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Highways England Responds to Bognor Regis Cycle Forum Questions on Emsworth To Chichester Cycle Route Plans

Adam Bell, raised questions on behalf of Regis Cycle Forum, over issues with Highways England plans to alter the Chichester to Emsworth Cycle route along the A259.

The Highways England reply skirts many of Adam’s issues by claiming the provision is for a share use Non Motorised Users (NMU) and not a dedicated cycle way. This categorisation allows national standards for cycling to be avoided and seems unlikely to provide a realistic alternative to cyclists continuing to use the road carriageway space.

The HE response followed by Adam’s original questions are below the horizontal line.


———- Forwarded message ———
From: A27 Designated Funds <A27DesignatedFunds@highwaysengland.co.uk>
Date: Wed, 2 Sep 2020 at 16:56
Subject: RE: Chichester to Emsworth Designated Funds A27 Link Improvement Package Feasibility Study
To: Bognor Cycle Forum <bognorcycleforum@gmail.com>
Cc: A27 Designated Funds <A27DesignatedFunds@highwaysengland.co.uk>

Dear Mr Bell

Thank you for your letter on 1st September 2020 regarding the Chichester-Emsworth NMU (Non-Motorised User) project. Thank you for showing an interest into this scheme and conducting such a comprehensive analysis of the Feasibility Study.

I would like to reassure you that no decision has been made yet on a solution for the project. We are still in the process of reviewing the Feasibility Study recommendation against the new released guidance and testing its viability. The Feasibility Study is used as a baseline, but we are now working on taking thinks forward and identifying a solution that performs best in terms of space availability, adhering to all relevant best practices/guidance and offering the best value for money. Throughout this process, we are working in close relation with both West Sussex County Council, as the local highway authority and asset owner, and Chichester District Council, as the local planning authority, who are both supportive of our proposals.

The recent announcement of the Government’s new design guidelines for cycling infrastructure design (Local Transport Note 1/20) has necessitated a re-evaluation of the design process as you have rightly pointed. These guidelines refer to shared use as the ‘last resort’ solution but do quote some exceptions on where it may be appropriate, such as interurban routes with low pedestrian flow like the A259. We are mindful of this new designation but also note that shared use paths have been used widely for providing safe journeys for both cyclists and pedestrians across both the Highways England and West Sussex networks for many years. The existing network around Chichester includes popular examples of shared use paths such as Centurion Way and the path alongside the A259 between Chichester & Littlehampton.

The A259 road is not a trunk road and is maintained by WSCC, hence CD 195 isn’t mandatory although represents good practice. That is why the options proposed in the Feasibility Study applied the principles of CD 195 only where that was applicable given the constraints of the road.

As one of the initial activities in our design phase, we will review the feasibility report in light of the new guidance contained in LTN 1/20.  We will be conducting a series of early engagement meetings where we will be engaging with stakeholders from the local authorities (parish, district and county) as well as local and national cycling organisations to understand any concerns or aspirations they may have.  We will also be exploring what can be delivered in light of LTN 1/20, aiming for the highest possible safety standards within the space available, whilst still providing value for money and without affecting the need for the A259 to be a HGV diversion route in case the A27 is blocked. The main objective of the scheme is to enable a growth in journeys made by active modes along the A259, but with the corridor being the main diversion route for A27, reducing car use or lowering vehicle speeds would impact the corridor’s strategic importance.

With regards to the query on widths, we specified a 3.5m wide path where achievable which gives scope for inclusion of a formal 0.5m strip whilst maintaining 3m width as recommended in Table E/3.1. Paragraph E/3.5 CD 143 allows for a minimum of 2.0m width where flows are less than 200 users per hour, therefore a 0.5m strip could be achieved where path widths are 2.5m. Furthermore, where a hard strip is provided on the carriageway, it can be considered as part of the separation distance for shared use routes. Therefore, there is scope to achieve greater separation as the design is further developed in the future. This will be further assessed during the next stages of the design.

In relation to the Cycling Level of Service query, the assessment doesn’t specifically need the inclusion of driveways. With that in mind, pedestrians/cyclists have priority at driveways similar to the priority proposed at some side roads.

Our current focus is to procure a design partner and we are currently in detailed contract negotiations. We expect the design phase to commence this Autumn.

