Traffic Issues along the A2 East of Sittingbourne
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26 Jan 2011This letter is sent to you by Protect Kent and 10 local councils who have come together because of shared concerns about increase in traffic on the A2 to the east of Sittingbourne as a result of the proposed completion of the Sittingbourne Northern Relief Road (SNRR) and proposed further growth at Sittingbourne.
To provide context for our comments and concerns we note the following:
• Policy T8 of the Swale Borough Local Plan promotes the provision of the Sittingbourne Northern Relief Road (SNRR), linking the A249 to the A2 around the northern and eastern sides of the town. The main objective of the road is to provide traffic relief for central Sittingbourne, thus facilitating opportunities for town centre regeneration.
• By the end of 2011 the middle section of the SNRR will be completed, meaning that the road will be completed from the A249 around the northern side of Sittingbourne and will terminate within the East Hall Farm development on the eastern side of Sittingbourne north of the mainline railway. This will provide an alternative routing for traffic to and from the Eurolink Industrial Estate and the East Hall Farm development site without the need for it to pass through the town centre, thus significantly improving current town centre congestion. The only section of the SNRR remaining to be provided will be the section from East Hall Farm across the mainline railway to Bapchild on the A2, for which a route alignment is yet to be agreed.
• Policy T8 of the Swale Borough Local Plan requires that in formulating proposals for this final part of the SNRR, from East Hall Farm to Bapchild on the A2, regard should be given to the impact of the new road on the traffic flows and living environments along the A2 corridor to the east, with appropriate mitigation measures to be provided before the road is fully opened.
• The consultation undertaken by KCC Highway Services in February 2010 on its preferred alignment for the final part of the SNRR anticipated that traffic volume on the A2 east of Bapchild would increases from 15,143 movements a day in 2007 to 25,254 movements a day in 2026 simply as a result of linking the SNRR to the A2, without any additional development, comprising a 67% daily increase in traffic. This would be the case irrespective of the route alignment.
• The consultation by KCC Highway Services did not include any proposals to mitigate the impact of the anticipated increase in traffic, contrary to the requirements of Policy T8 of the Swale Borough Local Plan.
• In its response to the consultation, Swale Borough Council urged KCC Highway Services to recognise the likely impact of increased traffic further east on the A2 and to promote, within a realistic timescale, a link from the A2 to the M2.
• Swale Borough Council is currently preparing the Core Strategy for its Local Development Framework (LDF). Consultation on alternative spatial options commenced on 17th January 2011. The spatial options were agreed at a meeting of the Borough Council’s LDF Panel on 25th November 2010, and all four of the options include the completion of the SNRR. Additionally, Option 3 proposes a first phase of a proposed Sittingbourne Southern Relief Road (SSRR) whilst under Option 4 a full route of the SSRR would be identified. Both options 3 and 4 are linked with high growth at the Kent Science Park.
• The spatial options, including the proposals for completing the SNRR and providing the SSRR, were formulated by officers and considered by Members of the LDF Panel without any traffic modelling to assess their respective impacts on the A2 and the wider highway network. This assessment remains to be undertaken.
• Neither the completion of the SNRR nor the provision of the SSRR feature in the Government’s recent announcements on future highway schemes to be publicly funded following the comprehensive spending review .
• We are unaware of any support from the Highways Agency for a new motorway junction on the M2, which is essential for the provision of the SSRR.
Although it is recognised and accepted by Swale Borough Council and the County Highway Authority that traffic will increase on the A2 east of Sittingbourne as a result of the completion of the Sittingbourne Northern Relief Road (SNRR) and future development at Sittingbourne, it is of serious concern to Protect Kent and the local councils that the impact on the communities along the A2 arising from the expected increase in traffic is not being seriously considered or mitigated as part of the future planning of Swale. There is no comprehensive package of mitigation measures being developed to ensure that the physical environment and quality of life of communities along, or close to the A2, will not be permanently eroded as a result of the significant predicted rise in traffic along the A2 – a road that already has capacity issues.
In particular, it is of concern that the only potential mitigation for the A2 being considered by the Borough Council and the County Highway Authority is a possible new link road between the A2 and M2 – the Sittingbourne Southern Relief Road. However, there have been no assessments to establish what the effects of a link road will be and whether or not it will actually provide any relief for the A2, or simply attract yet more traffic.
Furthermore, if a link road is a potential solution then it is of concern to Protect Kent and the local councils that only one potential route alignment is being considered. This route is close to Sittingbourne, at the widest point between the A2 and M2, and would pass through a designated Special Landscape Area and areas designated in the Swale Borough Local Plan for their nature conservation value. It is probably the most environmentally damaging route that could be chosen. The fact that this route is exactly the route being promoted by the owners of the Kent Science Park to facilitate their expansion plans, leads us to believe that the main motivation for the link road is not primarily about relieving traffic on the A2 but to secure an alternative access to the Kent Science Park to enable it to expand. It is the concern of Protect Kent and the local councils that economic objectives appear to being put above the need both to minimise environmental impacts and the need to mitigate impact of increased traffic on local communities.
Reliance on a single alignment for the potential link road close to Sittingbourne also means that the opportunity to consider how a link road might act as a solution to existing traffic issues elsewhere along the A2 is not being taken. For example, there are longstanding issues at Ospringe where almost constant traffic, including a high volume of heavy goods vehicles, is impacting on a designated Conservation Area and the quality of life of residents. This is a location that has been the subject of routine air quality monitoring for some time and, because pollutants have been detected above National guideline levels, an Air Quality Management Area is to be declared. This has been put down to existing traffic flow and the narrowing of the road.
