Sustainability, Planning Guidance, Local Economy and Scheme Justification - Phil Whitehead
1 INTRODUCTION 1.1 Personal Introduction
1.1.1
Sir, my name is Philip Whitehead, I am the senior Transport Campaigner with Torbay and South Devon Friends of the Earth, a position I have held for the past 5 years. In this time I have campaigned on a range of issues and proposals around the Torbay area which potentially relate to a sustainable transport strategy for the area.
1.1.2
I have no particular vested interest in these proposals for the Ring Road, however, I have lived in Paignton since 1970 and therefore consider myself very much a local resident. During the time that I have lived in Paignton I have seen traffic levels build up in Torbay and the problems this has created in terms of congestion and a general deterioration in the quality of the urban environment.
1.1.3
My interest in the proposals for Stage 3 and 4 of the Torbay Ring Road have arisen from my membership of and involvement with a number of organisations including Friends of the Earth, Greenpeace, Alarm UK, Transport 2000, CPRE and the New Economics Foundation. I have come to a firm conclusion that the proposals for Stage 3 either by Devon County Council's Plateau Route or Torbay Borough Council's Valley Route as well as the Stage 4 proposals are unsustainable in environmental, economic and social terms. Therefore, the proposals should be rejected and the council's encouraged to look at alternatives broadly in line with The UK Sustainable Development Strategy and the relevant PPG's that have been revised as a result of 'This Common Inheritance' and the above Strategy.
1.2 Who I represent
1.2.1
The group I am representing is Torbay and South Devon Friends of the Earth. They are an independent voluntary organisation which campaigns for changes of policy at
an international, national and local level to bring about sustainable development.
Based in Torbay for nearly ten years, the group have been successful in changing and informing public opinion on a range of environmental issues and bringing pressure to bear on politicians at all levels. There are presently 581 Friends of the Earth members in the Torbay and South Devon area.
2 SYNOPSIS
2.1 Contents of proof
2.1.1
This proof of evidence consists of:
(i) main objections to the Stages 3 and 4 proposals other than those areas of evidence covered in other Friends of the Earth proofs.
(ii) including reference to government policy and guidance
(iii) and other evidence which has a bearing on the proposals
(iv) and presentation of potential on-line improvements
(v) a critique of Devon County Council's Public Consultation
3 THE PROPOSALS FOR STAGES 3 AND 4 ARE UNSUSTAINABLE
3.1 Non compliance with policy objectives
3.1.1
This scheme does not constitute a sustainable transport option and therefore is not in accordance with either The UK Sustainable Development Strategy or the resulting PPG's and RPG for the South West.
3.1.2
Devon County Council have said "This road is part of a Sustainable Transport Strategy." The following proof will show this to be untrue.
3.2 Global agreements
3.2.1
At the United Nations Conference on Environment and Development in Rio de Janeiro (the Earth Summit) in June 1992, the UK signed the final conference report - a convention on sustainable development normally entitled 'Agenda 21' (the Agenda for the 21st Century). In doing so, the UK has committed itself to achieving a wide range of environmental objectives and targets. This has now been adopted by the Government into the UK Sustainable Development Strategy.
3.3 Bruntland Report
3.3.1
The most widely accepted definition of the term sustainable development is that which originated in the Bruntland Report; (1987)
3.3.2
"Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs."
3.3.3
This statement phrases 'sustainable development' as a wide ranging concept which
encompasses social, political, economic and environmental considerations. There are three concepts which arise from the above definition of sustainable development which require precise definition: development, needs and future generations.
3.3.4 Development
Development is not the same as growth, although the two are often used synonymously. Growth involves the physical expansion of the economic system. Sustainable growth is ultimately contradictory, since there are physical limits imposed by the earth and its natural resources. Development, by contrast, implies improvement and progress and includes social and cultural as well as material dimensions. Sustainable development emphasises conservation and the recognition that natural resources are not simply free goods to be pillaged and pilfered at will.
3.3.5 Needs
Needs are defined in the Bruntland Report as 'meeting the needs of all and extending to all, the opportunity to satisfy their aspirations for a better life'. The environment simply cannot cope with meeting the material standards enjoyed by the rich while? at the same time, supplying the basic necessities to the burgeoning populations of the developing world.
3.3.6 Future Generations
The concept of future generations involves the notion of stewardship. We have a moral duty to look after our planet and to hand it on in good order to future generations. This means improving already degradated areas and avoiding irreversible damage (such as the destruction of species such as the Cirl Bunting) or imposing risks on the future (such as changing climatic conditions or rising sea levels from increasing levels of greenhouse gases).
