This is the response of Action-Access-A1079 to the City of York Council Local Development Framework: Core Strategy Issues and Options document, which was put out for public consultation in July 2006.

We have assessed section 13 of the Full Document, and parts of the Executive Summary, against the following criteria:

The document does not currently give any consideration to the safety of road users (including public transport users, private motorists, commercial vehicles, cyclists, and pedestrians). We would like to see more evidence of transport policies which put the safety of all road users as a top priority. The following factors can help to improve road safety:

• Reducing congestion
• Better road design
• Reducing the need to travel (this is not the same as pricing people off the roads)

By its nature, transport planning deals with the flow of people, goods and services between locations. Often these flows do not fit nicely into the artificial boundaries of local authority areas. 

Unfortunately the document  has very little evidence of partnership working. We would like to see closer engagement with neighbouring local authorities, public services, businesses, and transport users outside of York. The responsibility of the York LDF does not stop at the city walls. The public transport choices available to communities and businesses along the A1079 corridor fall far short of the high quality services available within York, and it is vital that the York LDF recognises the needs of the large (and growing) number of commuters for whom “reducing dependence on the car” is simply not an option.

We understand that East Riding Council was not notified of a recent traffic study commissioned by City of York Council at Kexby – even though most of the York-bound traffic of the East Riding flows through Kexby. It is vital that local authorities work together to build a whole-systems customer-focused management plan for the A1079 corridor, and the communities they jointly serve. 

York is not an island. The York LDF must consider the needs of transport users from the surrounding areas, including those for whom York is merely an obstacle en route to Leeds and the West Yorkshire conurbations. The lack of such consideration seriously undermines the credibility of the entire Issues and Options document.

We have identified Grimston Bar as the most congested section of the northern A1079. This congestion is a significant barrier to all road users in accessing services, jobs, educational and recreational activities. It also has a growing impact on the quality of life of settlements in the Grimston Bar area and along the northern end of the A1079. Studies have shown that rat-running through Elvington and towards Stamford Bridge is a growing concern, as road-users seek to avoid the peak-time queues on the A1079 and the Grimston Bar roundabout.

The jewel in York’s transport strategy is the Park and Ride (13.4), which the document is justifiably keen to promote. However the Park and Ride at Grimston Bar is part of the problem as well as part of the solution. We would like to see the Issues and Options document examine ways to improve the operation of the Grimston Bar Park and Ride, and reduce the congestion that it causes. Some particular aspects that could be further considered are:

• The overall capacity of the Grimston Bar interchange may have been reduced by the Park and Ride, which pulls traffic across the interchange. In hindsight the Park and Ride is probably on the wrong side of the interchange (i.e. it should have been located outside of the A64). Given that it is probably not possible to rectify this problem, the Issues and Options document needs to develop proposals for improving traffic flow in this area.
• The hub and spoke nature of the Park and Ride system means that it does not offer a solution to transport users wishing to access the growing number of retail and employment opportunities around the York ring-road. We think the Issues and Options document needs to examine traffic patterns between the A1079 corridor, Askham Barr, Monks Cross, and Clifton Moor and assess how develoment at these sites is pulling traffic away from the city centre (as well as generating car journeys that might not otherwise have occurred). Alternatively, it will be necessary for the York LDF to place constraints on further development of these locations.
• Our studies have shown that much of the traffic at Grimston Bar is between the A1079 corridor and West Yorkshire, rather than between the A1079 and York. We would like to see proposals in the document for ways to take this traffic off the Grimston Bar interchange. This would relieve a major source of congestion and improve the quality of life in the surrounding area, as well as relieving pressure on neighbouring routes in the Elvington / Dunnington / Stamford Bridge area.

We have identified that housing and commercial development is a key contributor to congestion on the A1079. It is therefore important to ensure that housing and development plans in the York LDF are linked with corresponding investment in transport infrastructure. 

The Options and Issues document does not currently recognise this important linkage. There are two key points to be addressed. 

1. Firstly, economic development in York and along the York ring-road will create demand on the transport infrastructure, but the document does not explain how this demand will be met (whether by private or public transport or a mixture). 

2. The document does not adequately consider how economic development in York will affect transport demand outside of York. Figures from East Riding of Yorkshire Council show a 25% increase in population in the A1079 corridor in the decade to 2001, with considerable growth expected in the decade to 2011. York is a primary destination for much of this population growth in terms of employment, social, education, and leisure activities – and hence the York LDF is a key driver of this growth. It is therefore crucial that the Issues and Options document should lead the way in ensuring that transport infrastructure planning keeps pace with the population growth.

The York Issues and Options transport strategy is based around reducing car usage, and draws upon central government planning guidance to support this approach. However it fails (13.3) to recognise that there are specific factors driving the growth in congestion in the York area – namely a high population growth rate in the A1079 corridor – that makes much of this guidance redundant. Whilst it is important that local strategy should be aligned with national strategy, it is also important that transport solutions reflect the local situation, and this is currently not the case. 

