ChiCycle position on the proposed A259 Chichester to Emsworth conversion of pavements to shared use cycle tracks

ChiCycle position on the proposed A259 Chichester to Emsworth conversion of pavements to shared use cycle tracks

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West Sussex County Council (WSCC) and Highways England (HE) have opened a public consultation on the A27 Designated Funds NMU scheme between Chichester and Emsworth. The scheme mainly consists of relocating cyclists onto the A259 pavements and the removal of the existing on carriageway cycle lanes.

  • Webpage for the A27 Designated Funds NMU consultation is available here
  • Consultation closing date is 23rd Sept 2021
  • Email to send consultation responses A27DesignatedFunds@highwaysengland.co.uk
  • Contact number for the consultation Tel: 0300 123 5000

We recommend everyone wishing to support local walking and cycling takes note of the ChiCycle position (given below) in addition to following the material presented on the WSCC consultation website. Whatever your opinion, we believe you should have your say and give feedback on the proposed scheme.

ChiCycle Reject the HE and WSCC A27 Designated Funds NMU Proposal because it involves Inappropriate Conversion of Town, Village and Residential Pavements to Shared Use Cycle Tracks

Current HE and WSCC A27 Designated Funds NMU proposals fail to meet DfT standards. Although ChiCycle agree safety concerns with the Chichester to Emsworth section of NC2 need to be addressed, we strongly oppose attempts to resolve these issues by redirecting two way cycle traffic onto residential, Town or Harbour Village pavements. Converting the pavements to shared use will provide neither genuine practical/safe options for cycling nor acceptable solutions that meet pedestrian needs. National policy on walking and cycling Gear Change forbids wasting public money on such schemes that fail to comply with DfT standards.

ChiCycle reject the proposals to convert existing Harbour Village footways/pavements into shared use cycle tracks. However, we feel the traffic calming and speed restriction measures could be beneficial. We recommend the Designated Funds scheme are refocused and redesigned purely around traffic volume/speed reduction and resurfacing of the poorly maintained highway including all carriageway and pavement areas.

Realistic Long Term Town Planning Objectives Need to be Established that will Restructure the Local Transport Network and Minimise Motor Traffic on the A259.

Thoroughly researched and well designed interventions can provide alternative (and preferably sustainable) transport options that negate peoples need to drive through our sensitive Harbour Village streets. The long term town planning solutions ChiCycle recommend are:

  • Downgrade the A259 from an A road to a  local traffic route only. It is otherwise irresponsible to encourage walking and cycling while in excess of 20 thousand vehicles a day (including long distance HGV traffic) can suddenly be redirected from the A27 onto these narrow village streets without notice;
  • Reduce the speed and volume of traffic on the A259 through residential areas. This is a key element of Dutch CROW Road Safety Manual philosophy and has resulted in an impressive uptake of sustainable transport modes in the Netherlands;
  • New housing development schemes between Chichester and Emsworth to be designed to provide links directly onto the A27 for motor-traffic. In conjunction with other measures, this will significantly reduce motor traffic volumes through the Harbour Villages;
  • Encourage only public transport, pedestrians and cyclists to use the A259. Make the A259 route less attractive for motor vehicles while providing adequate alternative routes leading motor-vehicles away from residential areas;
  • Install modal filters to restrict private motor vehicles from driving through the Harbour Villages. Highway links provided by local developments onto the A27 can provide adequate alternative routes for motor traffic that currently relies on driving the length of the A259;
  • Improve local railway stations by providing generous provision of secure bicycle parking facilities. If biking to the stations is made safe and convenient, significant numbers of commuters will switch away from driving to work and start going by train;
  • Create a subsidised integrated transport system to simplify local journeys, particularly those that use combinations of rail, bus and bicycle. An affordable all you can eat local travel package combining bus, train, bike hire and boat trips will be a powerful persuasion for tourists to leave their cars behind. This will lead visitors towards spending in local businesses rather than creating summer transport gridlock throughout our coastal area;
  • With low volumes of motor traffic achieved by redesign of the local transport network, village streets should be re-developed by encouraging more local shops, cafes and restaurants to establish. This will enhance local living opportunities for all residents and will expand the regions tourism trade;
  • Include walking and cycling permeability throughout new development following design styles used in Poundbury in Dorset. Wherever possible introduce additional pedestrian connections within and around the existing Harbour Villages. This encourages vibrant village communities where residents are happy to rely on easily accessible local business and amenities. Design methodology to achieve permeability for walking and cycling is outlined in the DfT Manual for Streets;
  • Exploit and preserve the natural beauty that attracts people from around the world to England’s South coast by implementing a Mini Holland scheme between Chichester and Emsworth making this a top UK family tourist destination.

