I do not agree with the preferred sites for housing development. The BX116 site should be removed from the list.

Overall Comment
Although some reference is made to traffic no solution is offered nor attempt made to quantify the impact of the development proposed sites. Based on the figures published in 2011 for the link road submission this overall level of development is likely to increase the traffic of the A259 by between 14000 and 20000 vehicles per day. Current levels of traffic measured on the A259 provided by Highways England show a figure of 21500 vehicles per day. Based on the figures given in TA79/99 Part 3 the A259 through Little Common can be classed as Road Type UAP3 with a capacity limit of 900 vehicles per hour. Measured (by Highways England) peak traffic is recorded at 869 vehicles per hour and the total proposed new build will add at least 171 vehicles/hr, more likely a total of up to 1200 vehicles per hour will be reached, leading to gross overloading of the road and roundabout at Little Common. As regular drivers along this route will know the eastbound flow in 2015 often has mile long queues and the westbound flow queues can be in the order of 0.5 miles.

A late appearance of a note about the impact of the traffic generated by the proposed developments does little to relieve the concern. (This document does not meet the full requirements of Guidance on TransportAssessment - DoT 2007.) There are a number of reasons for this. The housing data does not reflect that current figures used elsewhere in the DaSA documentation and there is no reference to any industrial development that is considered so important to the mix. The traffic is assumed to be all cars whereas the road carries a significant portion of HGVs and regular buses that add to the volume and delays experienced by users at present.

No effort has been made to consider the combined impact of the new junction/lights required to provide access to and egress from Barnhorn Green (already granted planning permission) nor the pedestrian crossings before and after the roundabout and that a primary school is also situated close to the roundabout. Surprisingly all the data used assumes that all approach roads to the roundabout have a 99999 vehicle per hour capacity. This is clearly incorrect as the A259 has a capacity limit of 900 vehicles per hour and the minor road much less.

To show traffic exceeding a realistic limit makes the results of this study count for little. As is already experienced by A259 users queue lengths can be long without the impact of the new road junction and traffic lights west of the Little Common roundabout.

Please see more detailed comment and analysis at Appendix 1.
Making provision for Population Movements

If the presumption is now in favour of (housing) development then it is illogical and inconsistent not to have a presumption in favour of infrastructure development also. In particular the need to enhance road capacity to meet the expected demand new development generates.

The only sensible way to improve capacity for viable longer term traffic flow across Bexhill is to provide a new northern bypass between, say, the Lamb Inn and the Ninfield Road so linking with the new western extension from the Link Road. Undoubtedly such new construction of this nature should be part funded by the CIL raised from developers. This would be easier if the developments permitted were to follow round the north along the route of such a new road and make sites such as BX101 and BX 80 more accessible.

This approach has already been outlined in the adopted Core Strategy that states:

8.12 Growth also provides an opportunity for the town. Development has been focused on urban redevelopment in recent years, as limited transport capacity on the A259 to Hastings has frustrated new sites being developed. A high proportion of this has been flatted chemes, often for older people. However, there is the potential for sustainable urban extensions, subject to additional traffic capacity.

8.47 Housing growth may both stimulate business development as well as help otherwise achieve the vision for the town. However, large-scale growth would not be consistent with the objective of retaining its essential character, nor with the commercial property market. Even within these other sustainability parameters, the very limited highway capacity, primarily along the A259 trunk road towards Hastings but extending through the town, is a real constraint upon development at present.

8.56 Development to the west of Little Common, both north and south of Barnhorn Road (A259), will also be considered. Again, the area enjoys an attractive pastoral character, but without impacting on the wider landscape for the greater part. It also benefits from reasonable access to shops and services at the Little Common district centre. Access would need to be created directly off the A259, supplemented by existing estate roads. Whydown Road and Sandhurst Lane are unsuitable access roads.