3.4 The UK Sustainable Development Strategy (Jan 1994)
3.4.1
This document sets the basic framework for the development of specific transport proposals in the UK. Chapter 26 begins with:
3.4.2 'A SUSTAINABLE FRAMEWORK'
"* To strike the right balance between the ability of transport to serve economic
development and the ability to protect the environment and sustain future quality of life
* To provide for the economic and social needs for access with less need for travel.
* To take measures which reduce the environmental impact of transport and influence the rate of traffic growth.
* To ensure that users pay the full social and environmental costs of their transport decisions, so improving the overall efficiency of those decisions for the economy as a whole and bringing environmental benefits."
3.4.3
The report goes on to identify in 26.17 under; 'Elements of a sustainable transport policy'
"It is not the Government's job to tell people where and how to travel. But if people continue to exercise their choices as they are at present and there are no other significant changes, the resulting traffic growth would have unacceptable consequences for both the environment and the economy of certain parts of the country, and could be very difficult to reconcile with overall sustainable development
goals. The Government will need to provide a framework in which people can exercise their transport choice in ways which are compatible with environmental goals."
3.4.4
The above has led to a revision of the Planning Policy Guidance notes to local authorities
3.5 The Planning Policy Guidance notes
3.5.1
These notes issued by the government have been revised to take account of the UK Sustainable Development Strategy setting, the framework for local planning decisions.
3.5.2 PPG1 General Policy and Principles 1992 states:
"the sum total of decisions in the planning field, as elsewhere should not deny future generations the best of today's environment.... The planning system has a positive
role to play in guiding appropriate development to the right place as well as preventing development which is not acceptable."
3.5.3 PPG 13 Transport March 1994
This guidance note forms an important part of the Governments Sustainable Development Strategy in relation to transport. The main reason for publishing this document is to reduce the environmental impact of road travel.
3.5.4
"The key aim of the guidance is to ensure that local authorities carry out their land use policies and transport programmes in ways which help to:
* reduce growth in the length and number of motorised journeys
* encourage alternative means of travel which have less environmental impact: and hence
* reduce reliance on the private motor car."
3.5.5 PPG13 Transport and the environment
"1.1 An effective transport system is vital or the local and national economy. But continuing growth in road transport and consequent environmental impacts present a major challenge to the objective of sustainable development. Traffic growth on the scale projected could threaten our ability to meet objectives for greenhouse gas emissions, for air quality, and for the protection of landscape and habitats.
1.2 There is scope for further improvements in vehicle emissions, but in themselves will not be sufficient. Further means will be necessary to reduce the environmental impact of transport and influence the rate of traffic growth.
1.3 The location and the nature of development affect the amount and method of travel; and the pattern of development is itself influenced by transport infrastructure and transport policies. By planning land use and transport together in ways which enable people to carry out their everyday activities with less need to travel, local planning authorities can reduce reliance on the private car and make a significant contribution to the environmental goals set out in the Government's Sustainable Development Strategy."
3.6 The Royal Commission on Environmental Pollution (RCEP)
3.6.1
In its 18th Report on Transport and the Environment published in October 1994, the RCEP has gone further in its analysis of what needs to be done to achieve sustainable objectives. The report makes many important observations on what constitutes a sustainable transport strategy:
3.6.2 RCEP Preface
"The need for a change in direction, and a new strategy, is starkly highlighted by forecasts of road traffic growth and by the road building programme. Expenditure on the present programme is the largest ever, and many schemes in it are the subject of intense controversy. On the basis of past official forecasts even this programme would not prevent congestion worsening. We do not regard this cycle of continual road building facilitating continual growth of road traffic as environmentally sustainable."
3.6.3 The RCEP recommend eight objectives for a sustainable transport policy: (Chapter 14, page 233)
"A. To ensure that an effective transport policy at all levels of government is integrated with land use policy and gives priority to minimising the need for transport and increases the proportions of trips made by environmentally less damaging modes.
B. To achieve air quality standards that will prevent damage to health and environment.
B1. To achieve full compliance by 2005 with World Health Organisation (WHO) health-based air quality guidelines for transport-related pollutants.
B2. To establish in appropriate areas by 2005 local air quality standards based on the critical levels required to protect sensitive ecosystems.
C. To improve the quality of life, particularly in towns and cities, by reducing the dominance of cars and lorries and providing alternative means of access.
C1. To reduce the proportion of urban journeys undertaken by car from 50% in the London area to 45% by 2000 and 35% by 2020, and from 65% in other urban areas to 60% by 2000 and 50% by 2020.
C2. To increase cycle use to 10% of all urban journeys by 2005, compared to 2.5% now, and seek further increases thereafter on the basis of targets to be set by the government.
