even a toucan crossing puts cyclists in a highly dangerous situation. It is likely lives will be lost here without speed reduction measures or grade separation under this design.

The suggested approach for the roundabout is also unacceptably poor

  1. A21 NMU / Vauxhall Lane / Roundabout / Pembury Road entry / exit section
    1. The design for roundabout looks poor, as it crosses the A21 southbound exit slip road and Pembury Road without protection.
    2. We suggest moving it to the other side of the roundabout, removing the need to cross Vauxhall Lane.  The southbound side is a more natural alignment.
  2. Suggesting a two-way shared path on the Eastern side of Pembury Road creates problems for the entire planned route.  Making the path shared, designs in conflict and is not best practice. Motor lane widths can and should be reduced and car parking removed to create segregated cycle lanes, separate to both motor and pedestrian traffic.
  3. As the cycle path crosses Tudeley Lane it should have full priority over the side road.
  4. Goldsmid Road to Tonbridge Station
    1. The rest of the route along Pembury Road as designed is extremely poor.  If the route is designed well it will carry considerable volumes of pedestrian and cycle traffic at peak times. Our experience of shared use pedestrian/cycle paths locally and in London suggest it will not be enough to enable both sets of users to travel comfortably and safely. Many cyclists will ride on the road and younger or elderly cyclists will not feel comfortable with sharing the footpath, especially in the section where no changes are planned. The cycle route design has completely failed at this point.
    2. A simpler suggestion would instead be routing the path down Goldsmid Road, although it’s slightly longer (6 mins vs 5 mins), because of the other advantages:
      1. Goldsmid Road is already 20mph (the plan is wrong – says 30mph)
      2. It could be closed to through traffic which will make it largely traffic free, making it better for residents and cyclists of all ages and abilities. Alternatively it could be made one-way, with two lanes for bikes.
      3. Goldsmid Road becomes Priory Road seamlessly.  It’s 30mph, but should be changed to 20mph as part of this route upgrade. However Priory Road would still require significant traffic reduction most easily through filtered permeability or a change to one way only.
      4. The Vale Road link could also be closed to through traffic as there are several other options for motor traffic to access this area (unless it is converted to one way to route motor traffic away from the cycle route.
      5. Once you get to Tonbridge High Street, a Toucan crossing should be installed to enable cyclists of all ages and abilities to turn right safely. Segregated cycle lanes should also be provided in and through Tonbridge Town Centre as a further project.
    3. The best way to unlock transport cycling potential for this area of Tonbridge and to connect to Tunbridge Wells would be to created a kerb separated cycle lane on each side of the Pembury road for the full length. This will enable residents to join fully segregated infrastructure to get them to the town centre as well as enabling quick, convenient, continuous and safe travel by bike to Tonbridge Town Centre, which is something the current design fails to achieve.

Representatives of Tunbridge Wells Bicycle User Group would be happy to meet with representatives of the Kent County Council and the organisations involved in designing the cycle route to discuss these points in detail.

TWBUG response to the proposed A26 cycle route

Tunbridge Wells Bicycle User Group campaigns for high quality cycling infrastructure on behalf of the 60% of the population[1] who want to use their bicycle for short journeys but who will not share the road with heavy, fast-moving vehicles.  Our research shows that traffic congestion cannot be solved by road-building or widening and we need to offer alternative means of transport to improve conditions for all road users.

We note the stated aim of the improvements to the cycle route along the A26:

‘…encourage more cycling along the route which would contribute toward congestion relief, improvements in air quality and health’

We agree this aim and welcome KCC’s decision to invest time and money in improving cycling provision.  Increased use of the bicycle is space-efficient and can dramatically increase road capacity, reduce pollution and improve health, as shown in Waltham Forest[2].

We support the proposal as a step in the right direction for cycling in Tunbridge Wells…

We welcome a number of specific aspects in the consultation:

  • Raised tables on side junctions and attempt to make cycle route continuous by, for example removing parking spaces and upgrading advisory lanes to mandatory.
  • Reference to increasing cycling as a mode of transport.
  • 20mph in Southborough High Street.
  • Co-operation between three councils.