Strategic Development along the A259 must be halted until realistic town planning interventions capable of dealing with the areas transport crisis are underway. Paragraph 111 of the current National Planning Policy Framework (NPPF) allows planning permission to be refused in the current situation where safety and severe congestion caused by additional traffic from new development would prove unacceptable:

111. Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

A27 Designated Funds Must be Invested into Better Value for Money Interventions that Genuinely Benefit the Community Rather than Squandering Money on a Useless Shared Use Pavement Scheme

Between Chichester and Emsworth, it is not cycling that creates danger, neither is danger caused by pedestrians walking through the Harbour Villages! The root of the A259 safety issues are the unacceptably high volume and speeds of motor vehicles travelling through our sensitive village communities. This is the key problem that we need to address.

Highways England Designated Funds have a limited scope allowing them only to provide a partial solution to this regions transport issues. However a thoroughly researched town planning strategy can identify where Designated Funds interventions can dovetail with additional schemes provided from alternative funding streams.

Two streams of additional funding could easily integrate with the A27 Designated Funds scheme. Thes are:

Excellent opportunities exist to deliver a cost effectively Mini Holland ChEmRoute scheme because the A27 has already been built as a bypass to reduce traffic through the Harbour Villages. The A27 and A259 run almost parallel to one other, only few hundred metres apart. All that is required is a couple of short link roads and junctions and the area could have a sustainable transport scheme that is the envy of the rest of the country.

By contrast the currently proposed NMU scheme threatens to have a negative impact on the Harbour Village communities, making pavements hostile environments where vulnerable, elderly and disabled residents are excluded.

Additional details of why the current scheme is unacceptable are provided in the question links show below the horizontal line.

HE and WSCC Claim it is Acceptable to Convert Pavements to Shared Use on Interurban and Arterial Roads such as the A259. Is this a credible claim ?

ChiCycle feel this is a misrepresentation of LTN1/20 standards by omission.

The official text from the LTN1/20 standards is shown below with the HE & WSCC omissions from the sentences highlighted in red.

6.5.6 Shared use may be appropriate in some situations, if well-designed and implemented. Some are listed below:
-Alongside interurban and arterial roads where there are few pedestrians;
-In situations where a length of shared use may be acceptable to achieve continuity of a cycle route;

Fishbourne High-street is clearly an inappropriate location for converting pavements to shared use to carry a national cycleway

ChiCycle feel it is not credible to claim locations like Southbourne High-street are arterial roads where few pedestrians will use the pavement.

We also feel the omission of “a length of shared use” from the quoted text is disingenuous. Design standard summary principle No22 permits short lengths of “less good provision rather than jettison an entire route which is otherwise good“. Summary principle No2 instructs that “On urban streets, cyclists must be physically separated from pedestrians and should not share space with pedestrians“. ChiCycle agree with the recommendation that compliance can be relaxed for occasional short lengths of provision to prevent rejection of otherwise excellent schemes. However, HE & WSCC are arguing that the entire NMU scheme should be exempt from compliance. ChiCycle feel it is unreasonable that virtually continuous non compliance with DfT standards is being presented as acceptable adherence to current national guidelines on walking and cycling.