C3. To reduce pedestrian deaths from 2.2% per 100,000 population to not more than 1.5% per 100,000 population by 2000, and cyclist death from 4.1% per 100 million kilometres cycled to not more than 2 per 100 million kilometres cycled by the same date.
D. To increase the proportion of personal travel and freight transport by environmentally less damaging modes and to make the best use of existing infrastructure.
D1. To increase the proportion of passenger-kilometres carried by public transport from 12% in 1993 tp 20% by 2005 and 30% by 2020.
D2. To increase the proportion of tonne-kilometres carried by rail from 6.5% in 1993 to 10% by 2000 and 20% by 2010.
D3. To increase the proportion of tonne-kilometres carried by water from 25% in 1993 to 30% by 2000, and at least maintain that share thereafter.
E. To halt any loss of land to transport infrastructure in areas of conservation, cultural, scenic or amenity value unless the use of the land for that purpose has been shown to be the best practicable environmental option.
F. To reduce carbon dioxide emissions from transport.
F1. to reduce emissions of carbon dioxide from surface transport in 2020 to no more than 80% of the 1990 level.
F2. To limit emissions of carbon dioxide from surface transport in 2000 to the 1990 level.
F3. To increase the average fuel efficiency of new cars sold in the UK by 40% between 1990 and 2005 that of new light goods vehicles by 20%, and hat of new heavy duty vehicles by 10%.
G. To reduce substantially the demands which transport infrastructure and the vehicle industry place on non-renewable materials.
G1. To increase the proportion by weight of scrapped vehicles which is recycled, or used for energy generation, from 77% ar present to 85% by 2002 and 95% by 2015.
G2. To increase the proportion of vehicle tyres recycled, or used for energy generation, from less than a third at present to 90% by 2015.
G3. To double the proportion of recycled material used in road construction and reconstruction by 2005, and double it again by 2015.
H. To reduce noise nuisance from transport.
H1. To reduce daytime exposure to road and rail noise to not more than 65 dBL Aeq. 16h at the external walls of housing.
H2. To reduce night-time exposure to road and rail noise to not more than 59dBL Aeq. 8h at the external walls of housing."
3.7 British Government Panel on Sustainable Development
3.7.1
This view that future growth in road traffic as unsustainable was echoed by the British Government Panel on Sustainable Development in its First Report (Jan 1995) which stated "The Panel agrees with the Royal Commissions analysis that the projected growth in road traffic over the next decades is unsustainable."
3.8 The Regional Context
3.8.1 Regional Planning Guidance for the South West RPG10 July 1994
This document primarily provides advice for the updating and review of development plans for the South West states:
3.8.2 '3. The Regional Development Framework'
3.1 A key objective of the planning system, and development plans in particular, to ensure that development is sustainable; ie that it meets the needs of the present without compromising the ability of future generations to meet their own needs. This does not mean that all change should be resisted or prevented. Planning for change in a way that protect and enhance the distinctive environmental qualities of the Region will assist in attracting new investment and jobs, improve the quality of life of existing residents and protect the environment for future generations.
3.2 Sustainability should be the cornerstone of the Region's development plans and planning decisions. Environmental appraisals of all development plans should
ensure that they encompass and promote sustainability objectives as well as showing how environmental and other effects have been appraised in arriving at the plan's policies and proposals."
3.9 Transport: the way ahead South West Debate - Report to the Secretary of State
3.9.1
"Between July and October 1995, the Government Officer for the South West (GOSW), with the support of the University of the West of England, and in partnership with the Regional Planning Conference, the seven counties of the region, the Regional CBI, Transport 2000, CPRE, FoE, the Road Haulage and Freight Transport Associations and a range of other interested parties, held a series of invited seminars to discuss the way forward for transport in the region."
3.9.2
The participants came to the consensus view that;
"In the light of the UK Government's clear commitment to the principle of sustainable development, the participants in the South West seminars are agreed that present transport trends and associated policies based on 'predict and provide' do not make economic, environmental or social sense. Urgent steps are now needed to redress this and to promote measures which meet economic, environmental and social objectives in a complementary way rather than trading competing aspects.
The essential basis for any future strategy is:
* seeking to avoid travel demands; and
* management of transport systems to reduce negative impacts and prioritise use.
Future policy needs to reflect that transport is a demand derived from other activities and not something to be provided in its own right or at cost to other objectives.
A new vision is needed for transport to reflect this. We suggest:
Transport policies and programmes, working with land use and economic development policies, should help to provide levels and forms of access appropriate
to future economic, social and environmental needs.