…on the basis that further improvements will be made once funds become available in order to make the route usable by all from 8 to 80…

Our suggestions are additional to those proposed in the plans and aim to make the route attractive to those who presently do NOT cycle.  Once implemented, our suggestions will:

  • Make the route safe for the large number of people that want to use their bikes for everyday use, not least the thousands of children that attend one of the many secondary and primary schools along the route;
  • Satisfy the top priority of local Joint Transportation Board for new road schemes – ‘road danger reduction’; and
  • Fulfil the aim of the Tunbridge Wells Borough Council’s cycling strategy 2015

‘To make cycling a normal part of everyday life in the borough, by creating a safe and welcoming environment for cyclists of all ages and abilities’.

 …by making the following changes.

Experience and evidence from London, Cambridge, Leicester, Brighton and elsewhere in the UK shows that potential cyclists need physical segregation from motor traffic to make them feel safe enough to use the route. Best practice[3] states that for speed of 40mph or above and at vehicle flows of 5,000 or more per day, cycle tracks[4] are needed. This is particularly important on a major arterial route like the A26, given the large number of school children that could potentially switch their journeys to cycling if the route is safe enough.

Proposal 1: Employ full segregation with a separate kerb-protected track at road level by raising it to pavement level or by using ‘kerb upstands’ between road, cycle track and pavement[5].

Evidence shows that a route needs to be continuous for it to be used extensively.  Parts of the route are acknowledged as less than ideal, particularly between Southborough Common and the A21.

Proposal 2: If it proves too difficult and costly in the short term to build the whole of the route from Tunbridge Wells to Tonbridge, the route should be designed to the highest standards [6]throughout and then built in sections as and when resources allow.

In practice, this means we (a) accept the current proposal – but ask for the speed limit to be lowered to 30 mph speed to protect cyclists – for the route north of Southborough Common as an interim measure and (b) implement the highest standard for the funds available on the section from Grosvenor Road roundabout to Speldhurst Road, where the road is widest and should attract the highest numbers of people cycling.

The greatest danger to pedestrians and cyclists and, therefore, the biggest barrier to people cycling, is at side junctions where motor traffic is turning.   We are pleased to see that a number of junctions have raised tables to slow traffic and to indicate priority for pedestrians and cyclists.  We note that the entrances to some junctions are being ‘tightened’ to reduce danger to pedestrians and cyclists.

Proposal 3: include raised tables and tighter entrances at most, if not all, side junctions.

The 20 mph zone being implemented to the east of St John’s road will improve life for residents and increase safety in those residential streets. In many towns and cities, such ‘filtered permeability’ zones are reinforced by allowing pedestrians and cyclists free movement, but preventing motor vehicle from using the streets as rat-runs by closing specific streets to through traffic.

Proposal 4: Take the joint opportunities of 20mph in St John’s and an improved cycle route to restrict vehicle access to a number of side roads along St John’s Road.

[1] National Travel Surveys, local area walking and cycling statistics

[2] https://wfcycling.wordpress.com/mini-holland/evidence/

[3] http://www.standardsforhighways.co.uk/ha/standards/ians/pdfs/ian195.pdf

[4] Cycle Track: a track separate from the main carriageway for use by cyclists. Cycle tracks may be newly constructed or created through conversion of a footway (using powers under the Highways Act 1980 [4]) or footpath (using the Cycle Tracks Act [5]). Definition from Highways England Interim Advice Note 195/16

[5] http://therantyhighwayman.blogspot.co.uk/2014/06/a-sunny-southern-seaside-safari-part-3.html

[6] https://tfl.gov.uk/corporate/publications-and-reports/streets-toolkit

Tunbridge Wells Bicycle Users’ Group view on the A26 cycle route consultation

TWBUG has been campaigning for a number of years for more high quality cycling infrastructure in Tunbridge Wells. We are not so much campaigning for existing cyclists but for the 60% of the population[1] who would like to make more short journeys by bike rather than by car but who will not share the road with heavy, fast-moving motor traffic in order to do so. Our recommendations are based on ensuring that the designs are safe and attractive for those who presently do NOT cycle on the A26.

