Response to West Sussex Transport Plan 2022 to 2036 Consultation

Response to West Sussex Transport Plan 2022 to 2036 Consultation

ChiCycle members are disappointed with the draft West Sussex Transport Plan 2022 to 2036. This draft policy document is open for consultation until the 8th Oct 2021. A link to the WSCC consultation transport plan webpage is available here.

The Language of Sustainability and Environmentalism is used Superficially within the Draft Transport Plan. However, few Recognisable Commitments are made to support Walking and Cycling.

The Vision and Objectives section of the Draft West Sussex Transport Plan 2022 to 2036 initially uses language suggesting  a move towards sporting sustainable travel. However, detail provided later in the document shows the opposite policy approach with priority on increasing provision for private motor vehicle use!

There a notably no projects showing any real ambition to move away from a culture of car dependency:

  • No schemes are proposed to make any West Sussex town/city centres car free.
  • No suggestions for new light rail and/or tram routes which would be ideal low carbon transport solutions to join up new and existing urban areas along West Sussex’s coastal plains.
  • No joined up town planning strategy is proposed that sets aside space for sustainable transport routes before building of new developments commence.
  • No schemes are proposed for new cycle parking facilities at train stations with safe routes provided for cyclists to conveniently reach stations.
  • No Low Traffic Neighbourhood schemes are proposed.
  • No schemes for expanding Twenty is Plenty schemes are mentioned.
  • No automated traffic enforcement schemes proposed that would ensure motor vehicles stick to a safe 20 MPH in urban areas. This would make walking and cycling viable and safe options for making short local journeys.
  • No schemes to filter through traffic residential areas using bollards or planters placed in the road. This would make these areas more appealing for people to walk, cycle and enjoy local living.

Wishful words are used in the draft document without any following detail policy committent to these words credibility:

3.4 Active travel modes, public or shared transport will be attractive options in built up areas and between towns, and rural communities will have access to the services they need.

ChiCycle would love to see active travel modes being made attractive in West Sussex. However, unless WSCC invest in practical schemes to enable this, these words in section 3.2 are only a false promise.

WSCC’s First Priorities Predominantly Focus on Increasing and Encouraging use of Private Motor Vehicles. This is Not the Basis of a Sustainable Transport Policy

For the areas Adur, Arun, Chichester and Worthing, the very first stated priority of the transport plan is to “improve performance of the A27“. The A27 is a trunk road that is highly unsuitable for sustainable modes of transport such as walking and cycling! Improving this road provides little advantage for public bus transport and offers no benefits for rail transport users.

The first priority for Mid Sussex is also to expand trunk road capacity and encourage additional unsustainable private motor vehicle use. The first stated objective is to “improve the performance of the A22, A23, A264, A272 and A2300“.

The first priority for the South Downs National Park is extremely vague. ChiCycle believe this is also intended as a focus on prioritising roads to promote expansion of the use of private motor vehicles. However, it is anybodies guess what is actually meant by: “Our transport strategy for the South Downs National Park is to deliver improvements within existing highway land“? This sentence could mean almost anything at all! Environmentalists might consider it an “improvement” if these highways were converted into wild flower meadows. The motoring lobby might favour conversion of these spaces into motorways. Whatever the first transport priority is for the South Downs National Park, it needs to be more clearly explained before it can be meaningfully discussed in any public consultation.

The first transport priority for Horsham appears to follow a more realistic approach in keeping with this period of climate emergency. However, it also suffers from vague wording rendering most of the text meaningless! Again, the term “deliver improvements within existing highway land” could mean virtually anything? However, ChiCycle approve of the strategy to “provide bus priority at signal-controlled junctions“. We are please to see this is also a priority for the Crawley area.

The first priority for at least six out of the eight areas covered, prioritises road capacity expansion. There can be no meaningful move towards sustainable forms of transport while the least sustainable mode of transport is prioritised above environmental responsible alternatives!

WSCC Avoid Responsibility for Carbon Dioxide Reduction by Optimistically Claiming Consumer Choice and Motor Vehicle Technology will Resolve the Issues Without Significant Need for Local Government Intervention

Electrification of private motor vehicles provides only a modest improvement in total lifecycle CO2 emissions with comparable miles covered and if the size of vehicle replaced is similar. The majority of energy powering electric cars comes from gas fired (fossil fuel) power stations and the manufacture of electric cars is far more carbon intense than for cars with internal combustion engines. Although electric cars produce moderately less CO2 over their entire life cycle than comparable internal combustion engined cars, this is not a credible pathway to carbon neutrality by 2050

It is stated that:

3.2 The transport network will be on a pathway to net zero carbon by 2050
through mass electrification, reduced use of fossil-fuels and local living. It
will also be safer and more efficient overall with more walking, cycling and
use of public or shared transport and less congestion on major routes that
connect West Sussex towns with Gatwick Airport, London and nearby
cities.