To achieve this, transport policies and programmes should be measured against the following objectives:
a a more transport-efficient economy, with lower growth in travel by car and heavy goods vehicles than growth in national economic production
b a more environmentally-efficient transport system, reducing the exposure of individuals to noise and poor air quality, and minimising net impacts from transport infrastructure development
c a positive approach to strengthening communities, support local public and private facilities, local skills and training, and local economies and identity
d a safer system for all, especially vulnerable road users, to remove fear and to encourage children to reclaim their independent movement
e a system which is more predictable in its operation through efficient management, to allow economic development to have a firm basis for decision making
f provision and management of all modes based on desirable access levels which provide choice and reflect local needs, opportunities and development strategies
g local distinctiveness based on active public participation and improved awareness
h coherence in delivering objectives, both geographically and functionally
These objectives should be reflected in developing indicators, targets and measures for new transport approaches."
3.10 Towards a Sustainable Transport Policy for Devon (Nov 1992) Devon County Council.
3.10.1
"3.8 It has become clear that the emphasis placed over the past decades on speed and unlimited personal mobility are not sustainable, and that we must find a redirection of policy which places the various objectives more in balance. There is a need to move towards Sustainable mobility."
3.11 The Devon County Structure Plan First Review - Consultation Draft (August 1995) (Devon 2011)
This document has identified as its first aim (Chapter 4 page 13):
3.11.1
"To plan for the future of the County in such a way as to help safeguard the global environment by seeking to ensure that all development is consistent with the principles of sustainability."
Then it goes on to say:
3.11.2
"4.4 A number of issues can be seen to arise from this Aim, some of which relate to specific topic areas and some to the plan as a whole. The strategy and policies of the plan therefore seek to:
* Reduce the need to travel, especially by private vehicles.
* Promote the use of alternatives to car travel such as public transport, walking and cycling
* Promote measures that conserve fossil fuel
* Conserve other resources
* Promote measures to reduce global atmospheric change."
3.11.3 Devon 2011 Chapter 6 Conserving and Enhancing the Environment, Policy EN1 states:
"In considering proposals for new development, priority should be given to the aims of sustainability so as to ensure that the global environment is not adversely affected, that the natural environment is conserved and the local environment enhanced. Where the environmental effects of a proposed development are uncertain but potentially significant, the Local Planning Authority should request the preparation of an environmental impact assessment."
3.11.4 Devon 2011 Chapter 10 Transport (page 97)
A Hierarchy of Modes states:
"10.21 The need to co-ordinate future investment in transport infrastructure within a comprehensive and integrated framework has encouraged the adoption of a
hierarchy of travel modes which builds upon the strengths of each mode and encourages individuals to select the most suitable and environmentally acceptable mode of travel for their journey. The special needs of some sectors of the community may reduce the sustainability of some travel modes for individual journeys. The investment framework will ensure that the desired level of accessibility is achieved for all sectors of the community."
3.11.5 Devon 2011 Policy TR3
"An integrated and balanced transportation system will be developed which promotes the use of the most sustainable and environmentally acceptable modes, uses the following hierarchy:
1.Walking
2.Cycling
3.Public Transport
4.Private Transport"
Clearly there have been major changes in thinking throughout the policy spectrum and although the recent statements by Devon County Council are encouraging and seemingly in line with government guidance, I do not think the proposals for Stages 3 and 4 of the Torbay Ring Road are the type of proposals envisaged within all the guidance, policies and thinking on sustainable development.
3.12 Transport Policies and Programmes (TPP) - Package Bid 1995/96 July 1994
3.12.1 Policy Context
"5.4.7 The continued development of the Transportation Strategy for Torbay illustrates the practical application of the County Council's emerging Sustainable Transport Policy and the objectives and schemes included in the Torbay Package are consistent with the policies contained in this document.
5.4.8 The Local Development Plan is the Torbay Local Plan. The transportation policies contained in the Local Plan are based on the aims of the Torbay Transportation Strategy and as such are consistent with this transport package."
3.13 Package Bid
3.13.1
While Devon County Council claim that the proposals are Part of a 'Sustainable Transport Policy' (Environmental Statement Volume 1 Page 5 Para 2) I do,not believe this to be the case and neither do the government, for in a letter to Devon County Council, dated Dec 19th 95, Matthew Quinn, Director, (Environment and Transport) Government Officer for the South West, with regards to 1996-97 Local Transport Capital Expenditure Settlement (page 3 Paragraph 3,4 and 5) states:
3.13.2
"We are unable to support The Torbay package this year. Our main concern about this package relates to demand management.
First the package contains a substantial weight of major and minor highway schemes, which we consider have not been fully justified in strategic terms. The Government's view is that it is not possible to meet rising demand for road space in urban areas by a programme of road construction and improvement. Before giving support to highway proposals within a package, we need to see the case made that alternative measures (including do-nothing) will not work.
