Comments from (ie name of organisation, or surname): Action Access A1079

Action Access A1079 is a newly-formed regional partnership, comprising local councillors, organisations, and individuals based in the A1079 corridor.

i) To improve the safety record of the A1079 by making access onto, from and across the road safer and by reducing the delays on the route by various means.

ii) To improve the flow on the A1079 in order to improve the economic outlook from, to and within the region.

iii) To improve the sustainability of the area.

C1. Why do you oppose the policy in the draft Plan ?

First of all there is much good work in the draft Plan, and we particularly welcome the following aspects of the Regional Transport Strategy (RTS):

1. The RTS puts a strong emphasis on enhanced public transport, and it is therefore to be hoped that some improvements in public transport choices in the A1079 corridor may be forthcoming.

2. There is a realistic understanding of the reasons why people need to travel. One of the best sections of the strategy relates to “access to employment and social infrastructure issues”. This notes that the ideal solution to transport problems is to reduce the need to travel in the first place, and sets out requirements for ensuring that populations are located close to work, health, education, and leisure/retail facilities. This is a significant statement.

3. Another section of the RTS looks specifically at the York sub-region. Although it tends to see Malton and Selby as the main constituents of the sub-region, from the point of view of transport planning this should help to achieve a more holistic view of the A1079 problems than is currently possible at the level of the three local authorities.

4. The RTS has a section (T8) dedicated to rural transport, and recognises that “remoteness of populations and settlements can make access to services, and therefore the provision of traditional public transport prohibitively expensive.” It goes on to state “whilst it is desirable that this access to services is improved by means other than the car, and for people without access to a car, an issue that makes rural accessibility distinct from urban is that it is access to services per se that is important, regardless of mode. This highlights the fact that transport is a means to an end and not an end in itself.”

This enlightened statement is one of the few places in the strategy where there is any recognition that public transport is not always the most appropriate transport choice – especially in rural areas such as the A1079 corridor.

We have identified the following weaknesses in the Regional Transport Strategy (RTS):

1. For most road users, especially on the A1079, road safety is probably the number one concern, yet amazingly there is no discussion of road safety in the RTS. As one of our respondents put it, there is “no margin for error” when driving on the A1079.

2. The single biggest weakness of the RTS is the lack of linkage with the regional housing strategy. The evidence available locally, such as from the Dunnington study, does not seem to have been considered by regional planners, and as a result the connection between housing development in East Yorkshire and congestion on the A1079 is not recognised at the regional level. In fact there is very little cross-referencing between the RTS and the housing strategy, suggesting they have been developed in isolation of each other.

3. The regional housing strategy is at a far more advanced stage of readiness than the RTS. We think it is important that the transport strategy should be developed to the same level as the housing strategy. If this does not happen then continued large-scale population growth in the A1079 corridor will cause even more congestion and road safety issues.

4. With one exception, as noted above, the RTS is underpinned by an unexplained assumption that all private car use is inherently wrong. This damages the credibility of the entire strategy, and undermines much of the good work it is trying to achieve. It is also not clear whether this approach is affordable, not least because of the financial implications of a large-scale modal switch from the private car (which generates revenue through petrol taxes) to (subsidised) public transport. The RTS is written primarily from the urban perspective, and tends to assume that universal public transport is available and affordable. This may be achievable in large conurbations like London and Leeds, but is probably not sustainable in the A1079 corridor. It is important that the RTS addresses the needs of all transport users, not just those in urban areas. By failing to make positive proposals on how public transport can be integrated with private car usage the strategy limits its viability as a basis for transport planning for most of the East Riding.

5. The RTS suggests that local authorities could introduce congestion charging as a measure to reduce use of the private car. However a weakness of the proposed approach is that it only addresses the demand side of congestion, and not the supply side. Since population growth is a major factor in the growth of transport demand in the A1079 corridor, this one-sided approach is inadequate, and could lead to a situation where congestion charging becomes simply a revenue-raising opportunity for local authorities. (The widespread public concern about the funding arrangements of Safety Camera Partnerships is an important precedent for what can happen when local financial imperatives are allowed to influence good transport policy).

6. There is very little discussion of environmental issues in the strategy; what discussion there is relates to the environmental impact of air travel rather than road transport. This is surprising given that transport (whether public or private) is one of the major contributors to pollution.

7. The strategy identifies a range of targets which will be used to measure successful implementation. However, although there is a very large number of these targets, the focus is narrow - reducing the number of parking spaces, reducing distance travelled by private car, percentage of passengers using non-car modes to get to local airports, and so on. This narrow base is likely to compromise management of the implementation. We feel it is particularly an issue for the A1079 corridor where transport choices are so limited, and such a narrow range of measures is unlikely to allow progress of the strategy to be properly managed.

C2. How, specifically, do you want the draft Plan changing ?

We should not forget that the current problems of road safety and congestion on the A1079 did not arise by chance. They are the result of planning decisions taken in the past, where national and regional strategy has in some cases been allowed to override local needs. In a nutshell, large-scale housing development in the A1079 corridor, without corresponding investment in transport infrastructure, has directly contributed to the current situation of congestion and frequent accidents on the A1079.

We believe the following points will help to improve the Regional Transport Strategy and the overall Regional Spatial Strategy.