Our research over the last 4 years has confirmed that traffic congestion cannot be solved by building or widening roads but only by offering alternative means of transport. In particular, we can only accommodate population growth by transitioning some local journeys to more space-efficient modes and the bicycle can dramatically increase journey capacity.

capacity

We are very pleased that KCC is taking action to improve cycling provision along the A26 and is investing time and money in drawing up plans. This is good news as it represents a sea-change in local transport policy towards a realisable and affordable solution to congestion, pollution and our sedentary society.

Purpose of the A26 cycle route

The stated aim of the improvements to the cycle route is to:

‘…encourage more cycling along the route which would contribute toward congestion relief, improvements in air quality and health’

We agree with that aim and we acknowledge that the current proposals will improve conditions for existing cyclists and attract some new cyclists.  We would go further and recommend a number of changes which will:

  1. Enable the large number of people that have said that they are willing to use the route to do so by making it safe;
  2. Make the route safe enough for parents to let their children ride to school on their own – potentially several thousand schoolchildren;
  3. Satisfy the top priority of Kent County Council / Tunbridge Wells Borough Council Joint Transportation Board for new road schemes: ‘road danger reduction’; and
  4. Meet the aim of the Tunbridge Wells Borough Council’s cycling strategy 2015

‘To make cycling a normal part of everyday life in the borough, by creating a safe and welcoming environment for cyclists of all ages and abilities’.

We believe that our additional proposals will make a larger contribution to reducing congestion and improving air quality.

Our proposals

Experience from London, Cambridge, Leicester, Bristol, Bath, Brighton and many other UK towns cities is that physical segregation from motor traffic is needed to make potential, but nervous cyclists feel safe enough to use them.

Proposal 1: We recommend putting the cycle path on a separate kerb-protected track or raising it to the level of the pavement.

The evidence is that for a route to be used extensively, it needs to be continuous.  There are parts of the route that are acknowledged as less than ideal, particularly between Southborough Common and the A21.

Proposal 2: If it proves too difficult and costly in the short term to build the whole of the route from Tunbridge Wells to Tonbridge, we suggest that the route should be designed to the highest standards and then built in sections as and when resources allow.

In practice, this means (a) largely accepting the current proposal for the route north of Southborough Common and (b) implementing a higher standard from Grosvenor Road roundabout to Speldhurst Road. This is the part of the route where the existing road is widest and should attract the highest numbers of people cycling.

The greatest danger to pedestrians and cyclists and, therefore, the biggest barrier to people cycling, is at side junctions, where motor traffic is turning.   We are pleased to see that a number of junctions have raised tables to slow traffic and which indicate priority for pedestrians and cyclists.  We also note that the entrances of some junctions are being made ‘tighter’ to reduce the danger to pedestrians and cyclists.

Proposal 3: increase the number of side junctions with raised tables and tighter entrances to include most, if not all, side junctions.

A 20 mph zone is being implemented to the east of St John’s road in order to improve life for residents and to increase safety in those residential streets. In many towns and cities, such zones are being reinforced by allowing pedestrians and cyclists to move freely in and out of the zone, but restricting motor traffic, by closing specific streets to through traffic.

Proposal 4: Take the joint opportunities of 20mph in St John’s and an improved cycle route to restrict motor access to a number of side roads along St John’s Road.

Building the section from the Velo House to Majestic Wines to an excellent standard[2] will lead to a ‘virtuous circle’. Like the fully segregated sections of London cycle superhighways, it will be used by much higher volumes of bike riders who will then say ‘This actually works – let’s build the rest of it’. Success attracts funding – and so will start the first element in our overall project: transforming Tunbridge Wells into a town that is nicer and healthier to live in and that works for all of us.

With your support we can do it. To ensure your views are listened to please do not delay, but respond as soon as possible to the consultation.

[1] As shown in National Travel Surveys, local area walking and cycling statistics

[2] The UK has three high quality design guides for cycling that TWBUG believe ought to be used for this route. Please feel free to visit these links to see what we should be aiming for:

https://tfl.gov.uk/corporate/publications-and-reports/streets-toolkit#on-this-page-1

http://www.standardsforhighways.co.uk/ha/standards/ians/pdfs/ian195.pdf &

http://www.makingspaceforcycling.org/