Local Plan 2011-2031 Proposed Submission Draft

Policy SP6: Sustainable Transport and supporting text

Objection

I object to policy SP6 and its supporting text on the basis that the evidence base supporting the policy is flawed.

Policy SP6 states that the Local Council will deliver accessibility and promote the use of sustainable transport modes insofar as reasonable and practicable and sets out a number of objectives. Objective a. is to comply with the provisions of the Hertfordshire Local Transport Plan and other supporting documents as considered necessary.

However, the Hertfordshire Local Transport Plan and its current supporting documents are fundamentally flawed in its consideration of the transport implications for North Hertfordshire in that they fail to take into consideration recent and proposed development within Luton Borough and the associated generated traffic flowing along the A505 into North Hertfordshire.

Furthermore, the Council's transport related evidence base also fails to take this traffic growth into consideration. The key evidence documents are as follows:

* The North Hertfordshire Local Plan Testing Technical Note prepared by AECOM dated 6th July 2016

* The Local Plan Transport Technical Review prepared by Odyssey Markides dated 23rd September 2016

The North Hertfordshire Local Plan Testing Technical Note prepared by AECOM looks at what impact the preferred Local Plan Scenario would have on the transport network in the future and sets out a series of proposals for mitigating existing transport issues issues generated by the new development proposed in the Local Plan. However, the technical note fails to factor in trip generation from both recent development in Luton such as the expansion of Luton Airport, and development proposed within the Luton Borough Local Plan travelling into North Hertfordshire along the A505, A602 and B656 to access the A1M.

Similarly the Local Plan Transport Technical Review prepared by Odyssey Markides fails to factor in this trip generation. It relies on various AECOM evidence reports which all fail to factor in this additional trip generation as they focus entirely on trip generation within Hertfordshire only.

As a result of this failure to factor in trip generation from Luton the mitigation proposals are only sufficient to address trips generated by predicted baseline growth and the development proposals in the Local Plan. The Local Plan Testing Note admits that the proposals will barely address the predicted trip generation and further measures will be required to address further growth in the future. Given the growth predicted in the assessments fail to factor in trip generation from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan the proposed mitigation measures will not be sufficient to accommodate future demand.

The proposals to increase capacity on the A505/A602/B656 route to the A1M comprise:

* Signalisation of the Pirton Road/A505/Upper Tilehouse St/Wratten Road junction (Scheme HM8);

* Signalisation of the Upper Tilehouse St/A602/Paynes Park junction (Scheme HM10); and

* Improvement of the A505/B656 Hitchin Hill roundabout (Scheme HM15).

These schemes are recognised in the testing documents as barely accommodating the growth predicted by the assessments, and would not therefore accommodate the additional traffic growth from Luton travelling to the A1M or additional growth beyond the plan period. They are in effect a sticking plaster solution which accommodates an incorrect level of predicted traffic growth.

The Local Transport Plan and the Local Plan should be proposing a transport strategy that accommodates the correct level of predicted growth and which provides scope for accommodating future predicted growth beyond the plan period. The current proposals fail to do this.

An additional factor should be the suitability of the existing roads to accommodate the level of predicted traffic. All of this traffic would travel through Hitchin via Moormead Hill and Upper Tilehouse Street. These are single lane roads with residential dwellings on either side and run through a catchment area for Samuel Lucas JMI school. These factors conflict with increased capacity in the following ways:

1. The roads and pavements along Upper Tilehouse Street are narrow and result in extremely close proximity of high volume traffic and pedestrians. The traffic includes a high volume of HGV's and the pedestrian flows include a large number of infants and children travelling to and from the school. This is just an accident waiting to happen.

2. Traffic travelling up Moormead Hill regularly travels far too fast and represents a safety hazard for children and parents trying to cross this road.

3. Upper Tilehouse Street is suffering from high levels of air pollution and the Upper Tilehouse Street/Paynes Park junction is to be designated an Air Quality Control Area as a result. The predicted additional traffic, and the additional traffic not taken into account, will exacerbate this problem within a residential area.

The above safety and health factors demonstrate that Moormead Hill and Upper Tilehouse Street are unsuitable as strategic roads and strategic traffic should be diverted along an alternative route.

The policies reliance on compliance with the Local Transport Plan and other supporting documents in order to mitigate adverse impact arising from the development proposed in the plan is flawed as these documents do not factor in all traffic growth sources. The Council's evidence base on transport issues should be updated to factor in growth from from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan.

The mitigation proposals HM8, HM10 and HM15 should be dropped in favour of an enhanced road linkage between the dualled A505 west of Hitchin and the Hitchin Hill roundabout. This scheme matches Scheme 80 assessed within the Hertfordshire Transport Vision High Level Project Appraisal of Long List of Schemes for Hertfordshire Transport Vision produced by AECOM in February 2016. This will resolve the current capacity issues, accommodate additional traffic generated by the local plan proposals, accommodate additional traffic generated by Luton Airport and the proposals within the Luton Local Plan, and reduce safety and health issues on Moormead Hill and Upper Tilehouse Street.

Paragraph 7.6

Objection

I object to paragraph 7.6 as the transport models referenced in the paragraph are flawed in that they fail to factor in trip generation from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan. The models therefore support proposal that will be inadequate to accommodate future traffic growth within Hitchin.

The transport models should be re-run including these additional traffic generation sources.