I would like to reassure you that we will be engaging with all stakeholder groups at key points throughout the design phase to ensure we can agree on the best deliverable solution for the corridor and gauge any feedback.

Thank you once again for contacting us and expressing your interest in this project. Please rest assured that part of the appraisal we are currently undertaking involves raising the exact same issues you have in your letter and we are looking into progressing the scheme in a safe and cost-effective way, adhering to all relevant best practice and guidance.

Kind Regards

Adriana Chirovici

Project Manager

Regional Investment Programme South and East

Mobile: 07712 407 985

Tel: +44 300 470 1468
Highways England | Bridge House | 1 Walnut Tree Close | Guildford | Surrey | GU1 4LZ
Web: https://highwaysengland.co.uk/

From: Bognor Cycle Forum <bognorcycleforum@gmail.com>
Sent: 01 September 2020 07:59
To: A27 Designated Funds <A27DesignatedFunds@highwaysengland.co.uk>; Elliott, Simon <Simon.Elliott@highwaysengland.co.uk>
Subject: Chichester to Emsworth Designated Funds A27 Link Improvement Package Feasibility Study

For the attention of Mr S Elliott

The need to improve NCN2 on the section westwards from Chichester has been recognised locally by cyclists for many years.  The fact that Highways England are looking at a package of measures to improve cycling facilities is welcomed.  The WSP Feasibility Study states that it would explore the options to create a consistent, safe route for pedestrians and cyclists.  

However, the Bognor Regis Cycle Forum have a large number of concerns about the methodology used and the numerous discrepancies and inconsistencies throughout the study.  In addition, despite the Study stating it conforms with the requirements of CD195, this is not the case.  All of these reasons mean the whole basis for selecting a mainly off-road shared use path (Option A) is incorrect and better, safer solutions need to be considered instead. 

Separate to this, nothing in the proposals makes any attempt to materially reduce car use, lower vehicle speeds or attempt to try and achieve modal shift to make cycle use the default for shorter trips, as required by the Government.

 Design Criteria

Page 3 refers to the West Sussex Cycling Design Guide (2019), and states “WSCCs aim is that these design standards become commonplace in all new schemes throughout the county” and page 12 confirms the assessment of the existing cycling facilities was examined in line with the core design principles set out on the DfT LTN 1/12, and the Sustrans Design Manual : Handbook for cycle-friendly design.  Page 64 states that design guidance for cycle provision set out in CD195 is used for assessing the 2 options.

 Q1.    CD195 states that it is for cycle only routes, not shared use paths and covers the requirements for trunk roads and the motorway network. The A259 is not a trunk road and the proposed option is not a cycle only route.  Therefore, why was this design manual used as the reference for the study?

 Q2.    Why were the design principles from LTN1/12 not used for assessing the 2 proposed options?

 Q3.    Bearing in mind the recent release of LTN 1/20 along with the “Gear Change” document from the Government, and the recent announcement from the Transport Minister that authorities must follow LTN 1/20, will the proposals be amended to reflect the changes required by LTN 1/20?

Page 65 states that Table E/3.1 (from CD195) was used to determine the required width for the proposed cycle infrastructure and that due to the speed & volume of traffic, the minimum provision is off road cycle tracks.

Q4.    For the majority of the proposed route, in the main, a 3.5m path is stated.  However, there is no mention of the separation strip as required by CD195.  A separation strip, by its very definition, does not form part of the useable path.  CD195 states an absolute minimum separation strip of at least 0.5m is required in 40 mph areas and 2m in 60 mph areas.  Why has this separation strip not been provided along any part of the route?

There are large sections of 2.5m shared-use path which go alongside many walls and hedges which are higher than 0.6m.  Table E/3.2 of CD195 requires an additional width of 0.5m to maintain the effective width of the path.

Q5.   Why does the proposed option not comply with Table E/3.2 of CD195 in providing the additional width required?

 Q6.   Why does the proposed option not comply with Table E/3.1 of CD195 in stating that the maximum length for any sections which are only 2.5m wide is only 100m?