There appears to be little point in having a strategy published and approved if some of its fundamental points are to be ignored.
Critique of Transport Note dated November 2016 (Exigo)

Introduction

This document addresses the A259 Little Common Section but fails to state any practical capacity limits on the road or other traffic relevant infrastructure such as crossings, traffic lights or the Little Common roundabout. The computer modeling used appears to have no practical limits set and it produces results these bear little, if any relation, to the perceived behavior on the A259 at this location.

The so called SHLAA sites to not correspond totally with the Preferred Options in the DaSA and so render the overall results as unreliable for drawing any proper conclusions regarding long term traffic impacts. The traffic being modeled does not include any HGV or regular bus services.

Guidance on Road capacities is published in TA79/99 and based on the parameters of this road the A259 may be classed as UAP3 with a capacity of 900 vehicles/hr each way. This is the figure missing from the analysis presented.

The document addresses the situation at Little Common roundabout in isolation. Traffic is significantly affected by the overall environment where a pedestrian crossing is on the east side of the roundabout and there is a Primary School within 0.5 miles also on the east side. Furthermore, the period covered by most of the analysis (ie the future) fails to recognize the existence of the new road junction, traffic lights and pedestrian crossing required to serve the already approved development at Barnhorn Green west of the roundabout.

Before presenting an alternative and more complete analysis there are 2 further comments. This note states it addresses the impact of site BX116. In particular the table at 4.2 stating a current Barnhorn Road queue length of 12 vehicles at the peak hours bears no relation to actual queue lengths now experienced (in the order of 1 mile or approx 300 vehicles). However, it states at 4.3 queue lengths after the SHLAA completion would be 132 and, if Spindlewood Drive (BX116) is added, at 4.8 this is extended to 155 (or a 17.4% increase). If these figures are multiplied by the factor the current situation is out then 25 times these numbers may be the outcome (possible 10 mile queue!!)

Alternative Analysis

Current Traffic figures (possibly measured in 2015) have been provided by Highways England (Table 1) together with a diagram of the Little Common Roundabout (Diagram 1). Projected traffic is based on the housing and industrial premises proposed in the DaSA suitably weighted using the data already published in support of the Link Road submission in 2011/12.

The final situation is quite complex and I have not found a way of determining the cumulative effect. However it is possible to surmise the impact of the new Barnhorn Green access road, the combined effect of the Roundabout , pedestrian crossing and Little Common School and how these would impact on the A259 flow.

While the professional Traffic Analysts have access to advanced software to assist them I have had to use manual methods. My analysis is based on models with fewer parameters but produces results confirmed by current experience of users of the A259. All calculations have been made using Excel spreadsheets. The models are in published documents and the empirical model used to examine the overall situation on the Roundabout follows published work in the USA about a very similar situation.

Current Traffic

The (2015) measured level of A259 traffic reveals a both way 24 hour total of 21452 vehicles with a peak period between 0700 and 1900 when the average levels are 748 vehicles/hr eastbound and 735 vehicles/hr westbound. Max levels at 1000hrs (westbound) and 1600hrs (eastbound) are 750 and 869 respectively. These are carried on a road that has a capacity of 900 vehicles per hour in each direction.

A very recent traffic survey over a 3 day period (September 2016 as reported in Reference A. 3.1.10 revealed total 2 way traffic to be 23530 vehicles/day. This is an increase of 9.6% over a single year.

Projected Traffic

It has not been possible to get projected traffic figures for the A259, so far, from Highways England. So using the TRICS Generation Rates in Table 2 and the DaSA development targets for houses and industrial premises a comparison has been made with the forecast figures published in support of the Link Road submission, See Table 3. The proposed DaSA buildings are shown to generate 1309 vehicles/hour at peak times. An average of 834 vehicles per hr and a daily total of 20000 vehicle movements per day. This figure has been scaled to reflect the difference between this amount of building and that used in the Link Road submission and scaled for the Barnhorn Road levels shown in that submission (See Table 4). This gives a total of 14059 vehicles per day compared to the figure of 19600 calculated for projected building in 2011. This needs to be uplifted by the percentage increase measured in current actual traffic (21500-18200)(*100/18200) or 18%. Giving a prediction of an extra 16570 vehicles per day on the A259.