In addition, ChiCycle cannot understand how WSCC & HE can describe our harbour village streets as interurban roads where these streets have frequent street lights and 30 or 40 MPH speed limits. This description is even harder to accept where there is continuous housing, shops and community buildings such as pubs and churches lining both sides of the road. Why does the scheme consider installing 20 MPH speed limits on these virtually flat straight interurban arterial roads unless these streets have been miscategorised and are in fact urban residential streets?

We also reject the notion that locating shared use cycle tracks on narrow urban high streets could ever be described as well-designed and implemented infrastructure.

Conversion of pavements to shared use is universally considered unsatisfactory in current and also previous 21st century UK guidelines. LTN1/20 states:

6.5.4 In urban areas, the conversion of a footway to shared use should be regarded as a last resort. Shared use facilities are generally not favoured by either
pedestrians or cyclists, particularly when flows are high. It can create particular difficulties for visually impaired people. Actual conflict may be rare, but the interactions
between people moving at different speeds can be perceived to be unsafe and inaccessible, particularly by vulnerable pedestrians. This adversely affects the comfort of both types of user, as well as directness for the cyclist.
6.5.5 Where a shared use facility is being considered, early engagement with relevant interested parties should be undertaken, particularly those
representing disabled people, and pedestrians and cyclists generally. Engaging with such groups is an important step towards the scheme meeting the authority’s Public Sector Equality Duty.

Previous guidelines LTN1/12 on shared use paths  gave the following warnings about converting pavements to shared use.

6.12 A common reason for taking cyclists off the carriageway is the perception that it will improve safety. However, it is important to understand that a shared use route will not necessarily be safer than an on-carriageway alternative. In particular, careful consideration is needed where a cycle track running alongside a road crosses side a road – see Figure 6.1. At these locations, there is significant potential for conflict, which can sometimes negate the safety benefits of segregating cyclists from motor vehicles. Section 10.3 of LTN 2/08 discusses this in greater detail.
6.13 Where cycle tracks alongside roads accommodate two-way flow, the potential for conflict can increase significantly. It is probable that drivers are less likely to expect cyclists to come from both directions because, intuitively, they might assume cyclists would be travelling in the same directions as traffic in the adjacent part of the carriageway – see Figures 6.1 and 6.2.
6.14 Another reason for taking cyclists off the carriageway might be to provide a more convenient route. However, journey times can increase if the route is discontinuous or it takes cyclists out of their way (coherent and consistent route signing can help here).

Previous 2008 guidelines on walking and cycling LTN02/08 gave the following warning on converting pavements to shared use:

8.1.2 In general, off­road cycle routes in urban areas tend to be the least desired option, and it is usually better to cater for urban cyclists on­ road if this is practicable. Off­road routes are often created by converting existing footways/footpaths and, if such routes are not carefully designed, pedestrians may view them as a reduction in quality of provision. It is important to consult with cyclists and pedestrian groups on the design of such facilities. This can help reduce the likelihood of objections to the conversion of pedestrian facilities. More information on the establishment of shared use schemes is available in Local Transport Note 2/86 Shared Use by Cyclists and Pedestrians (DoT, 1986).
8.1.3 In addition, urban off ­road routes may be frequently interrupted by side roads. Track crossings of side roads can be difficult to get right, and they may become points of conflict between cyclists and motorists.

Current design standards for street design DfT Manual for Streets 1 warns against the conversion of pavements to shared use:

6.4.8 Cyclists should be catered for on the road if at all practicable. If cycle lanes are installed, measures should be taken to prevent them from being blocked by parked vehicles. If cycle tracks are provided, they should be physically segregated from footways/footpaths if there is sufficient width available. However, there is generally little point in segregating a combined width of about 3.3 m or less. The fear of being struck by cyclists is a significant concern for many disabled people. Access officers and consultation groups should be involved in the decision-making process.

DfT Manual for Streets 2 also a current design standards for street design warns against the conversion of pavements to shared use:

6.2.10 Off-carriageway cycle tracks can have advantages, but will generally need to be shared with pedestrians, who may see them as a reduction in provision. They will therefore be the least desired option, particularly in urban areas.

