Local Plan 2011-2031 Proposed Submission Draft

North Hertfordshire Local Plan 2011-2031 proposed submission
Representations and objections

I object to Policy SP6 (Sustainable Transport) and supporting text.

In particular I object to the proposals for mitigating the transport issues that may be caused as a result of the Local Plan being implemented. These proposals are set out in the North Hertfordshire Local Plan Testing Technical Note prepared by Aecom dated 6 July 2016 (a copy of which is attached).

I object to the following specific proposals in the technical note:

* Reference HM8 - Signalisation and road widening of the Pirton Road/A505/Upper Tilehouse Street/Wratten Road junction.
* Reference HM10 - Signalisation and road widening of the Upper Tilehouse Street/A602/Paynes Park junction.
* Reference HM15 - Alterations to the A505/B656 Hitchin Hill roundabout.
I object for the reasons set out below.

Economic growth and sustainability

A major cause of the traffic generation on the roads noted above is travel from Luton into North Hertfordshire to access the A1M.

However, the mitigating proposals are based on forecasted growth in traffic from journeys within Hertfordshire only. They fail to take into account increased traffic into and through Hitchin that will be generated by the expansion of Luton airport, and other development activity within Luton. The evidence base is therefore flawed.

Furthermore the Aecom technical note admits that the proposals will barely address the traffic caused by the forecasted growth in travel within Hertfordshire, and that further measures will be required to address any above-forecast growth (or presumably growth from other sources such as the expansion of the Luton economy).

The proposals are therefore not a long term solution to the growth in traffic into and through Hitchin, and do not represent adequate infrastructure to support development in the area. The proposals do not represent a sustainable solution to a problem that is only going to grow as the economies of Hitchin and neighbouring Luton continue to develop, and so are not value for money for the local taxpayer.

Transportation proposals should instead reflect a more realistic forecast of future growth in travel into and through Hitchin. The mitigation proposals proposed by Aecom should therefore be rejected in favour of an improved road link between the A505 west of Hitchin and the Hitchin Hill roundabout. This is consistent with 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.

Health and safety

The roads noted above are predominantly single lane residential roads that fall within the catchment areas of Samuel Lucas JMI School and the various Hitchin secondary schools. Upper Tilehouse Street is also home to Tilehouse Street Pre-School.

The roads and pavements along parts of Upper Tilehouse Street are already extremely narrow and the Aecom proposals appear to suggest a further narrowing of the pavements. The road is used by a large number of heavy goods vehicles, coaches and buses and this creates existing safety issues when combined with the large amount of pedestrian traffic (including infants, children and buggies) during the school run. Pedestrian traffic is likely to increase in the short term as Samuel Lucas JMI School continues its programme of expansion (which will ultimately result in a doubling in size).

The Aecom proposals will exacerbate pedestrian safety issues as follows:

* Further narrowing of pavements, increasing the risk of collision between pedestrians (infants in particular) and large vehicles.
* Increasing the number of lanes, adding to the difficulty of crossing the road safely.
* Removing roundabouts that act as a natural speed restriction, thereby encouraging an increase in traffic speed that will inevitably increase the risk of accidents occurring. Traffic travelling up Moormead Hill already travels too fast on a regular basis, presenting a safety hazard for children and parents trying to cross the road.
These safety concerns demonstrate that these roads are already unsuitable for use as through roads for strategic and commercial traffic heading to and from the A1M, and that the Aecom proposals will only make these issues worse.

The transportation proposals that form part of the Local Plan should therefore reflect the need for an alternative route for such traffic.

Air quality and the environment

By increasing road capacity, the proposals will worsen levels of air quality within a residential area that is also home to schools and pre-schools.

The proposed Local Plan confirms that the Upper Tilehouse Street/Paynes Park junction is to be designated as an Air Quality Management Area this year, therefore recognising the pre-existing air quality issues in the area. The Aecom proposals will increase traffic capacity and attract further traffic into the area. The proposals are therefore inconsistent with the recognised need to actively manage air quality in the area.

I would hope that any proposed road developments will be subject to a detailed impact assessment that takes into account the health of residents and the users of schools and businesses in close proximity to the relevant roads.

It is clear that the most effective way of managing air quality and protecting public health in the area is to establish an alternative route for through-traffic heading to the A1M. An alternative route should take the form of a bypass along the lines described above and below. This will reduce the impact of through-traffic from high polluting coaches and heavy goods vehicles in particular.

Recent development

The Aecom design proposals are based on an out of date map of the area which fails to recognise that four new houses have been built next to the Highlander pub. The map used by Aecom for proposal reference HM8 appears to show this area as empty land, and so the proposals should be reconsidered in light of this relatively new building development.

Accessibility

Residents of Upper Tilehouse Street already experience significant difficulty in accessing the road from their driveways due to heavy levels of congestion at peak times.

This will be made worse by the proposal to widen the road to three lanes and to make our driveways smaller.

Alternatives

As mentioned above, the mitigation proposals proposed by Aecom should therefore be rejected in favour of an improved road link between the A505 west of Hitchin and the Hitchin Hill roundabout. This is consistent with 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.


See attachment