Sussex Wildlife Trust's response to the East Sussex Local Transport Plan 2006 – 2011, Consultation Draft.
To: Jon Wheeler, Transport and Environment, County Hall, St Anne’s Crescent, Lewes BN7 1UE

25th May 2005

Dear Sir

East Sussex Local Transport Plan 2006 – 2011, Consultation Draft.

Thank you for your letter of 14th March encouraging the Sussex Wildlife Trust (SWT) to comment on the Local Transport Plan. I would now like to make the following comments, mostly regarding the generality of the plan.

Throughout the document much is made of the link between a poorly performing economy and a perceived inadequate transport infrastructure. This link could be an exaggeration and runs the risk of unduly skewing the direction of strategy. Even statistics within the report are less clear than is implied. For example the Sussex Enterprise survey found that 18% of respondents claimed that poor transport was a constraint on their competitiveness. In other words, however, 82% do not. Also the same survey showed that over half of respondents felt that building more roads just adds to congestion and hence is damaging to competitiveness.

There are many statements in the plan that may have the effect of reinforcing a roads = prosperity view, but there are also more hidden statements that give a better indication of the complexity of the situation. For example on p 39 the phrase “it is far from clear that road investment in isolation leads directly to desirable inward investment” appears. The plan should make it clearer that the situation is complex, that solutions will be diverse and that simply building our way out of the problem is bound to fail.

There is a conflict in the Plan (common to most transport and economic strategies) that is perhaps best highlighted on p 58. This section states that there may be a general pressure for fewer, larger premises with higher transport footprint. However a sustainable transport strategy must be based on a larger number of smaller and more local enterprises in order to reduce transport footprint. There may be a limited ability for a Local Authority to impact on this, but a large-scale approach promoting strategic transport networks, rather than small local solutions will exacerbate the problem. Large scale, strategic transport routes tend to benefit larger businesses and distant markets / suppliers, at the expense of smaller firms and more local markets / suppliers. East Sussex, as a county of small to medium sized enterprises, may be being protected by a relatively poor transport system!

Building a high capacity transport system in order to encourage business expansion at the cost of ever-increasing transport demand drives an unsustainable trend. This will increase resource use, drive more environmental damage, and will produce more pollution and greenhouse gases, all to maintain an economy that is highly vulnerable to transport insecurity.

The LTP does offer several programmes that should help provide local and small-scale solutions, however, the plan is occasionally undermined by the general strategic background which leads the reader to conclude (incorrectly) that much larger scale answers are needed.

The point of a transport plan is access, not transport. What is needed is access to jobs, markets, services and materials, but transport is the least efficient way of addressing access. Furthermore the greater the distances involved the less the efficiency of delivering access. The aim should be to deliver access in ways that reduce transport demand.

There are also conflicts in parts of the Strategy Appraisal section. The “expected contribution” section (p 40) is optimistic. The claim that the Economic Strategy will contribute to the protection and enhancement of the environment seems a little unlikely, indeed the Environment Strategy on the same page states that economic regeneration will increase transport and development related environmental impacts.

The Environment Strategy in general is probably a more balanced background but should be integrated more with the Economic Strategy. The fundamental point here is that government policy and the global need is for a reduction in CO2 emissions and this requires an overall reduction in car use.

This background actually supports a lot of what is in the plan, although the over-emphasis of poor transport = poor economy could be building a false expectation first that strategic road improvements can be delivered and second that they may provide an answer.

The Demand Management Strategy is generally supported. The reduction of transport demand and promotion of modal shifts are good principles driving strategy. Also the promotion of strong locational policies through development control could be effective in promoting localisation. We also support the focus on minimising car dependency through locational policies in the Transport and Development Strategy.

Nevertheless, the Demand Management Strategy is heavily based on parking restrictions. Whilst this is supported, perhaps there should be more tools in the box for demand management in East Sussex. Maybe this is the time to consider congestion charging?

SWT strongly opposes the push for increasing air passengers at Gatwick, Shoreham and Lydd, in the Strategic Accessibility Strategy (p46). It is impossible to claim environmental protection on one hand while pushing air travel on the other. Air travel is the fastest growing producer of CO2 emissions. Again the economy should be based on increasing localisation not promoting long distance travel.

SWT strongly supports the Walking, Cycling, Rail and Bus Strategies. If anything, more should be done to support walking and cycling as perhaps they represent the largest potential contribution to reducing car dependency.

Regarding major road schemes, SWT supports that the view the main emphasis of strategy must be to reduce reliance on cars (p100). We agree with the presumption against road improvements except as part of an integrated approach to transport and agree that there should not be a significant local road building programme.

As a point of detail, many bridge repairs are listed on p98. This should be used as an opportunity to enhance waterways to allow for otter re-colonisation. Otters are starting to move back into Sussex and their population could be encouraged to grow. This could, however, be held back because of road deaths as otters may leave a river to cross a road because of poor access under roads. A relatively small amount of mitigation could overcome this problem and help conserve the species in Sussex. More information on this can be obtained from the SWT, but it would be helpful if the option of bridge improvements for protected species could be raised in the Plan.

In general, therefore, I find the plan rather biased in its background, over-emphasising and over-simplifying the link between economy and transport, and there are some questionable assumptions about the contribution of transport improvements to the environment. Statements regarding possible environmental damage should be stronger and there should be an expectation that if current policies do not reduce congestion, pollution and CO2 emissions, then stronger policies may be needed in the future. Nevertheless, the basic principles of trying to reduce transport footprint, reduce car use and encourage modal shift are supported.

I hope these comments are helpful and wish you luck with developing what is bound to be a very difficult strategy.

Yours faithfully

Dr A Whitbread