Main Modifications to the Proposed Submission Core Strategy

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Main Modifications to the Proposed Submission Core Strategy

MOD 8.1

Representation ID: 21482

Received: 26/09/2013

Respondent: Campaign for Better Transport

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We object to this modification for the following reasons:

1. lt conflicts with RDC policy SRM1 which seeks to mitigate the effects
of climate change by promoting sustainable transport;
2. lt conflicts with RDC policy TR2 which commits the council to making
'Improvements in the availability, quality and efficiency of sustainable transport';
3. lt conflicts with RDC's responsibilities under the Climate Change Act
2008 to take action to reduce carbon emissions


Full text:

We object to this modification for the following reasons:
1. lt conflicts with RDC policy SRM1which seeks to mitigate the effects
of climate change by promoting sustainable transport;
2. lt conflicts with RDC policy TR2 which commits the council to making
'Improvements in the availability, quality and efficiency of sustainable transport';
3. lt conflicts with RDC's responsibilities under the Climate Change Act
2008 to take action to reduce carbon emissions

Further reasons for objection:
We note that a station at Glyne Gap is an aspiration specified in the East Sussex County Council
Local Transport Plan 3 (LTP3) - 4.18 and 4.52.
A new station would also strongly reinforce and be highly compatible with all the 'Transport Specific Objectives' and 'High Level LTP Objectives' described in Table 1 of 2.6 of LTP3 (Below). The 'Transport Specific Objective' with the highest score in the table- 'Access to jobs, services and leisure'- would be strongly reinforced by a new station: it would be available to all, including
'persuadable' car drivers- those willing to consider a mode shift to a high quality available alternative. The station would therefore have a high 'social equity' component.

A Table submitted with the representation can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=20674

Additional comments on the recent study by Mott McDonald:
A new station serving this busy and growing shopping and leisure centre on the A259 has always been a popular idea: we have been campaigning for the station since 1986 and at that time, had the support of several businesses on the site. This is an incomplete study that despite its popularity has not engaged with the public at all, and has been carried out with an air of secrecy: the study brief was only obtained through a Freedom of Information Act request. We note that the study:
* Worked on a 'one train per hour in each direction' assumption, so was set to fail;
* Failed to take into account increased passenger numbers arising from enhanced and complementary bus and cycle links;
* Over emphasized the importance of small time penalties against better reliability;
* Includes extra parking as a necessity where none is needed: it would undermine the bus and rail market;
* Didn't include consideration of prospective benefits or opportunities for a reduction in congestion;
* Failed to address the increased attractiveness of 'workplace travel plans' for local workers­
including those at Ravenside itself;
* Ignores the needs of all those seeking high quality alternatives to the car and attractive ticket offers, especially the young;
* Ignores the station's contribution to the ESCC Local Transport Plan objectives in respect of short car trips transferring to public transport;
* Doesn't examine possible alternative patterns of service or future infrastructure improvements that would be the determinants of success for Glyne Gap station; it fails to take account of the signalling upgrade operative from November 2013;
* Doesn't take a strategic view of the transport needs of Bexhill and Hastings- always considered together as a whole - and ignores potential demand management measures that would raise the 'value for money' performance of the station;
* Acknowledges the acute overcrowding on the 2 car Brighton- Ashford service but doesn't offer any solution;
* Leaves a question mark over whether all potential sources of funding have been explored.
At just 3% of the cost of the Bexhill to Hastings Link Road, Glyne Gap station would offer sustainable travel opportunities to a growing number of people- especially the young- who are declining the 'car habit'.
We urge you to reject proposals to adopt the above modification 8.1, policy BX1, in respect of a new station at Glyne Gap.

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