CLoS assessment

 The scores look at each section as a whole both eastbound and westbound, when there may only be an issue creating a lower score in 1 direction only.  This factor doesn’t seem to have been taken into account.  The study tends to look at a journey from the west, heading east.  In addition, no differentiation is made between a side road junction into a cul-du-sac.  Therefore the whole basis of Table 5-1 on Pages 68-69 comparing the existing route with Option 1 and Option 2 is flawed.

 Link 1 Havant Road Emsworth.

It’s not stated in the report when the site visit occurred, but it’s implied it was early 2020.  That being the case, it’s odd that for the assessment of Link 1 – Havant Road, there’s no mention at all of the approx. 250m stretch of new shared use path which was in use from May 2019 on the north side of the A259, from Selangor Avenue up to where the existing section of NCN2 crosses from the south of the A259 to then access the off road section and tunnel under the A27. The shared use path does however appear in the Preliminary Design drawing in App. C.

Table 3-1 on Page 15 provides a score of 19% with one of the reasons being frequent side road junctions with conflicting movements not separated.  There are 9 junctions each on the north and 8 on the south side of the A259.  It also mentions the 30mph limit and high volumes of traffic results in a low score.  However, the assessment doesn’t take into account that some side roads might be a cul-de-sac with only 4 houses and would not therefore be generating large volumes of traffic.

Table 3-2 Emsworth High Street scores higher at 42% for safety despite no segregation due to traffic speeds and volumes being low.  This is not consistent with Table 3-1 when the traffic volumes must be the same.  The safety score would be improved due to 20 mph and also the toucan crossing at West Street, but this would only be of benefit for cyclists heading eastwards.

Page 68 For Link 1 Havant Road (Emsworth) Option 2 states the Proposed CLoS would be 70% for 1.5m on-road cycle lane due to improved light protection where possible.  However, for Link 4 Southbourne to Farm Lane, the similar improved 1.5m wide cycle lane for Option 2 only achieves 33%.

 Page 69 Link 6 Broad Road to Cutmill Creek.  Under Option 2, the improved 1.5m cycle lane has a CLoS of 36% and yet Link 10 Hillier Garden Centre to Salthill Road scores 41%

 The differences CLoS percentages between the various different Links does not seem at all consistent.

Page 64 States that Option A would be an off-carriageway 3.5m to 2.5m two-way cycle track (shared use path for some sections).  However, Page 66 only refers to a 3.5m to 2.5m bi-directional shared-use path and a two-way shared use path is also referred throughout Table 5-1 on Page 68, and shared use is used from then on. 

 Q7.   Is any of the route to be a cycle only track or is the entire route to be shared use? 

 Q8.   Are horses to be allowed on the route or part of the route? 

The CLoS assessment confirms that 8 factors are deemed to be critical and have a greater score.  This is one of the reasons Option A is deemed to be the most suitable option, as stated by the summary on page 66 “The removal of cyclists from the carriageway will also considerably lessen the risk of collision of cyclists with all types of motorised traffic”.  For the Personal Injury Collisions taken into account for this study affecting non- motorised users, 66% occurred at a junction, roundabout or side road.  Some of these are pedestrians, but the figure is similar to national data regarding road traffic incidents and cyclists. However on Page 88, for the section along Havant Road in Emsworth the study states ”Due to the conflicts associated with a shared use path facility and numerous private access driveways with restricted visibility, the option of off-road cycle provision was excluded for this section”.

In numerous places along the proposed route, there are large numbers of private driveways as well as side junctions.

 Q9.   Why does the CLoS assessment used not include the private driveways in respect of the “risk of collision with turning vehicle at junctions” criteria?

 Q10.    How can a feasibility study recommend as safe a shared use facility which has multiple private access driveways with nil visibility but elsewhere state such a facility wouldn’t be acceptable due to conflicts from driveways with limited visibility?

 If a shared-use path is provided, then as well as the large number of private driveways now being added to the list of junction hazards to be encountered by cyclists coupled with the zero or limited visibility for car drivers emerging from their driveways, to stop on the path, there is also the factor of limited visibility for cyclists when crossing many of the side roads, when they no longer have priority.  An example of this is in Link 5 Farm Lane to Broad Road, where due to the position of the crossing point across Broad Road, cyclists would be positioned round the corner and not have a good field of vision for checking back in the direction of Emsworth, and in addition would not comply with the visibility splay requirements stated in Table E/3.5 of CD195.  The recommended crossing point here does not comply with the bent-out crossing of a minor road as set out in E/4.7 of CD195, and this failure to provide an adequate and compliant crossing point occurs for the numerous times the shared-use path crosses a minor road.