Second, while alternatives to the car are proposed in the package, we are concerned about the apparent lack of complementary restraint measures. As stated in the package guidance, investment in alternatives to the car alone is unlikely to provide a solution to urban transport problems. Bids proposing such investment need to include details of complementary demand management measures, to show that customer take-up and consequential benefits are to be maximised. While studies on restrictions in central Torquay are mentioned in the package, these will need to be developed into proposals before this package can be supported."
3.13.3
As the Package Bid bears such a close resemblance to the Torbay Transportation Strategy and the Torbay Ring Road forms an integral part of that strategy, clearly the government is unconvinced by either the Torbay Transportation Strategy or the Torbay Ring Road proposals.
3.14 Indicators of Sustainable Development for the United Kingdom (March 1996)
This recently published Government document states:
3.14.1
"1.4 If we are to make good decisions about policy relating to sustainable development, we need reliable information about the state of the environment and the factors which impact on it, including information on relative risks and on costs and benefit ameliorating any adverse impacts.
1.5 We need a set of summary statistics which highlight the main issues and help both policy-makers and the public better understand them. The objective is to produce a limited number of indicators, so that the main trends are highlighted.
1.7 The indicators in the preliminary set are based on the objectives set out in the Sustainable Development Strategy. They will be useful in monitoring progress towards the objectives set out in the strategy. They will also help to fulfil the UK's international obligations of reporting to the UN Commission on Sustainable Development."
3.14.2
The report goes on to introduce a range of indicators and unsustainable trends which include:
"b Transport use
Indicator b1: Car use and total passenger travel.
Since 1970, the amount of car travel per head of population has almost doubled, while travel on other passenger road vehicles has dropped by a quarter. Rail travel has remained unchanged.
Indicator b2: Short journeys
While most journeys of less than a mile are made on foot, the proportion of these journeys being made by car is increasing. Around 60 per cent of journeys of 1 to 2 miles is made by car, and about 75 per cent of journeys of 2 to 5 miles. Only 2 per cent of journeys of up to 5 miles are made by bicycle, compared with 4 per cent 20 years age.
Indicator b3: Real changes in the cost of transport
Since 1974, the real price of rail and bus fares has increased slightly faster than the growth in real incomes. The real cost of motoring has fallen in real terms, and is therefore much more affordable than it was 20 years age.
Indicator b4: Freight traffic
The amount of freight traffic has changed relatively little over the last two decades or so, but the distances over which it has been moved have increased by one third. The share of freight carried by road has increased while that carried by rail has declined."
3.14.3
All these indicators point to unsustainable trends in the transport sector and all are relevant to this inquiry, as Stages 3 and 4 of the Torbay Ring Road would exacerbate these trends, encouraging further unsustainable traffic growth.
3.14.4
The government have accepted that these trends cannot continue. This is explicit in PPG13. They have made it clear that major changes are needed to address the present unsustainable trends. In the sixth of his speeches on the future role of transport policy (The Great Transport Debate) Brian Mawhinney has signalled plans for new research on how to facilitate modal shift.
3.15 In Local Transport Today. April 13 1995 Brian Mawhinney stated:
3.15.1
"Providing alternatives to the car is not enough", and he committed the Department of Transport "to do some serious work on how we can make it easier for people to switch from one form of transport to another."
3.16 Major changes needed to tackle traffic growth
It is quite clear that major changes are needed to address the problems caused by unsustainable patterns of traffic growth. Having considered the arguments, guidance and research on the subject of sustainability with regards to transport, I am of the
opinion that the proposals for Stages 3 and 4 of the Torbay Ring Road are unsustainable.
3.17 Other arguments
The rest of the arguments against the proposals laid out in this proof and the others which form the case against the road in principle will add weight to this basic argument that the proposals are unsustainable in economic, social and environmental terms.
4 OUTDATED PROPOSALS
4.1 Stages 3 and 4 out of date in present era
4.1.1
I feel that major changes have occurred in the thinking on how to plan for future transportation needs, especially for urban areas. Planning to meet the demand for new roads to meet rising traffic growth is now simply unacceptable, therefore, the whole justification for Stages 3 and 4 of the Torbay Ring Road must be questioned. This more enlightened thinking on transport is a relatively recent phenomena in terms of the range and consensus of views, and takes account of a great deal of research on the implications of traffic growth and its environmental, social and economic costs. This includes the Royal Commission on Environmental Pollution's 18th report on Transport and the Environment, the Standing Advisory Committee on Trunk Road Assessment's report on Trunk Roads and the Generation of Traffic and a whole range of reports and research by organisations and academics with an interest in sustainable transport.
4.1.2
As the proposals for a Torbay Ring Road have a relatively long history and date back to 1972 when demand management was never considered as an option for future transport needs, it is understandable that the councils involvement were able to consider the option of a Ring Road Strategy at all.