ChiCycle wish to accentuate that any guidelines indicating shared may be permissible in certain circumstances are unlikely to be advocating conversation of  urban high street pavements to shared us. If the NMU scheme was proposing a shared use route like Centurion Way that runs away from the highway, although it may fall short of current standards, ChiCycle would not oppose it. Conversion of narrow urban high streets pavements to shared use cycle tracks is generally considered to be unacceptably poor quality design. Failure to consider the negative impact this will have on disabled pedestrians will be a contravention on the 2010 Equality Act.

Proposed Shared Use Pavements Pass Multiple Private Driveways. Visibility From these Driveways is Often Very Limited. How can these Proposals Possibly be Safe for Cyclists?

Many existing driveways on the A259 already struggle to meet existing minimum standards for visibility (splay criteria) for exiting across a pedestrian only footway. This requires drivers to see 2.5 metres either side of driveways from 2.5 metres back from the driveway exit onto the pavement. HE and WSCC acknowledge this is an issue! Nobody claims 2.5 metres visibility each side of a driveway is adequate for a National Cycle route.

Cars from this driveway are unable to see an approaching cyclist on the pavement when pulling out

The purpose of DfT and DMRB splay visibility standards is to ensure drivers have adequate visibility so they are able to make the necessary observations of approaching traffic before they pull out from side streets and driveways. Failure to adhere to these standards leaves avoidance of collision to luck. Unless cyclists universally stick to the slow walking speed of pedestrians, drivers cannot see them early enough to make safe decisions before pulling out from their driveways. The only safe way residents could exit from these driveways, is to have someone at hand outside of the car to wave them out when the track becomes clear of cyclists. This is unlikely to be a workable solution for most residents.

Advice is given on this matter that will prove impossible to follow. Evidently, drivers will be unable to check for approaching cyclists because HE & WSCC both acknowledge visibility criteria will not be met and the exits onto the cycle track are blind. How could drivers possibly adhere to the following advise if their vision is blocked?:

The onus is therefore on motorists to check for approaching pedestrians and cyclists before crossing the path, consistent with the Highway Code.

Unfortunately this advice obfuscates that it remains the local highway’s authority responsibility to make sure roads are designed with driveway exits having adequate visibility of approaching traffic. Failure to ensure this will leave the WSCC in contravention of the Road Traffic Regulation Act 1984 which requires local authorities to maintain “expeditious and safe movement for all traffic”!
What is being recommended to drivers, is similar to asking people to play a safe game of Russian Roulette by only cautiously pulling the trigger. ChiCycle remain unconvinced this approach will help anyone avoid injury.

HE & WSCC claim the scheme need not comply with LTN 1/20. Is this really true?

Although at first on a superficial level this may appear to be true, if the situation is scrutinised in more detail, it is clear this statement is false. Although DfT gives local authorities advice on how to construct safe highways by issuing “guidelines”, the purpose of these documents is to enable compliance with laws such as, Traffic Management Act 2004, Road Traffic Regulation Act 1984 and the Equality Act 2010. Significant departure from DfT  guidelines will also result in conflict with these national laws.

In addition, national policy on walking and cycling forbids central government money being spent on non compliant infrastructure that fails to meet LTN1/20 standards! If WSCC permit this scheme while it falls significantly short of national transport standards, they will likely be asked to return the money spent to national government and this repayment will have to come out of the local county budget.

National policy for walking and cycling Gear Change states that:

Funding only schemes which meet the new standards.
We will not fund or part-fund any scheme that does not meet the new standards and principles described in theme 1 and in the Appendix. We will not allow any other agency or body to fund such schemes using any of our money. This includes schemes delivered through pots such as the Transforming Cities Fund

ChiCycle believe HE and WSCC will need to comply with current national government highways standards and in particular DfT LTN1/20. 

The Artists Impression that Heads Up the NMU Promotional Material, Illustrates an Impressive Standard of Provision for Cycles. Is this an Accurate Representation of the Scheme?