Option Appraisal (Page 66).

There are discrepancies in the way this is worded as well as important safety factors not being taken into place, leading to an incorrect selection of a mainly off-road shared use path as the preferred route.

Section 5.2.2 states “the A259 is a relatively high-speed and highly trafficked link, with signposted speed limits exceeding 30mph in the entirety of all three sections” and “This guidance indicates that off-road provisions for cyclists are the most appropriate for this link”.

The study has 12 sections or links listed.  There are only 3 links with above 30 mph areas in the entirety, one of which is Link 7 Cutmill Creek to Old Bridge Road which is intending to use the existing off-road path anyway.  The option appraisal incorrectly uses the existence of above 30 mph in those 3 links as justification for off-road provision along the entire route.

Section 5.2.3. states that the shared-use path in Option A is able to meet desirable minimum requirements set out in Table E/3.1 of CD195 and retain 3.5m width for the majority of the route, with some small sections the width being down to 2.5m (the absolute minimum set out in the CD 195 guidance).

As stated above, there is no mention of the minimum 0.5m separation strip (rising to 2m where the national speed limit applies which would be needed for Link 7).

Section 5.2.4 states “The provision of a consistent, segregated route also meets the standards set out in WSCC design guidance, which states that on primary distributor roads, where speeds are greater than 30mph, off carriageway provision must be provided”. However, this omits the rest of the description which continues “(cycle tracks), preferably segregated”.

The proposed option A actually drastically increases the number of potential incidents due to the large numbers of entrances and side roads onto the shared use path.  This is flagged up as an issue in App. F  Road Safety Review, which states the number of private drives with no visibility to/from the shared use path.  It also states a number of side roads and field accesses have limited visibility.  All of these add a large number of potential conflict points with cyclists. 

Page 67 states “The initial design process for Option B related to the improvement of the existing on-carriageway cycle facilities along the A259. However, after further design considerations, this Option was discounted from the scheme due to identified constraints relating to the speed of vehicles between the A259 and A27 as well as a high number of PICs involving cyclists being identified along this route”.  As stated above, the vast majority of incidents occur at junctions or wherever a car might turn into a cyclist. 

In the analysis of the various options shown in Table 5-1 on Page 68, this shows Link 1 Havant Road Emsworth with mainly 1.5m cycle lanes currently has a CLoS of 33%, but this can be increased to 70% with the lanes amended to always be 1.5m wide and some light protection.  There has been no proper consideration of improving the cycling provision by looking to provide similar light protection on the existing cycle lanes.

There is no consistency in the treatment of the shared use path when crossing side roads.  In some places, cyclists will have priority, but in the main, cyclists will be expected to give way.  To have a mix of priorities will be dangerous and confusing for all users.  At a typical cycling speed of 12 mph, being required to come to a halt regularly will not satisfy the requirements for safety, directness nor comfort.  In addition, by being required to regularly accelerate away from junctions will not be conducive to encouraging cycling and will merely encourage some people to ride on the road.  By removing the existing cycle lane marking will therefore encourage vehicles to drive closer to any cyclists on the road and increase the likelihood of incidents.

In addition, in the various built-up areas, especially in the numerous long sections of only 2.5m width shared-use path, there is not adequate and safe width for two way cycling and pedestrians, and the design and use of such a provision is contrary to LTN 1/20 and does not even comply with the Highways England Design requirement for shared-use paths set out in CD143. 

The path will also increase the numbers of incidents between pedestrians and cyclists.  In addition, LTN1/12 highlights the fact that two-way cycle tracks on one side of the road can significantly increase the potential for conflict due to drivers being less likely to expect cyclists to come from both directions.

Overall therefore, the selection of a shared-use path for the entire route not only will be more dangerous for cyclists than the existing provision, does not comply with CD195, CD143, nor LTN 1/20, and will not satisfy the core requirements of a safe, consistent high-quality route which promotes sustainable travel.

Adam Bell

Chair

Bognor Regis Cycle Forum

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