4.1.3
As a recent letter from Devon County Council states.
"The existing transportation strategy stems from the Torbay Transportation Study completed in 1972. The Study's final report advocated a strategy based upon the improvements of the Ring Road for through traffic, and feeder routes into the town centres" (letter from Devon County Council, 19th April 1994)
4.2 Is the justification for a Ring Road established
The councils view that the need to provide a Ring Road is well established.
It was until recently unquestioned:
4.2.1 Torbay Local Plan 5.33, Public Local Inquiry Statement of Case 107/2, Torbay Ring Road (Stage 3), Borough of Torbay Planning Department.)
4.2.2
"The need for a new Ring Road to serve Torbay is not disputed. Both Routes conform with the Structure Plan Alteration and the Transportation Policies and Programme, and the local plan has been granted a certificate of conformity with the Structure Plan."
4.3 Need for new road must be justified
4.3.1
Many of the current government circulars emphasise that particular care must be taken to demonstrate the need for a new road and such a blunt statement as the above does not begin to do so. The national enthusiasm for road building has risen, peaked and tailed off significantly. While this scheme may have been consistent with Prime Minister Thatcher's "Roads for Prosperity" policies during the 1980's, it is now very much out of place in the second half of the 1990's. Whilst the maintenance of acceptable levels of accessibility remains a laudable transport policy, the mechanism of building more and more roads is no longer regarded as appropriate. The case for the scheme is therefore not proven.
4.3.2 (Devon County Council minute EP/94/313/HQ, Highways and Transportation Committee 13th April 1994 3.2)
The proposals have over the years been at least in part justified on the basis of 'predict and provide' with statements such as;
"The existing Kings Ash Road is unsuitable to handle the predicted volume of traffic which would bring attendant noise and pollution to this residential area. An improvement to this situation is clearly warranted."
4.3.3 (Devon County Council minute EP/85/340 Planning and transportation Committee 2nd October 1985).
"The predicted traffic flows for the design year 2005 for this section of the Ring Road stands at 33,000 vehicles per day, and fully justifies the provision of a dual carriageway with limited access'"
4.3.4 Devon County Structure Plan Third Alteration 1989-2001 March 1994) Policy TRN2
"To sustain and develop the road network to accommodate the demand for movement arising from the settlement pattern by giving priority to the development of the major road network for 2001 as shown on the key diagram."
4.4 Predict and Provide
4.4.1
This ethos of predict and provide has been historically based on and encouraged by National Road Traffic Forecasts (NRTF) figures showing massive future growth in road based traffic.
4.4.2
The Torbay Transportation Strategy has accommodated this growth by encouraging some traffic away from the Coast road onto the Ring Road.
4.4.3
The Annual Average Daily Traffic (AADT) on the Coast Road has shown a marginal 1% reduction in the period 1991-1994 while the Ring Road has seen a significant 14% increase. Overall the total volume of traffic crossing Torbay has grown by 6.6% in just 3 years.
4.4.4
This whole approach of attempting to meet demand for traffic growth especially by new road building has become unacceptable to the government. There are many examples of this in speeches by the former and present Secretaries of State for Transport and specific transport guidance:
4.5 Ministerial speeches and statements
4.5.1
Speech by the Rt. Hon. John MacGregor, Secretary of State for Transport, 28th of May 1991:
"But it is not the Government's policy to cater for all forecast demand. There will be cases......where on economic or environmental grounds, or indeed both, it is neither
practicable nor desirable to meet the demands by building the roads."
4.5.2
Speech by the Rt.Hon. Dr. Brian Mawhinney, Secretary of State for Transport to the Conservative Party Conference, 11th October 1994:
"Our main priority now should be to manage our existing road network in the most effective manner.......... So I make clear again that we plan to minimise new trunk road building through open countryside and in cities and to drop road schemes with less advantage to people but with serious environmental disadvantage."
4.5.3
Speech by the Rt. Hon. Sir George Young, Secretary of State for Transport to the Conservative Party Conference, 11th October 1995.
"I believe the key is not to build lots more roads but to make more intelligent use of the ones we have. That makes sense. Economically and environmentally. We simply don't have the money or space for maintaining them, enhancing their capacity and removing bottle-necks and danger spots. Brian's Great debate has shifted the centre of gravity of public opinion. And there is now an appetite for a more balanced policy."
4.5.4
Statement by the Rt. Hon. Sir George Young, Secretary of state for Transport:
The Times reported on 29th of November 1995. "In a statement issued on budget day Sir George Young, the Transport Secretary, said the revised road programme reflected rising construction priced, the tough public expenditure round and the need to protect the environment. Sometimes that means cutting out of the programme schemes that clearly have not attracted the necessary level of public support and acceptance" he said.
