Copy of the letter sent to the Planning Department at Wycombe District Council on 24th November 2017.
CONSULTATION ON PUBLICATION VERSION OF WYCOMBE DISTRICT LOCAL PLAN
Please consider the following representations from the Penn & Tylers Green Residents Society on the above version of the Local Plan. These representations incorporate those of the Ashwells Forum group of residents and of the representative on the WDC Liaison Group from Chepping Wycombe Parish Council.
Firstly, it is our view that the Plan complies with the provisions of s.20(5)a of the Planning and Compulsory Purchase Act (2004) and is thus “legally compliant”.
Secondly, however, we must respectfully assert that the Plan is not in our opinion sound, when examined against the considerations in paragraph 182 of the NPPF, because it is ineffective in a significant regard, as indicated below.
Our Major Concern
The major concern of all contributors to the letter is the significant increase in traffic through Penn and Tylers Green, particularly past the Middle School, as a consequence of having a new, two-lane route to and from the A40 London Road, via Cock Lane, the Spine Road, and Gomm Road. This increase is likely to be at A40 London Road levels. WDC’s declared aim is to have no significant increase in traffic through Tylers Green and past the Middle School. We maintain that, since it is not practically possible, using the proposed traffic calming measures, to achieve WDC’s intention, the Plan is unsound in that regard and ineffective, because of the harm that will be done to Tylers Green.
Furthermore, the planned north end connection of the Spine Road to Cock Lane is not justified on the forecast of only an additional 42 vehs/hr at am peak hour from the Gomm Valley and Ashwell’s sites, so there is no planning need for it.
1. We do appreciate that WDC are trying to address our concerns by making the declaration in the Local Plan (5.1.46) that the capacity of the Spine Road and the northern end of Cock Lane should be restricted by effective traffic calming in order to prevent it becoming an unofficial ‘by-pass’. We note that WDC claim that the effectiveness of the traffic calming cannot be accurately assessed until planning applications and Traffic Impact Assessments have been submitted for both Ashwells and the main Gomm Valley developments. However, we believe that there is already sufficient data available from March 2017 and later, which was not fully considered by WDC, before the Plan was finalised.
2. We see a conflict between WDC’s objective to ensure no significant increase in traffic and Bucks County Council (BCC)’s repeated view that ‘the Spine Road effectively provides an additional route down to the A40 London corridor which some existing traffic on the network may re-divert onto…..modelling work shows that it proves more desirable than some other routes locally…..the additional traffic would be significant…..It is proposed that the stretch of Cock Lane will be widened to ensure the function of the Spine Road is achieved.’ (Cllr Mark Shaw (BCC), 23rd March 17).
3. A Jacob’s study in August 2017 (Countywide Local Plan Modelling, Phase 3 Technical Note) clearly labels the Spine Road/Cock Lane as a mitigation measure – but then shows that it significantly increases travel time eastwards on the A40 from before Cock Lane right out to Junction 3 with the M40. ‘This contravenes Plan Principle 5a), page 89, “Improve congestion on the London Road” ‘.
In this connection, we would draw attention to a recent report, ‘The impact of road projects in England’, commissioned by CPRE from consultants at Transport for Quality of Life (TfQL). This reviewed over 80 official evaluations of road schemes, as well as carrying out four detailed studies of older road schemes. The report challenges what it describes as the misguided belief that expanding the road network can reduce congestion and concludes that road building schemes:
• induce traffic, that is generate more traffic – often far above background trends over the longer term ;
• lead to permanent and significant environmental and landscape damage,
• show little evidence of economic benefit to local economies
4. We have obtained figures based on Jacobs’ modelling for an unconstrained route that shows an increase to almost two and a half times baseline AM peak traffic flow levels (to almost 700 v/hr in each direction) along Cock Lane past the Middle School. Other BCC / WDC figures show that, of this increase, only 3% is a result of the new houses in the Gomm Valley while 97% comes from traffic diverted from elsewhere.
5. These figures are similar for the 200m of Cock Lane, which it is proposed to widen to two lanes. According to Jacobs, the new houses in the Gomm Valley will generate only about 42 v/hr [30 heading north + 12 heading south] at the a.m. peak hour. Neither this prediction nor the one in para 4 above has been questioned by BCC. We are obliged therefore to ask the question, “ Where is the planning need to justify connecting the top of the Spine Road directly to a widened top end of Cock Lane? ”
6. We have been advised by an experienced traffic consultant that, worthy though the detailed traffic calming measures are, as set out in para 5.1.2 of the Development Brief, neither they, nor chicanes or traffic lights will achieve WDC’s goal of no significant increase in traffic past Tylers Green Middle School and will not mitigate or obviate the almost 700 vehs/hr each way at am peak hour predicted by traffic modelling. He says that traffic calming measures can be effective in slowing traffic and making the road safer, but they very seldom result in a decrease in traffic of the magnitude needed here to achieve WDC’s stated aim. His experience tells him that connecting the Spine Road to Cock Lane will unavoidably create an alternative route to the A40 which determined drivers will find. None of the calming measures proposed in the plan is applicable to a widened Cock Lane.
