The Society has today submitted comments on an “Implementation Plan 2016/17 – 2020/21” for East Sussex’s Local Transport Plan. As the authority responsible for highways and transport planning across the county — including the East Sussex part of the national park — East Sussex County Council is consulting on how best to deliver the transport capital schemes necessary to support the local economy and promote social and environmental well being.
Our comments appear in full below:
These are the comments of the South Downs Society, the national park society for the South Downs National Park. The Society has nearly 2,000 members and its focus is the conservation and enhancement of the special qualities of the national park and its quiet enjoyment. Our comments will reflect this focus.
The Society welcomes the objectives set out in the plan and especially those relating to climate change, accessibility, social inclusion, road safety and environmental sustainability.
At para 4.7 we note the reference to improvements to the A27 east of Lewes. The Society is aware of, and has engaged with, the ongoing work of Highways England and DfT on this and will respond to any options for change in the light of predicted impacts on the national park in both short and long term. We have been in contact with the consultants working on this with regard to seeing, in user friendly form, the outcome from traffic counts and origin and destination surveys, model development and model validation. In order to inform our own position on any change options we need to have a feel for what increases and what reductions in traffic may be expected on routes crossing or near to the national park.
At para 4.12 we welcome the prospect of a county wide Cycling & Walking Investment Strategy and would be keen to engage with its preparation, especially in respect of access to and within the national park.
We note at para 6 the process for initiating and prioritising schemes but it is not clear at what stage, and how, the various environmental issues are taken into consideration. There is a risk that these may only be considered at a detailed design stage but an environmental “sift” needs to happen earlier, alongside any perceived economic or social implications.
We note under Eastbourne and South Wealden a case being made for improvements to the A27 east of Lewes. There is however no apparent reference to any implications that such changes might have for the use of the existing rail service which runs roughly parallel from Eastbourne to Lewes and beyond. Although the County Council is not the responsible authority for the A27 it must be conscious, in helping to promote changes to the trunk road network, of any wider transport implications and the prospect of encouraging a shift from rail to road use. Also, this section appears to make no reference to the need for safe and attractive access to the national park for different travel modes.
Newhaven: although something of an afterthought (the final para of the narrative and one mention in the list of measures), it is moderately encouraging to see a reference to the national park. The Society would be keen to be consulted on the proposed walking and cycling links to the national park.
Lewes and the National Park: we welcome the recognition that appears to run through this section that Lewes has a special character of its own which needs to be served by any transport investment. We also welcome the references to the links to the national park and the emphasis placed on more sustainable modes of transport.
One area where caution is required is the reference to improving traffic flow within the town: while few would argue in favour of congestion and the associated visual and physical disruption and threat to air quality and health, it would be undesirable to see traffic moving at speed through the town centre and other parts of town, and equally undesirable to encourage more car use in town seeking to benefit from – and eventually nullify – any improved traffic flow. Solutions to these dilemmas have long proved highly complicated. This section should also be cross-referenced to that on proposed changes to the A27 between Eastbourne and Lewes: it seems to us that any measures that make it easier to use a car to access Lewes along the A27 from the east is likely to add to the problems of congestion, parking capacity, air quality, etc rightly identified in this section.
Finally, we note that the delivery of the plan is dependent on the availability of finance and that economic growth is the top priority. In the circumstances the Society is anxious that the measures that it views as positive in terms of sustainable transport and improving access to, and enjoyment of, the national park and the associated advantages to health and quality of life may take a back seat. We would hope that the economic (especially the visitor economy), social and other benefits derived from the park will be fully recognised: the economy is more than offices and production lines.