4.6 Planning Policy Guidance
4.6.1
The fundamental change in approach is reflected in the recent PPG13 where the need to manage demand is quite explicit:
4.6.2
"1.4 The Government recognises that forecast levels of traffic growth, especially in urban areas, cannot be met in full and that new road building or upgrading of existing highways will in some cases be environmentally unacceptable. It is always Government policy not to build new trunk roads simply to facilitate commuting by car into congested urban centres.
1.5 To maintain the effectiveness of a transport system there are good reasons to place more weight on policies to manage demand, especially in urban areas by:
- promoting acceptable alternatives to the private car
- enabling people to reach everyday destinations with less need to travel; and
- reducing local traffic on trunk roads and other through routes.
1.6 To encourage authorities to develop these policies the Department of Transport has stated that, from 1995-96, authorities bidding for resources for local transport investment in urban areas will be encouraged to do so on the basis of a comprehensive transport strategy covering all forms of transport. These strategies should flow from the authorities planning policies. Guidance on the new arrangements will be given in annual Transport Policies and Programmes circulars of the Department of Transport and accompanying guidance."
4.7 Supplementary Guidance Notes
4.7.1
The above process is followed through in the Supplementary Guidance Notes where great emphasis is placed on the need to manage demand:
4.7.2
TPP Submissions for 1996-97. Supplementary Guidance Notes on the Package Approach major infrastructure and demand management.
4.7.3
"2.18 The Government has already made clear it's view that it is in general not possible to solve the problems of an urban area by a programme of road construction. In particular, there should not be new or improved roads built in urban
areas to facilitate commuting by car (as set out in PPG 13). Major road
improvements in urban areas may be appropriate in limited cases, but authorities should consider traffic restraint and improvements in alternative modes, and proposals should be grounded in a balanced strategy. Any major urban road proposals should include analysis of alternative solutions and an account of why no alternative is preferable.
4.24 As stated above, the Government believes that it will not be possible to solve the transport problems of urban areas by a programme of road building and investment. this does not mean that a road proposal will not be entertained by the Department. It does mean that if such a proposal is included, the submission must make clear how it balances with the other elements of the package. Roads may, for instance, be needed to relieve town centres to allow parking restraint or pedestrianisation. But road proposals should not bring more traffic into congested town centres; public transport proposals should aim to achieve mode shift; traffic restraint will usually be necessary to maximise the benefits from these schemes. Packages should reflect the guidance, in PPG 13, with its emphasis on reducing the need for travel, and on policies to encourage modal shift."
4.8 Failure to consider traffic restraint in TPP for 1996/97
4.8.1
Despite this quite explicit guidance Devon County Council persisted with applying for funding in their Transport Policies and Programme for 1996/97, for the Torbay Ring Road Stages 3 and 4, within their Package Bid for Torbay. This emphasis on major road building was probably the main reason for the rejection of the whole Package. (see 3.13)
4.9 Failure to consider traffic restraint - Devon 2011
4.9.1
Another example where Devon County Council are trying to persist with this road
scheme despite being fully aware of a fundamental shift in government thinking is in the Devon County Structure Plan First Review, Devon 2011 Consultation Draft August 1995.
Where despite a recognition that major changes are needed:
Page 2, 'Reason for Review'
4.9.2
"1.7 No full review has been undertaken since the original Structure Plan was prepared in 1974-79, since when there have been extensive legislative changes and related Government advice. There is a need to take account of and develop the policies of the Regional Strategy and Regional Guidance for the South West. It is necessary to roll forward the Plan horizon to 2011 to provide clearer strategic guidance. In addition the context within which the original and current planning strategy for Devon were developed has changed. A fundamental review rather than an alteration of the strategy is therefore needed to ensure that planning policy is able to guide change in the County into the 21st Century. The base date for this review is 1991."
4.10 New thinking or just green rhetoric by Devon County Council
4.10.1
Despite the identification of specific policies on creating a more sustainable transport strategy, specific policies such as;
4.10.2 Devon 2011 Policy TR3
"An integrated and balanced transportation system will be developed which promotes the use of the most sustainable and environmentally acceptable modes, using the following hierarchy:
1.Walking
2.Cycling
3.Public Transport
4.Private Transport"
4.10.3
Devon County Council have persisted with these particular road proposals which cannot be considered to be sustainable as they will not only accommodate but encourage traffic demand/growth.
4.11 Package bid
4.11.1
Furthermore, both the Package bid for Torbay and the Torbay Transport Strategy
attempt to meet demand for future traffic growth by either providing additional facilities for traffic movements or increasing the through-put on the existing network. There is little that constitutes demand management.