Traffic issues in Ospringe are not new. The Borough Council’s own Conservation Area appraisal for Ospringe undertaken in 2004 states (paragraph 11):
“The ever present stream of traffic in the narrow main street now makes it a place that is seemingly to be passed through as quickly as possible, and where any thought of stopping is no longer to be lightly contemplated.”
Consequently, it is the view of Protect Kent and the local councils that if a link road between the A2 and M2 is a potential mitigation for the impact of increased traffic on the A2, then the Borough Council and the County Highway Authority must assess alternative alignments to ensure that the location and alignment of the potential link road is the best to provide mitigation for the communities along the A2. It should also minimise impact on the environment and, importantly, involve full engagement with the local communities affected. Crucially, the consideration of a potential link road should be on the basis of finding the best highway solution, whilst having regard to environmental constraints. It is entirely inappropriate for the local authorities to promote a pre-determined alignment driven by other considerations, as currently seems to be the case.
In any event, the provision of a link road between the A2 and M2 seems to be highly aspirational and, at best, would be a long-term mitigation measure. If the SNRR is completed, it is inevitable that there will be a significant period of time following its completion before the link road is provided, if at all. Despite the requirements of the Local Plan, it seems that no other mitigation will be provided before the road is fully opened or even after it is opened. This is unacceptable to Protect Kent and the local councils.
If the SNRR is to be completed, which is proposed in all of the spatial options for the Core Strategy being considered by the Borough Council, then this must be accompanied by a package of mitigation measures that can be put in place before the completed road is opened. It is unacceptable to solve Sittingbourne’s traffic problems by simply moving them elsewhere and blighting rural communities. It is the strong view of Protect Kent and the local councils that Swale Borough Council and the County Highway Authority must examine all possibilities for mitigating and ameliorating the anticipated increase in traffic on the A2 to the east of Sittingbourne as a fundamental part of the planning of the final section of the SNRR, and not just rely on the aspiration of a new link road between the A2 and M2 at some point in the future. To this end it is imperative that there is a full and meaningful discussion with the local communities to reach consensus on appropriate mitigation measures that should be examined.
Notwithstanding this, Protect Kent and the local councils are of the view that it should not be taken as a given in the spatial options for the Core Strategy that the SNRR will be completed as originally intended. Nor should it be the case that growth levels in the South East Plan should be seen as the minimum, as seems to be envisaged in the spatial options being formulated by the Borough Council.
Circumstances have changed quite significantly over the last two years, and the future will be a very different place to the recent past. We now have a backdrop of recovery from a deep economic recession and a period of severe restraint on future public spending. It is the Government’s intention to abolish the South East Plan and to remove top-down development targets, and to return planning to the local level. Assumptions previously made about economic and housing growth at Sittingbourne cannot be relied upon and simply rolled forward. It is necessary to take stock and fundamentally reassess Swale’s role and the amount of development it can economically and environmentally sustain. For these reasons, and given the uncertainties surrounding possible mitigation measures to address the impact of increased traffic along the A2, it is essential that consideration is given to a spatial option that does not assume the completion of the SNRR.
With the completion of the middle section of the SNRR by the end of 2011, the pattern and distribution of traffic movements in Sittingbourne will dramatically change. This provides a major opportunity to assess what the changes will actually be, rather than rely on out-dated modelling predictions of what they were expected to be, in deciding whether or not it is still necessary or appropriate to join the SNRR to the A2. To make such a major decision on the basis of historic (pre-recession) traffic data and modelling is inappropriate.
On behalf of Protect Kent and the local councils I hope that Swale Borough Council and the County Highway Authority will give serious considerations to our concerns, and I would welcome your views on the issues raised in this letter.
Finally, I would like to let you know that Protect Kent and the local councils have established a joint Group to co-ordinate our work on this issue. I invite the Borough Council and the County Highway Authority to engage with the Group in a constructive dialogue so that we can take forward a shared agenda for dealing with the traffic issues along the A2. In particular I ask that the local authorities share with the Group all the background assessments that are undertaken in regard to the planning of the final section of the SNRR and a potential link road between the A2 and M2, and any other potential mitigation measures. In the new era of localism it is important that we have the opportunity to consider the data and assessments in detail and to discuss them with the local authorities. Protect Kent is co-ordinating the Group, so I would ask that any communication be made with Brian Lloyd, Protect Kent’s Senior Planner, in the first instance.
Chairman, Protect Kent
On behalf of:
Protect Kent, the Kent Branch of CPRE
Bapchild Parish Council
Bredgar Parish Council
Faversham Town Council
Milstead Parish Council
Norton, Buckland and Stone Parish Council
Ospringe Parish Council
Rodmersham Parish Council
Teynham Parish Council
Tonge Parish Council
Tunstall Parish Council
Also sent to:
Cllr Jerry Lewin, Executive Member for Sustainable Planning, SBC
Cllr John Wright, Executive Member for Regeneration, SBC
Cllr David Simmons, Executive Member for Environment and Rural Affairs, SBC
Abdool Kara, Chief Executive, SBC
Pete Raine, Regeneration Director, SBC
James Freeman, Head of Planning Services, SBC
Cllr Nick Chard, Cabinet Member for Environment, Highways and Waste, KCC
Cllr Kevin Lynes, Cabinet Member for Regeneration and Economic Development, KCC
Mike Austerberry, Executive Director of Environment, Highways and Waste, KCC
David Cockburn, Executive Director of Strategy and Business Support, KCC
John Burr, Director of Kent Highway Services, KCC
Paul Crick, Interim Director Transportation Strategy & Planning, KCC
Linda Davies, Director Environment and Waste, KCC
Gordon Henderson MP
Hugh Robertson MP