On the assumption that the traffic pattern follows the curve shown in Diagram 2 the peak 12 hour traffic will be approximately 552 vehicles/hour and the daily traffic both ways increased by about 8285 vehicles. Hence total peak hour traffic demand will rise to approximately 1250 vehicles/hr both ways along the A259.

In Reference A. 5.2.5 the projection for A259 base traffic for 2026 is 27382 vehicles/day. This alone means the peak hour traffic will rise to 1047 vehicles/hr, well in excess of the A259 capacity, without considering any additional contribution from the developments proposed in the DaSA.

Other Planning Applications like Reference A, if approved, will only serve to add further additional traffic (about 160 vehicles per day) to the A259.

Traffic Lights at New Junction for Access to Barnhorn Green

In order to provide access onto the A259 from the Barnhorn Green approved development the Developer proposes to create a junction with traffic lights about 800m west of the Little Common Roundabout. Diagram 3 refers. This junction will be single lane except for the north turning traffic on the west bound lane of the A259 where an unspecified length of waiting space is planned for this traffic. Hence A259 both ways traffic will need to be halted for right and left hand turning traffic from the new access road and for the right turning traffic into the new road the A259 eastbound traffic will need to be halted. Depending on the volume of traffic turning right into the new access road A259 westbound traffic will be halted once the waiting lane is full.

An analysis of the effect of this junction and lights using a 1:4 ratio for the Barnhorn Green/A259 traffic (171:748 approximately). This is shown in Table 5. Using an arbitrary traffic light cycle of 174 seconds this shows average delays of nearly 9 minutes and capacity through the junction of 45% of the demand. Clearly the parameters used for this junction will have a critical and potentially deleterious effect of the A259 traffic flow in the short term and become a very serious blockage in the long term should the predicted traffic levels not be reduced. Reference A also proposes an uncontrolled pedestrian crossing to the east of the Barnhorn Green junction and this will added to delays experience by A259 traffic.

Little Common Roundabout Capacity

The configuration of this road junction is shown in Diagram 1. A check analysis of the circumstances experienced by users of this roundabout and of its capacity has been made (Table 6). This reveals the junction is at design capacity for a lot of the time and explains the queue lengths of about 1 mile experienced by east bound traffic at present.

Future Roundabout Performance

In the future traffic will be increased due to Barnhorn Green and the other developments proposed in DaSA. In particular, the proposed BX116 site will double peak hour conflicting traffic from Cooden Sea Road. An empirical formula has been derived from work in the USA for a similar situation of a roundabout, pedestrian crossing and local school and is felt appropriate to adopt this to predict the effect on traffic of the Little Common Environment. Table 7 presents this analysis and shows queue lengths of 1 mile (today) extending to 3 miles (post Barnhorn Green) and then 7 miles following
completion of all developments. (Note that the impact of the turning traffic into Barnhorn Green junction examined above has not been factored in). Such a situation would be intolerable for A259 users and local residents and must not be allowed to just happen through inaction to achieve rerouting of traffic. The impact on emergency services is also likely to be severe. Specifically, ambulance access to, and transfers between, the Eastbourne DGH and the Conquest at Hastings.

Conclusion

The traffic loading of the A259 has been a matter of concern for many years although no mitigation schemes have been completed in full. This latest proposed round of building in the Bexhill area will cause even greater loading on a trunk route already running to near capacity for a significant part of each working day. In recent years the traffic levels have been steadily rising. Analysis shows that the total anticipated additional traffic load will saturate the road and the Little Common Roundabout unless steps are taken to provide alternative routes for traffic traversing the district. A total approach to the problem is required rather than the current situation where planning responsibilities are divided and communications between the players appear to be inadequate. Further, analysis of the potential problems should not rest solely with those who have a vested financial interest in individual projects but with public servants who should be able to provide a proper overview of the complete situation. Piecemeal examination of the effect of individual developments does not reveal the full picture.

Additional supporting information was supplied which can be viewed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28223