The Highways England (HE) visualisation used as the header image for the projects consultation website gives a misleading impression the short (580 metre) two way cycle track has a continuous half meter wide separation strip protecting cyclists from traffic. In this short length the segregation strip is broken 12 times by side-roads, access ways  and shared driveway exits. The segregation is broken on average once for every 45 metres of its length. Where the HE visualisation is shown crossing the 25 metre wide shared driveway mouth (that also is used by a busy caravan park),  an approximately 30 metre section of the two way cycle track will have no segregation from traffic. ChiCycle have made a created a more realistic impression showing that the segregation strip will not be continuous at this wide driveway mouth. 

Segregation Strip Will Not be Continuous
Segregation Strip Will Not be Continuous. The ChiCycle  image above gives a more realistic impression

For comparison the Highways England illustration is shown below.

Highways England Image is misleading
Highways England Image is Misleading

The sections of route being significantly modified from its existing layout add up to approximately 3.6 miles in length. 3/4 of this involves converting pavements to shared use cycle tracks. Only 1/4 of this length, comprising of two sections adding up to less than one mile in length, is segregated cycle track with separate footway facilities as illustrated. 

The total distance between Chichester’s Market Cross and Emsworth Quay  is 7.04 miles. The proportion of the route that will be converted to a standard illustrated above is approximately 1/8th of the total length of the route. The section illustrated runs only for 560 metres or 1/3rd of a mile. Short sections of the segregated cycle provision may be adequate but the majority of the route will be  a much lower standard of provision..

The NMU scheme is being titled as an improvement scheme benefiting pedestrians and cyclists. Will the advantages really outweigh the schemes shortcomings?

Helen Littler acknowledged on the 16th August webinar that cyclists wishing to make reasonable progress along the A259 remain expected to ride in the carriageway. With the safety and inconvenience implications of two way cycle provision being run across the mouths of over one hundred junctions and driveways, it is doubtful the route will be suitable for family cycling or school children riding to school. Very few regular cyclists consider they would use the proposed NMU infrastructure. 

Many residents who regularly walk the existing pavements worry about sharing the space with two way cycle traffic. People who walk dogs are particularly concerned this will prove impractical once two way cycle traffic is directed onto the pavements. Jeremy Board supports the NMU scheme because he states his No1 priority is “Driver friendly. We accept the way forward is electric cars, most of our cyclists drive and our drivers cycle. Gina’s Cycle Path will not change the layout of the A259 road for drivers“. However, we have found it very difficult to find anyone else willing to defend the poor quality NMU proposals.

Despite rejecting the summary principals as not mandating design requirements. Highways England chose to presented the Chichester to Emsworth NMU as compliant with LTN1/20 summary principal No1.:

Infrastructure should be accessible to everyone from 8 to 80 and beyond: it should be planned and designed for everyone. The opportunity to cycle in our towns and cities should be universal

Perhaps in some narrow technical sense the infrastructure could be described as accessible to people across this age range. It is plausible people from 8 to 80 could walk up to the edge of the A259 NMU from adjoining streets and look disapprovingly at the scheme. However, although access may prove possible, due to its poor quality and safety concerns, it is unlikely pedestrians or cyclists will regularly choose to use this scheme. The most likely outcome of the NMU scheme appears to be a modal shift away from walking and cycling towards car dependency.

ChiCycle doubt the NMU proposals meet the funding principals required for Designed Funds schemes! Particularly points 10 & 11 detailed in Highways England Designated funds plan 2020–2025 on page 36:

  • Point 10. Demonstrate value for money. With widespread opposition to the use of shared use pavements, it remain unclear who will use the poor quality NMU scheme and how this minimal level of use could represent value for money.
  • Point 11. Have a minimum benefit cost ratio greater than one. For some of the
    funds, our appraisal process provides a standardised way of demonstrating this. It is difficult to imagine how an unpopular shared pavement scheme could ever return 5.5 million pounds in value to the community.

