Policy TR2: Integrated Transport

To be effective the location of the proposed cycle network needs to be specified as the existing bridleway network is insufficient and all roads in the District are narrow and unsuitable for installation of cycleways.

Shepway District Council supports policy that promotes a sustainable transport system.

This policy of "promotion of public transport patronage" can only be effective if there is a real commitment to improving public transport provision in rural areas. Bus services in particular do not run late enough into the evenings or frequently enough at weekends to encourage or enable those living in rural communities such as Sedlescombe to forgo their cars. This is particularly difficult for young people who have no access to private transport and have to travel to the larger towns for college or employment.

Policy TR1 will not support the objectives set out in para 18. The Bexhill to Hastings Link Road (BHLR) will not improve regional accessibility; it will encourage car use for short trips; and this in turn will undermine the market for alternatives. Enhanced rail services could improve regional accessibility however.
So, we strongly oppose the BHLR (TR1i). The associated bus and cycle improvements referred to may be delayed because the use of ESCC funds to fund the BHLR could delay 'alternatives. This is the view of ESCC expressed at an LTP3 meeting held in Eastbourne Town Hall. It then follows that the investment in providing transport choice (TR1iii) will give a poorer return in benefits because the alternatives will have to operate in an environment where the car will for many be the first choice of mode.

In respect of TR1 iv, the investigation of potential is unnecessary as sufficient work has already been carried out to establish the case for the station. Adopting this part of the TR1 policy is effectively calling for previous work to be ignored, thus delaying the provision of the station. It is already 20 years late. (See ESCC/MottMcDonald study of Glyne Gap station, 2004)

We note comments at 18.35 but would comment that bus services to stations would be undermined by the provision of extra car parking and CO2 footprint would increase. You do not recognise this in your document. Service 318 serving Etchingham station is an example and its enhancement and that of other services to local stations would achieve the accessibility objective in a more sustainable way. Train taxis also merit a trial and will feature in the Abellio franchise offer for Greater Anglia railways.

Policy TR2 will be harder to deliver since the BHLR will encourage greater use of the private car, especially for short trips. Support the i - vi components. In the light of patchy and inconsistent services, suggest additional TR2 vii:

'working with the transport authority (ESCC) and operators, seek provision of enhanced weekday, weekend, Bank Holiday and evening services'.

And additional TR2viii:

'working with ESCC, secure real time and other high quality information systems for buses.

A new TR2 ix would read:

'working with ESCC to implement a programme of 'smarter choices' and traffic demand management'

This would include measures such as controlled parking zones in Rother DC locations; workplace travel plan implementation; travel planning exercises on key corridors such as A21 south of Tunbridge Wells, and A259 from Little Common to Ore;

For policy TR3, the BHLR and its associated housing development will determine the first mode of choice as the private car. Aspirations of TR3 will be undermined. We and many others think that this is a realistic view. The policy itself is something we could support but in the context of support for BHLR it is difficult to see how it could be successfully implemented. If the development is to be 'sustainable' there should be a target for trip levels to be attained by non-car modes. That requirement could be expressed as part of TR3i. We suggest that it is amended accordingly.

Policy TR4 is vague and ambiguous. The meaning of 'residual needs' and 'localised circumstances' is not clear to us. Pressure for car use in, for instance, those developments associated with BHLR would lead to a 'high residual need' - as would the provision of a poor bus alternative. A high level of bus services would not be likely out on those developments so TR4ii would not apply widely as a demand management tool. It is assumed that 'high level of accessibility to jobs, services and facilities means 'by alternatives to the car', but it is not clear. It would be legitimate in pursuit of reducing carbon emissions if an aim was included to reduce 'residual need'

TR4iii precludes change of use to, for instance, pedestrian zones, bus lanes/build outs or cycle storage, or landscaping/play areas. We object to this. We would like to think that car use has peaked and therefore that we need to be open to that possibility.

Policy EN4 fails to recognise and therefore does not address the problems of moving or parked vehicles degrading the quality of the public realm. Constant occupation by parked vehicles of places with historic and visual interest has the same effect as street clutter and reduces an attraction to visitors. When it moves, it creates an obstruction precisely where people wish to linger or stroll.

Pressure for parking arising from a lack of traffic demand management policies leads to any open space and urban and rural settings being vulnerable to damage, degradation and visual intrusion from parked vehicles. We suggest a new EN4 iv :

Create vehicle free zones where the presence of vehicles would devalue visual and/or historical interest and enjoyment and obstruct passive leisure activities such as sightseeing.

The same problems afflict the High Weald AONB. We suggest a new policy: EN8. This would be something along the lines of:

EN8 Building on existing networks, secure high quality, comprehensive public transport access opportunities to the High Weald AONB equal to those existing and planned for the South Downs National Park, with supporting parking controls.

Reason: ESCC and the South Downs National Park are jointly working on access improvements so experience is being gained which could easily be applied to and benefit the High Weald AONB, thus sustainably securing economic benefits and improving access not just for visitors but for all residents and workers.

CONCLUDES

Please Note:

I apologise for not adhering strictly to the format. I am unfamiliar with this type of on-line response, and require a training course.

The responses are simply comments on policies in the TR and EN sections of the Proposed Submission Core Strategy and do not relate to the descriptors at 6 and 7.

Nevertheless I hope that the meanings imparted are clear and that the submission will be accepted.

Support improvements in the provision and use of sustainable transport, in particular Policy TR2 i. to facilitate enhancements to the rail network and ii. to promote public transport patronage and associated infrastructure. Public transport access along the Rother Valley will be significantly enhanced following the reopening of the railway between Bodiam and Robertsbridge to provide a direct link with main line rail services.

THIS IS A ROBUST POLICY ON IMPROVING THE PROVISION AND USE OF SUSTAINABLE TRANSPORT, IT ACCORDS WITH THE OBJECTIVES OF OUR LOCAL TRANSPORT PLAN AND THEREFORE IS SUPPORTED BY THE COUNTY COUNCIL.

Natural England welcomes the policies in SRM1 Towards a Low Carbon Future, TR2 Integrated Transport and TR3 Access and New Development in the Rother Core Strategy.