Local Plan 2011-2031 Proposed Submission Draft

Policy SP6: Sustainable Transport & supporting text

OBJECTION

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

Policy SP60's objective to comply with the misguided Hertfordshire Local Transport Plan is not desirable or properly achievable particularly on the basis that it fails to take into consideration recent and proposed development within Luton Borough and the associated increase in traffic that will flow along the A505 into North Hertfordshire via Hitchin.

NHDC's transport-related evidence base also fails to take this transport growth into consideration.The key evidence documents are:

Document A: The North Hertfordshire Local Plan Testing Technical Note prepared by AECOM dated 6th July 2016.

Document B: The Local Transport Technical Review prepared by Odyssey Markides dated 23rd September 2016.

Document A (above) addressing transport issues related to proposals in the Local Plan 2011-2031 fails to factor in trip generation - from both recent development in Luton (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.

Likewise, Document B (above) fails to take into account the same growing 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 growing 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 the Plan's proposals will barely address the predicted trip generation - meaning that further measures will be required to address further growth in the future. Since expanded trip generation from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan are not taken into account in Document A's assessments, NHDC's proposed mitigation measures will not be sufficient to cope with future demand.

NHDC's proposals include:

i) Signalisation of the Pirton Road/A505/Upper Tilehouse Street/Wratten Road junction (Scheme HM8)

ii) Signalisation of the Upper Tilehouse St/A602/Paynes Park junction (Scheme HM10)

iii) Improvement of the A505/B656 Hitchn Hill roundabout (Scheme HM15)

These schemes are recognised in the testing documents as barely accommodating the growth predicted by the assessments, and thus would not accommodate the additional growth from Luton travelling to the A1M or additional growth beyond the plan period. They are a misguided, inadequate solution to future traffic flow incompletely calculated on flawed, partial predictions.

The Local Transport Plan and the Local Plan should be proposing a transport strategy based on better founded predictions which properly accommodate the future growth of traffic levels within the term of the Local Plan and beyond. The current proposals clearly fail to do this.

These concerns are in addition to the obvious problems that any amount of increased traffic - with increased concomitant dangers to public health and safety - will bring as it travels through Hitchin via Moormead Hill and Upper Tilehouse Street. These are single lane roads with residential dwellings on either side, which run through a catchment area for Samuel Lucas JMI School.

As can be observed on a daily basis, the factors which should be raising alarm signals in relation to increased traffic flow are:

1. The roads and pavements along Upper Tilehouse Street are narrow and result in extremely close proximity of pedestrains to high volume traffic. The traffic continually through the day includes HGVs travelling mere feet away from pedestrians on the pavement - comprising in mornings and afternoons a large number of infants and children travelling to and from Samuel Lucas and other schools within Hitchin.

2. Traffic travelling into Hitchin up Moormead Hill regularly fails to slow down from the high speeds that are common on the westbound A505 - again creating hazards to children and parents trying to cross the 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 increase in traffic flow - not to mention future increased traffic flow that NHDC has failed to take into account, will make this pollution problem even worse 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. It is immediately obvious to anyone on the spot who observes it (as I do, every day) that especially at peak times the above junctions are already a problematic bottleneck - mostly comprising cars and lorries wanting to pass through Hitchin - in such a confined area that, for example, the introduction of traffic lights would not solve the problem of such heavy build-ups of traffic that clearly require a more effective, efficient, alternative route around the centre of Hitchin - such as an enhanced link between the A505 west of Hitchin and Hitchin Hill roundabout.

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 - these documents do not factor in all traffic growth sources. The NHDC's evidence base on transport issues should be improved and updated to factor in growth from the expansion of Luton Airport and the proposed development allocations of the Luton Borough Local Plan.

The mitigation proposals HM8, HM10 and HM15 should be abandoned and replaced for vital safety and environmental reasons by a plan to create 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. Unlike HM8, HM10 and HM15 in the Local Plan, a Scheme 80-style scheme will provide a better solution to current capacity issues, accommodate additional traffic generated by the Local Plan proposals, accommodate additional traffic generated by Luton Airport expansion and the proposals within the Luton Local Plan, and reduce safety and health issues on Moormead Hill and Upper Tilehouse Street.