Mass electrification (presumably of motor cars?) will be unable to deliver zero carbon by 2050. While prioritising improvements to the road network for motorists, how could this be a realistic pathway towards net zero carbon? What is required are severer reductions in motor vehicle traffic volumes and speeds in parallel to the electrification of motor-vehicles. The paragraph above also mentions local living, walking, cycling and use of public or shared transport but there are no solid commitments to make necessary changes that would allow these transitions towards sustainability.

The Wording of the Document is at best Tepid about Realistic Changes Needed to Improve Active Travel and/or Local Living

Birmingham has announced what it calls a “transformative” transport plan that will see the car-centric city becoming a super-sized low-traffic neighbourhood. Virtually every neighbourhood in the Netherlands has been engineered to reduce motor traffic and enable sustainable local living. France, Germany and Belgium are quickly following the Dutch example. London Transport has introduced traffic reductions in the centre of the city with the Congestion Charge Area. London Transport have also implemented Low Traffic Neighbourhood zones LTNs in many areas across London – including Camden, Croydon, Ealing, Hounslow, Lambeth, Newham and Waltham Forest. Brighton is implementing Low Traffic Neighbourhoods. Bristol is implementing Low Traffic Neighbourhoods too.  York is now banning cars completely from its city centre.

By contrast WSCC’s new Transport Plan states that:

“The County Council is unlikely to be able to deliver the Plan alone as it has neither the resources, statutory powers nor funding to do so.”

The WSCC’s position on Low Traffic Neighbourhood schemes, is that these might only be considered if they are felt to meet undisclosed feasibility criteria. The policy states:

[WSCC may] Consider traffic management measures (e.g. expanded pedestrianisation, school streets, filtered streets and low traffic neighbourhoods) in urban areas where these are feasible and deliverable, and there is wide support from local stakeholders.

Despite West Sussex having only 75 miles of dedicated cycle provision that is mostly disjointed and of of poor quality, WSCC do not foresee prioritising of funding towards expand the cycle network. Reallocation of space is dismissed as it conflicts with the councils perceived need to maintain a culture of car dependency. It is stated in the draft policy:

The cost of new infrastructure is likely to outweigh the available funding for the foreseeable future and reallocating road space can result in conflict between different road users.

The draft policy recommends only to “provide good quality active travel infrastructure based on latest design guidance” where WSCC feel this may be possible.  Experience shows WSCC rarely consider DfT standards compliance is feasible even for brand new greenfield developments. Chicycle members insist all new active travel infrastructure absolutely must be of adequate practical standards of usability meeting or exceeding LTN1/20.

The draft document paragraph 4.29 singles out provision for cycling as particularly likely to “create conflict within communities or local environmental impacts“! By comparison, road building schemes and upgrading of road capacity receive only two references to environmental impacts and this is then only considered as a community concern rather than a cause of conflict. Is it really fair to hesitate from implementing Dutch style walking and cycling provision because creating liveable communities might really cause conflict and environmental impacts?  

Poor Quality A259 NMU Chichester to Emsworth Conversion of Village High Street Pavements into Cycle Tracks is listed as part of the Short term (2022-27) priorities for the Chichester area.

There is also mention of Westhampnett where a similarly poor quality and unsuitable shared pavement scheme has been installed.

Current DfT standards forbid the conversion of urban pavements into shared use cycle tracks. Previous DfT guidelines strongly recommended against it, particularly where frequent side-roads and driveways are crossed by the shared path.

ChiCycle members fear other active travel schemes listed in the draft policy are likely to be of equally poor quality and also substantially fail to meet DfT standards for walking and cycling.

We are in complete agreement with national policy on walking and cycling (Gear Change), particularly where it states that:

We do not seek perfection – but we do demand adequacy.
We would rather do nothing than do something inadequate.

Wasting public money on poor quality schemes that are only pretend token gestures towards supporting active travel is a criminal misuse of resources. It is worse than doing nothing because it severely reduces the possibility of future worthwhile interventions.

WSCC have been rightfully penalised by national government for misuse of public funds.  They are the only authority in the country to be told it could not apply for money in the next phase of the Active Travel Fund. ChiCycle members hope WSCC will begin to learn important lessons and start planning worthwhile schemes that at least comply with national minimum standards.

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