Gear Change the national policy on walking and cycling infrastructure makes clear that central government opposes installation of inadequate provision that is a waste of taxpayers money. The following test from the document can be found on page 20:

We will set much higher standards
Inadequate cycling infrastructure discourages cycling and wastes public money. Much cycling infrastructure in this country is inadequate. It reflects a belief, conscious or otherwise, that hardly anyone cycles, that cycling is unimportant and that cycles must take no meaningful space from more important road users, such as motor vehicles and pedestrians. It offers little protection from motor traffic and gives up at the points where any difficulty is faced or inconvenience to motorists is risked. These are often, of course, precisely the places where cycling provision is most needed.
We have today, alongside this document, published new cycling design
guidance which sets out the much higher standards we will now require if schemes are to receive funding, along with a number of failings, common in the past, which we will either no longer allow at all, or will strongly discourage. The summary principles are set out in the Appendix to this document. We do not seek perfection – but we do demand adequacy. We would rather do nothing than do something inadequate.

On Friday the 5th of February 2021, Paul Goodenough, WSP Design Manager for the NMU Scheme, Claimed that there is no mandate for the NMU scheme to Follow the Design Principles Contained Within the Current DfT LTN1/20 Standards for Walking and Cycling. Is this really correct?

WSP Design Manager Paul Goodenough made an extraordinary statement in a meeting on the 5th Feb 2021. He claims there is no mandate for Highways England to follow design principles that form an integral part of national policy on walking and cycling. This claim was made during a meeting specifically to introduce plans supposedly reworked to comply with national standards for cycling LTN1/20.

Just prior to Paul Goodenough’s statement, Andrew Gould (secretary of Chichester District Cycle Forum) highlighted that LTN1/20 (page 8) 1.6 Summary Principles state:

(Summary Principle No2)
Cycles must be treated as vehicles and not as pedestrians. On urban streets, cyclists must be physically separated from pedestrians and should not share space with pedestrians. Where cycle routes cross pavements, a physically segregated track should always be provided. At crossings and junctions, cyclists should not share the space used by pedestrians but should be provided with a separate parallel route.

Principal No22 permits highways authorities a small degree of  latitude but nonetheless it makes clear the majority of  infrastructure  is expected to comply closely with the previous 21 design principals. Principal No22 states:

(Summary Principle No22) When to break these principles.
In rare cases, where it is absolutely unavoidable, a short stretch of less good provision rather than jettison an entire route which is otherwise good will be appropriate. But in most instances it is not absolutely unavoidable and exceptions will be rare.

The chapter’s introductory text also explains:

The following summary principles form an integral part of this guidance

Not only do these summary principals form an integral part of walking and cycling standards LTN1/20 but they are also repeated again within the National Policy for Walking and Cycling  Gear Change. It is made very clear that these principles are mandates needed to be followed otherwise, if not adhered to, Active travel England will withhold funding from WSCC. Indeed WSCC are already being penalised by Active Travel England for wasting money allocated for walking and cycling. Gear Change states on page 20:

We will set much higher standards
Inadequate cycling infrastructure discourages cycling and wastes public money. Much cycling infrastructure in this country is inadequate. It reflects a belief, conscious or otherwise, that hardly anyone cycles, that cycling is unimportant and that cycles must take no meaningful space from more important road users, such as motor vehicles and pedestrians. It offers little protection from motor traffic and gives up at the points where any difficulty is faced or inconvenience to motorists is risked. These are often, of course, precisely the places where cycling provision is most needed.
We have today, alongside this document, published new cycling design guidance which sets out the much higher standards we will now require if schemes are to receive funding, along with a number of failings, common in the past, which we will either no longer allow at all, or will strongly discourage. The summary principles are set out in the Appendix to this document. We do not seek perfection – but we do demand adequacy. We would rather do nothing than do something inadequate. The standards will be enforced by a new inspectorate, Active Travel England, see theme 3, and we will expect Local Authorities and developers to utilise the guidance in the design of their schemes regardless of whether they are seeking Government funding. Well-designed and uncluttered streets benefit everyone

Paul Goodenough replied to Andrew Gould implying that conversion of urban high-street pavements into shared use cycle tracks are acceptable within current national standards. Paul said, “so I take on board what you are saying Andrew in terms of that summary principal, however it is a principal within the guidance and not a mandate,  and I would draw your attention to paragraph 6.5.6 point No3.