7. There is ambiguity in the application of traffic calming measures, as proposed by WDC and the County Highways Authority. Whilst it has been advocated that the Spine Road and the proposed widened section of Cock Lane are to be treated as one with regard to the assessment of traffic volumes, the application of any traffic calming measures to be applied to the Spine Road and Cock Lane are distinctly different. In the event that the Inspector agrees that it is preferable to stop the Spine Road within the Gomm Valley development and not join it to the top of Cock Lane, then there will be no conflict.
However, the joining of the Spine Road and Cock Lane as proposed will bring into play how the application of traffic calming will meet the stated objectives of preventing it becoming an ‘unofficial by-pass’. Whereas some specific means of traffic calming on the Spine Road have been spelt out, nothing specific has been proposed for Cock Lane. Indeed, the proposed improvement in forward visibility on Cock Lane, which paradoxically has been stated as something to be avoided on the Spine Road, will have the opposite effect. The two roads have quite different characteristics requiring different approaches to the means of deterring their use by through traffic, but this has not been recognised in the Local Plan.
We, therefore, see the only sure way of achieving WDC’s aim of no significant increase in traffic is:
- a) to have no direct connection between the Spine Road and the top end of Cock Lane, but to end the Spine Road in a cul-de-sac. We note that an objection to a cul-de-sac put forward by WDC was that it would be detrimental to fostering joined up communities, but pointed out that this aim contradicts the declared principle of achieving a separation between Tylers Green and the Gomm Valley development,
As an indication of the strength of local support for the views expressed in this letter, we have 539 signatories for an e-petition calling for the above ( see the link :
We should also like to point out that the traffic flow numbers we have used to reach conclusions in our above representations were obtained from Jacobs, BCC’s and WDC’s own traffic consultants, in reports produced for BCC or WDC. A more detailed analysis can be made available when necessary.
If we may, there are other aspects of the Plan to which we wish to draw your attention :
Identity of Tylers Green
Despite ‘Principles for the High Wycombe Area 2a (p.88)” calling for the need to ‘strengthen the Sense of Place …..by ‘respecting and improving the community identity of the adjoining settlements’, Tylers Green is not accorded any identity or any status in the Settlement Hierarchy (p.406) other than being grouped as ‘Hazlemere/Widmer End/Tylers Green’ as part of ‘Tier 1 of Large Urban Area’. We feel very keenly that our very different needs can, therefore, be easily overlooked and submerged by those of the greater High Wycombe area.
2. Land off Penn Road, Hazlemere
In our comments on an earlier version of this Local Plan (our letter to WDC of 1st August 2016), we made strong objection to the developer proposal to take land off Penn Road, Hazlemere, out of the Green Belt in order to build houses. The land is also in the AONB, and we argued that the proposal would constitute a major development in the AONB. This argument was accepted, and the proposal does not figure in the Local Plan under consideration. We wish to declare our strong support for this decision and our wish to argue the case to the Inspector should the proposal be repeated.
3. Traffic congestion
Another key issue for us is the cumulative effect of all the proposals by both WDC and CDC (since our community of Penn & Tylers Green straddles the border of Wycombe and Chiltern Districts ). Their separate proposals combine to increase traffic along the B474 through our village to an alarming degree.
4. Penn School
We are pleased to note that there is no mention of an earlier proposal for a large secondary school in the grounds of the former Penn Special School. We made a strong objection to it because the site and access roads to it are completely unsuitable for a large school.
5. Green space in Gomm Valley
Retention in perpetuity of green space in Gomm Valley and Ashwells, with public access as far as possible, is strongly welcomed. Management of the copse behind Carter Walk needs to be decided.
Finally, because our representations are seeking a change, we do wish to have the opportunity to speak at the public examination.
A copy of this letter goes to Cllrs Katrina Wood, David Shakespeare, Lawrence Wood and to David Anderson, Robert Harrison and Ian Manktelow, WDC, Cllr Ian Forbes, CWPC and colleagues in the Ashwells Forum.
signed by Brian Bennett, Secretary and Miles Green, Chairman of P&TGRS and Ashwells Forum