The document (13.4) states the importance of “reversing the trend of growing traffic levels”. However the only measure proposed is reduction in parking capacity in York City centre - hardly a credible policy. We think the York LDF needs to take a broader view:

• Demand management should consider the whole York area and surrounding areas, not just York city centre.
• The population growth in the A1079 corridor means that York should be actively increasing parking capacity, not trying to reduce it further (in other words parking capacity and demand management needs to be assessed relative to the population for which York is providing services).
• Any transport policy based solely on demand management and not taking into account the supply of transport infrastructure is clearly unsustainable. We need to see evidence of how the York LDF will manage the supply of transport infrastructure (parking capacity, public transport, road capacity and so on).
• Public transport is heavily subsidised, essentially by private transport through petrol taxes. The document needs to consider the financial consequences of a large-scale modal shift to public transport.
• The LTP2 integrated transport subsidy for York is currently 109% higher than the subsidy for East Riding (and 32% higher than the regional average). This inbalance in public subsidy for integrated transport is a significant barrier to end-to-end integrated public transport solutions which should link the growing population of the A1079 corridor with York, its primary hub. The Issues and Options document needs to include fully-costed proposals to support its objective of further increasing public transport capacity in the city, without corresponding investment outside of the city.

The document also needs to consider (13.5) where public transport is, and is not, an appropriate solution. There are growing concerns that public transport in general has significant environmental costs, particularly in areas of lower population density. By focussing solely on demand management the document gives itself little opportunity to explore solutions for reducing the need to travel in the first place.

The document does not demonstrate any understanding of the importance of integrating parking strategy with transport planning outside of the city boundary. If existing car users are to be encouraged to switch to public transport for work or recreational journeys into York, it is important for the York LDF to have a clear strategy of working with neighbouring local authorities and town and parish councils to develop parking solutions which can help reduce congestion on routes such as the A1079. 

In essence the challenge for the York LDF is to manage the interface between incoming road traffic (whether goods or people) and the "within the walls" (wherever the virtual wall is placed) non-road traffic.

In summary, we feel the single-issue focus of the transport policy set out in the Issues and Options document is essentially unsustainable, and is a barrier to effective solutions for the transport challenges faced by York and the hinterland that it serves. The York LDF should have a broader base, reflecting the balance between public and private transport choices and cost-effective transport solutions.

“Remoteness of populations and settlements can make access to services, and therefore the provision of traditional public transport prohibitively expensive.”

“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.”

It is clear that the Issues and Options document is somewhat at odds with this balanced approach. The cause of this issue is that the document tends to regard York as an island. We think the transport strategy of the York LDF needs to be firmly planted within the overall regional transport strategy. It cannot exist in isolation because transport infrastructure, by its very nature, is the basis of inter-dependence between regions, and is no respecter of artificial city boundaries.

We have serious reservations about the fitness for purpose of the transport strategy section of the LDF core as presented in the Issues and Options document. The document is underpinned by an isolationist attitude which is, in our view, at odds with the demands of modern integrated transport planning, and the role of York as the focal point of our region. 

The York LDF transport strategy is summarised in one line in the executive summary: "to reduce dependence on the car". This is an admirable objective, but the Issues and Options document does not provide enough evidence that long-term transport planning can be built around this single-issue approach. A particular concern is the way this approach conflicts with other aspects of the Core Strategy, and with aspects of the LDFs of neighbouring local authorities (in particular housing and development strategies) and the regional transport strategy. We really need to see a more comprehensive analysis of the issues facing transport users, and realistic solutions to the needs of all transport users – not just those who happen to both live and work within the walls of the city.

York is one of the major tourist destinations in the UK, and an important rail and road hub. It is also the a  primary destination for the communities of the A1079 corridor for access to health services, employment, education, retail and leisure services. It is therefore surprising that in an Issues and Options document of 110 pages, only 4 pages (i.e. chapter 13) are devoted to transport issues, and there is no consideration at all of how York fits into the wider hinterland that it serves. 

It is hard to escape the conclusion that the Issues and Options document does not understand the strategic importance of an effective transport strategy. When our group (Action Access A1079) was first formed many of us felt that reducing congestion and improving road safety were simple self-contained goals with little dependence on much else. However over the past few months we have come to realise that transport infrastructure underpins and enables almost every aspect of the regional spatial strategy, and many of the problems now faced by our region are the result of failures in transport planning in the past.

The transport strategy of the York LDF is an opportunity to make a real contribution to the future of the city and the surrounding area. York is the focal point of the region, and the York transport strategy should demonstrate a comprehensive understanding of the challenges faced by our failing transport infrastructure, and lead the way with its regional partners in establishing sustainable transport solutions to meet the needs of the city and neighbouring communities. The Core Strategy Issues and Options document needs further attention to ensure that the York LDF can deliver this vision.