1. The RTS needs to incorporate far more consideration of road safety issues. It needs to clearly define the relationship between road safety and road capacity / congestion, and identify how roads such as the A1079 should be made safer for all users. Road safety must be embedded at the heart of the RTS, and this is currently not the case

2. The Regional Spatial Strategy anticipates further large-scale population growth in centres such as Hull, York and Leeds. We think it is vital that the RTS should consider, in detail, how this will impact key regional road links like the A1079. We have seen, over the last 10 years, what happens when populations are allowed to grow without corresponding investment in local infrastructure. We therefore believe one of the main deliverables of the RTS should be a detailed statement of how transport investments will be made to accommodate the planned growth in populations, in order to ensure that road safety and congestion is improved rather than worsened.

3. The RTS perpetuates the view that the A1079 corridor is primarily used for access to York. This is outdated, and it is known from local monitoring that much of the traffic on the northern A1079 is travelling to and from Leeds and West Yorkshire. If public transport is to provide realistic solutions for commuters in the A1079 corridor then planners need to avoid directing travellers into the centre of York simply to allow them to travel onward to Leeds (or to Monks Cross / Clifton Moor).

4. There is some mention of community-led projects to revitalise local rail services by bringing them into some form of community ownership. In a similar vein we would like the RTS to provide more encouragement for local community groups which wish to take a more direct involvement in the management of roads such as the A1079 which are crucial for the local economy.

5. It is particularly important for the RTS to identify the environmental cost/benefit of the “modal shift” that it seeks to achieve, and the environmental impact of congestion. The strategy needs to demonstrate a clear understanding of the environmental consequences of its various proposals in semi-rural areas as well as urban areas. It should also provide more information about the environmental impact of public transport vs private car so that the public, and local authorities, can be better informed about travel choices. The RTS does already recognise that the environmental impact of public transport in areas of low population density can be disproportionate, but more detailed evidence and advice would help local authorities to get the balance right in their Local Transport Plans.

6. We would also like to see updated guidance in the RTS for the appropriate use of safety cameras, and their funding arrangements. (There is a range of views within our Group about the deployment of safety cameras, with some in favour and others concerned that they do not address the real causes of accidents on the A1079).

7. The RTS places considerable emphasis on restricting parking, as a way to force people away from the private car. This may make sense in urban areas, but is a threat to public transport adoption in market towns like Pocklington, Market Weighton and Stamford Bridge, where lack of free parking and inadequate parking capacity prevent users from choosing public transport alternatives for parts of their journeys – leading to further congestion on the A1079. Increases in population in the last 10 years have led to a serious erosion in parking capacity in the A1079 corridor. (Population growth in the East Riding in the last 10 years is the second highest of any region outside London). Reducing car parking capacity without providing real alternatives is known to increase congestion, not reduce it. The RTS also seeks to impose a common approach across the region, but market towns in the A1079 corridor have very different parking needs to urban areas. We believe that parking strategy must be determined at the town or parish level, not regionally, in order to ensure that adequate parking capacity is available in local towns to meet the needs of the local community and the local economy. It is perhaps worth noting that at the time of writing there is an active public campaign in Pocklington over the retention of free parking, which is under threat from the local authority.

8. It would also be helpful for the Plan to define the environmental impact of the parking strategy, and the targets for reducing car parking in new housing and office developments. We recognise that there is an entirely separate chapter of the RSS devoted to the environment, but further consideration should have been included in the regional transport strategy.

9. Both the parking strategy and congestion charging proposals in the RTS offer revenue-raising opportunites for local authorities. There is a risk that local authorities may seek to take these proposals forward for purely financial reasons, without considering those parts of the RTS that relate their responsibilities for reducing the need to travel in order to access work, education, and leisure facilities. Penalising motorists without providing real alternatives is merely taxation, and an economic burden on the local community, and will not achieve the desired modal shift. We would therefore like to see robust measures in the RTS to ensure that parking and congestion charging is not seen as an easy revenue stream for local authorities.

10. The Action Access A1079 group would like to see the congestion-charging proposals in the strategy extended to cover the supply side of congestion, in order to address situations where population growth is generating congestion. Under such a scheme, local authorities which allowed housing and other developments to go ahead without investing in local transport capacity would also be required to pay congestion charges. There is already good evidence that local authorities respond very quickly to the prospect of financial penalties – recent progress in regional waste recycling is a direct result of the threat of central government fines on local authorities who exceed landfill targets.

11. The list of transport investment and management priorities cited in the RTS does not include the A1079 corridor. The invisibility of the A1079 corridor as a strategic route means that it is overlooked in planning and investment decisions, even though it is a key link from the biggest port infrastructure in the country (Humberside) to the north east of England The fact that the management of the route is now split between Hull, York, and East Riding councils only worsens the situation, with no single authority having overall responsibility. The local authorities believed at the time that de-trunking the A1079 would allow them to bid for supplementary grants to help improve capacity and safety, but this has turned out not to be the case. We would therefore like the RTS to offer opportunities for roads such as the A1079 to be “re-trunked” in order to ensure proper investment in road safety and capacity.

12. We would like to see progress in the implementation of the Plan measured through a small number of high-level real-world measures, rather than the raft of low-level measures currently proposed. What is needed are simple indicators that allow the implementation of the strategy to be measured in terms that make sense to real transport users. A good example of a “real-world” measure that has been developed locally is queue length at key junctions. We want to see measures that focus on how the transport infrastructure is being developed to improve road safety, prosperity, quality of life, sustainability, and promote economic development.