Indeed, paragraph 6.5.6 point No3 does indicate a length of shared use path may be permissible within certain circumstances. However, it is abundantly clear that it is not appropriate to convert narrow pavements such as on Southbourne High-street, into shared use cycle tracks. Nobody is arguing that shared use cycle tracks are universally unacceptable. ChiCycle happen to consider the shared use section between Chidham and Bosham is acceptable as it is on a rural section of the route. However, it is preposterous to suggest that any section of pavement is suitable for conversion to a cycle track wherever this permits two cycle schemes to be connected together.

As a highways design professional, Paul Goodenough ought to understand the weakness of his own argument. ChiCycle contacted Paul Goodenough after the February the 5th meeting, asking him to clarify why HE should be exempt from following national walking and cycling design principals. He replied but was unable to give any explanation for why the design principals demanded by national cycle infrastructure standards should not apply to HE Designated Funds Schemes.

Drawings of the Proposed NMU Scheme Indicate that Fishbourne Road East is a Quiet Route Carrying Insignificant Volumes of Motor Vehicle Traffic. Is this Really an Accurate Assessment?

On 30th April HE project manager Adriana Chirovici acknowledged previously made ChiCycle concerns that Fishbourne Rd East is not a quiet route.

The most recent traffic data (publicly) available for this road was recorded in August 2009. Since this date there has been significant housing development along Clay lane that feeds onto Fishbourne Road East. Therefore, it is unlikely that typical traffic volumes on this road will have declined since August/September 2009.

West Sussex County Council provide the following traffic count data:
FISHBOURNE, FISHBOURNE ROAD EAST BY NO.29 Site Number: 00004581 Site Reference: C0123005L02
Vehicle Count Report August/September 2009.
Traffic volume ranged between 5129 & 2452 Vehicles Per Day

DfT guidelines LTN1/20 (Page 74) state that:

7.1.1 Where motor traffic flows are light and speeds are low, cyclists are likely to be able to cycle on-carriageway in mixed traffic, as shown in Figure 4.1. Most people, especially with younger children, will not feel comfortable on-carriageways with more than 2,500 vehicles per day and speeds of more than 20 mph. These values should be regarded as desirable upper limits for inclusive cycling within the carriageway.

Of the 33 days when full daily traffic data was recorded at Site Reference: C0123005L02 during 2009, only two dates reported vehicle traffic counts below 2,500 vehicles per day! Sunday the 9th Aug and Sunday the 16th Aug. This shows that during the period of this survey the traffic volume on Fishbourne Road East was only appropriate for cycling in mixed traffic on 6% of these days. It should also be noted that on two days the traffic volume on this road exceeded 5,000 vehicles per day!
DfT guidelines LTN1/20 (Page 74) contain the following comment on traffic volumes above 5,000 vehicles per day:

7.1.4….. At flows of above 5000 vehicles per day few people will be prepared to cycle on-street…..

Adriana Chirovici wrote to ChiCycle explaining “I would like to reassure you that we plan to undertake new traffic counts in the next design stage and this won’t be overlooked to ensure information is captured accurately”. However, the next stage of the NMU scheme’s project design seems to have gone forwards without new traffic counts having been made on Fishbourne Rd East.
ChiCycle do not believe this section of the route is quiet enough that additional provision for cyclists can be discounted.

Criticism that the NMU Scheme Fails to Comply with National Standards for Walking and Cycling Could Result in its Cancellation. Might it be Better to Accept this Sub Standard Scheme, Otherwise No Infrastructure will be Provided for Cyclists in the Foreseeable Future?

