The Society has submitted its formal comments in response to a consultation by Highways England on options for a new bypass on the A27 at Arundel, full text below:
These are the comments of the South Downs Society, the national park society for the South Downs National Park.
We would stress at the outset that the current consultation is fundamentally flawed – as with recent consultations at other sections of the A27 – by being restricted to the remit of Highways England to the trunk road network. While some effort has been deployed on linking the proposed works to the wider networks of highways, rights of way and pedestrian and cycling desire lines, the overall transport and traffic issues facing Arundel, its surrounds and the rest of the south coast corridor are not addressed and will inevitably be impacted adversely. The proposals are aimed at bypassing an existing congested bypass to the intended advantage of through traffic, not at contributing to improving access to and from Arundel or the national park.
The consultation material acknowledges but does not adequately address the inevitable element of induced traffic. Whatever option is favoured as an outcome of the current work and consultation, there will be an increase in traffic encouraged to use the A27, adding to the existing problems, including poor air quality, at places like Chichester and Worthing/Lancing (where “solutions” are not imminent) and modal shift from rail to road (contrary to government transport policy). The increased threat to the national park from the growth of traffic along the A27, raising expectations of further road building in or adjacent to the park, and the additional contributions to “greenhouse gases” and climate change, are of great concern.
That said, the Society recognises the congestion issues at Crossbush, particularly for westbound traffic and is not opposed in principle to alleviating those problems provided any measures are compatible with the statutory purposes of national park designation and the duty on Highways England under Section 62 of the Environment Act 1995 to have regard to them.
The Society’s appraisal of the route options will be based chiefly on the potential impact, for good or ill, in both short and long term, on the national park. In particular, the special qualities of the park, identified following extensive public consultation and participation, are at the heart of the planning consideration of any development proposals.
In summary these are:
* Diverse, inspirational landscapes and breathtaking views
* Rich variety of wildlife and habitats
* Tranquil and unspoilt places
* An environment shaped by farming
* Great opportunities for recreation and learning
* Well conserved historical features and rich cultural heritage
* Distinctive towns and villages, with community pride
The South Downs National Park Authority has carried out various assessments of the impact of the scheme options on these special qualities of the national park. In general these provide detailed confirmation of Highways England’s own assessment – that the environmental impact of all three options is substantially adverse. The Society fully endorses these findings.
The Society understands that, following our representations, a revised press release was issued by HE correcting its assertion that option 5A “passes between the national park and ancient woodland”. The route does of course take a route through both the national park and ancient woodland, as well as the village of Binsted.
Unfortunately some respondents to the consultation may be unaware of this glaring inaccuracy and their comments on the environmental impacts may be inadvertently softened accordingly.
Nevertheless, local groups and residents have submitted and published a good deal of information on the wildlife, landscape, community and cultural impacts of this option, sufficient to avoid any belief that this option can be anything other than hugely detrimental to the special qualities of the national park, a national designation and planning imperative that would require a major justification – including lack of more acceptable alternatives – if it were to be pursued. This Society fully endorses these detailed findings.
Indeed, Highways England’s consultation material identifies as “major adverse” in its own Environmental Appraisal the impact of option 5A on cultural heritage, landscape, nature conservation, geology and soils, “materials” and road drainage and the water environment. The EA also identifies a “permanent adverse effect on people, communities, farming and recreational businesses located south of Arundel”. The EA identifies as the only “moderate to slight benefit” the prospect of improvement to air quality due to reduction of congestion at Crossbush and other points along the A27, but qualifies this by acknowledging that there will be a worsening of air quality at other locations. The EA fails to acknowledge the additional contribution to greenhouse gases from the overall increase in traffic along the A27 promoted by the various bypass options, including the additional traffic which will be experienced at the notorious areas of congestion on the Chichester bypass and at Worthing/Lancing as a direct result of improving traffic flow at Arundel.
As an organisation whose focus is the conservation and enhancement of the special qualities of the national park and their quiet enjoyment, the South Downs Society strongly objects to option 5A.
Option 3 suffers from a similar Environmental Appraisal to option 5A. The EA identifies as “major adverse” the impact of option 3 on cultural heritage, landscape, nature conservation, geology and soils, materials, road drainage and water environment. It identifies as “slight-moderate adverse” the “effect on people, communities, farming and recreational businesses located south of Arundel”. Identified as the only “moderate to slight benefit” is the prospect of improvement to air quality due to reduction of congestion at Crossbush and other points along the A27, but qualifies this by acknowledging that there will be a worsening of air quality at other locations.
As an organisation whose focus is the conservation and enhancement of the special qualities of the national park and their quiet enjoyment, the South Downs Society strongly objects to option 3.
Option 1 clearly performs much the best in Highways England’s Environmental Appraisal of the route options. The impact on cultural heritage and nature conservation is described as “major adverse” while the impact in the areas of landscape, geology and soils, materials, noise and vibration, people and communities, road drainage and water environment are identified as “slight-moderate adverse”.
Much of the negative environmental impact arising from option 1 stems from the continuation of “improvement” works west from the Ford Road junction and into the national park.
Variations on option 1 have been put forward, in part following the alignment of route 1 but with wide single carriageway rather than double, a modest speed limit of, say, 40 mph and with different junction arrangements at Ford Road, facilitating journeys on foot or bicycle to and from the town centre and the national park. Such measures would appear to be consistent with those recently announced by HE on the A27 between Lewes and Polegate. There was strong public support in advance of the consultation for the inclusion of such variations – generally known as the “new purple route” — amongst the options to be appraised and their omission reduces the value and validity of the current exercise.
Such an option would appear to offer a significant reduction in the current congestion at Crossbush and other points along the road but without the major environmental damage identified for the three options selected. In addition, such an option seems less likely to induce the extra traffic levels that are inevitable from the proposed “expressway” options with all the associated increased congestion at Chichester, Worthing/Lancing and elsewhere, the highly undesirable modal shift from rail to road, and the increase in greenhouse gases and contribution to climate change.
The South Downs Society agrees with Highways England’s Environmental Appraisal, that all of the options put forward would be very damaging environmentally, and especially to the South Downs National Park.
The consultation underplays the implications of the induced traffic arising inevitably from the proposals, the inevitably short term nature of any traffic benefits at Arundel as new traffic is encouraged to use this road, and the additional congestion which will be caused at points east and west on the A27.
The Society believes that, on the basis of the evidence so far provided, a Planning Inspector could not reach a conclusion that the tests in Paragraph 116 of the NPPF had been satisfied with regard to any of the options under consideration.
While the Society objects to all three options because of their acknowledged major adverse environmental impact, options 5A and 3 score considerably worse than option 1.
In addition to performing less poorly in environmental terms, we note from the documentation that option 1 provides easily the best benefit to cost ratio.
The Society would urge fuller consideration of what is referred to in the consultation documents as the wide single carriageway “new purple route”. No adequate reasons are provided for rejecting it.