ChiCycle believe inappropriate conversion of Harbour Village pavements, turning them into two way cycle-tracks carrying a busy national cycle route, is worse than doing nothing! There are three reasons for us to believe this.

  1. Pedestrians need safe pavements that are convenient to use if our Harbour Villages are to remain vibrant communities. Bicycles are near silent in operation and it is stressful to share pavement space with bicycles that can approach from both in-front and behind. On seeing an approaching cyclist, pedestrians may choose to step clearly to one side allowing them space to pass. However, by stepping to one side, pedestrians may also be walking directly into the path of cyclist approaching in the opposite direction from behind. To safely walk on these kinds of shared use pavements, pedestrians will need eyes in the back of their heads. The situation will be particularly stressful for elderly, disabled, visually impaired, and parents accompanying young children. On routes away from the highway, away from the additional danger of being knocked into a busy carriageway, shared use may be appropriate in some circumstances. However, it is ludicrous to consider two way cycle traffic on a national cycle route NC2 can safely squeeze down Southbourne high street with cyclists slaloming around pedestrians sharing the pavement. It is shear madness to consider this an acceptable standard when the A259 remains designated as the back up route for diverting the entire traffic load from the A27 South Coast trunk road. With in excess of twenty thousand vehicles being diverted to thunder down these harbour village high streets, anybody knocked off from the pavements in a collision between pedestrians and cyclists will have a limited chance of survival. Combining cycles and pedestrians onto the harbour village pavements will severely deter both groups of users from using the streets.
  2. There are many housing developments being proposed between Chichester and Emsworth and these are in addition to many recently completed housing developments along the A259 corridor. Where the A259 passes through the narrow Harbour Village Streets, the road already has inadequate capacity to safely carry pedestrians, motorists and cycle traffic from  national cycle route NC2. To enable sustainable development of the area, well considered town planning is necessary to make improve the local transport network. It is unrealistic to expect existing narrow village streets to satisfactory cater for the traffic generated by thousands on new homes. Indeed, the NPPF acknowledges that new developments need  adequate transport networks for all modes of transport. The inappropriate conversion of Harbour Village pavements is only a token gesture that will allow developers to falsely claim that adequate infrastructure already exists to support construction of additional housing. New housing development can claim opportunists exist for residents to use sustainable transport modes by virtue of the NMU scheme being approved. However, once the new developments are constructed, it will soon be realised the NMU scheme’s failure to follow national standards has rendered it useless for both walking and cycling. Unfortunately, once new development has been constructed, without inclusion of the town planning measures necessary to create an adequate transport network, there will no longer be land available to retrofit any satisfactory solutions. Introduction of the  NMU will only function as a mechanism to avoid vital these town planning interventions until it is too late to provide adequate solutions. Completion of the NMU will permit a flood of new housing development who’s traffic will frequently gridlock the A259.
  3. Cycle campaigners and environmentalists welcomed the new National Policies on walking and Cycling Gear Change! Many hope it marks a watershed moment of genuine change in transport planning. It has been an acknowledgment that the needs of pedestrians and cyclists must be raised above unsustainable desires to increase motor vehicle dependants. Central government promised to end funding for poor quality schemes like the A27 Designated Funds NMU scheme. Active Travel England is intended to halt taxpayers money being wasted on useless token gestures that fail to genuinely support sustainable modes of transport. If this poor quality NMU scheme goes forwards without WSCC being severely punished for non compliance, then the scheme will become a template used by other authorities to avoid worthwhile investment supporting sustainable transport. By permitting the A27 Designated Funds NMU scheme Active Travel would demonstrate it is a toothless instrument unable to enforce even the most basic national standards for active travel. This will likely result in widespread adoption of similar schemes that will prove disastrous to community life across the country.

For these reasons ChiCycle believe it is vital to prevent acceptance of this poor qualityA27 Designated Funds NMU scheme. It will prove better to do nothing at all rather than accept this scheme that will worsen the situation for everyone in our community.

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