4.11.2
Devon County Council claims that these proposals form a Sustainable Transport Strategy, they are in fact nothing but the old transport policies dressed up as something environmentally acceptable to receive financial support. Clearly this has not worked as the Torbay Package bid was rejected. (see also 3.13.2)
4.12 PPG1 - General Policy and Principle
4.12.1 The guidance note states:
"Where the development plan is material to the proposal, and must therefore be taken into account, Section 54A requires the application or appeal to be determined in accordance with the plan, unless material considerations indicate otherwise."
Clearly the Plans should only be given limited weight because the Local Plan has reached the end of its life and the Structure Plan is undergoing a full review. Both will have to take on board the Governments guidance on sustainable development.
5 STAGES 3 AND 4 WILL NOT HELP THE LOCAL ECONOMY
5.1 Unsupported claims
Despite consistent claims to the contrary the proposals for Stages 3 and 4 of the Torbay Ring Road are unlikely to benefit the local economy in overall terms and because of the unsustainable land use patterns that this road will encourage, the local economy may actually suffer as a result.
5.2 The UK Strategy for Sustainable Development states:
5.2.1
"26.18 A transport policy that is compatible with sustainable development objectives is one which strikes the right balance between serving economic development and protecting the environment and future ability to sustain quality of life. Serving economic development is an important objective of transport policy. But there are alternative ways in which that objective can be achieved. One aim of the Government's framework must be to enable people to enjoy the desired end of access to goods, services and other people (the reason for travel) while substantially reducing the amount of movement needed to achieve that aim."
5.3 Claimed economic benefits
5.3.1
It has consistently been claimed or implied by both councils on many occasions that these road proposals will lead to significant economic benefits for Torbay, examples of this include:
5.3.2 Torbay Borough Council, Report No p/16/96 30th March 1994
"That the County Council should be informed that the Borough Council :-
b) requests the implementation of Stages 3 and 4 of the Ring Road as quickly as possible as part of the integrated transportation strategy for Torbay and to promote the economic regeneration of the Borough."
5.3.3 Devon County Council, Statement of Case. May 1995:
"2 The County Council's Objections and Policies:
to speed up urban renewal through economic revival of inner city target areas."
"3Torbay Transportation Strategy
The early implementation of Stages 3 and 4 of the Ring Road is an important element in the economic regeneration of the Borough as a whole."
5.3.4.Letter from Devon County Council, ref, BCWJ.1/T(3) April 19th 1994
"The County Council's move towards a Sustainable Transport Policy recognises the importance of promoting a High Quality Network of inter-urban and through routes of high standard safe roads to assist the economy of the County". "the early implementation of Stages 3 and 4 of the A380 Ring Road, together with the Kingskerswell Bypass, are essential for the economic regeneration of the Borough as a whole."
5.4 Failure of Council's to provide supporting evidence
5.4.1
Neither of the councils involved have ever tried to support their claim that economic benefits would be derived from this particular road scheme with either empirical evidence or their own research. And at no stage have the elected members on either council subjected these claims to direct scrutiny in sufficient depth within the democratic domain. For example, at a council meeting.
5.4.2
It seems self evident that a major piece of capital expenditure designed to boost the local economy should be rigorously tested to ensure that it achieves its aim. Public capital expenditure comes from the taxpayer, who is entitled to expect value for money, Money spent on one programme is money that can't be spent on other worthwhile programmes, such as health care or education.
5.4.3
When one piece of capital expenditure is going to cost over £20 million, and when the government is striving for efficiency savings across the board the importance of ensuring that the scheme delivers economic benefits is particularly acute.
5.5 Failure of DoT to provide evidence
5.5.1
It would seem reasonable therefore to expect (especially in recent years) that the DoT as one of the main promoters of road schemes would have undertaken research into the economic benefits of such schemes.
5.5.2
A parliamentary question of 14th July 1994, addressed to the Secretary pf State for transport, asked how many studies the DoT had carried out or commissioned in the last ten years on the economic effects of road building. The answer was "None".
5.6 Environment Secretary questions methodology
5.6.1 'Local Transport Today' - Gummer seeks end to link between economy and traffic (1st February 1996.)
"Environment secretary John Gummer has implicitly criticised the Department of Transport's method of traffic growth forecasting, by suggesting there is no reason to assume that traffic growth is inextricably linked to economic growth.
Presenting the annual lecture to the National Environment Research Council Gummer said that economic growth would have to be sustainable in the future. To achieve this, he said traffic growth would have to be reduced: "If there has been a link between economic and traffic growth in the past, there is no reason to assume that this must continue into infinity. At some point the constraints of time, space and congestion will have their dampening effect on traffic growth."
5.7 Lack of evidence
5.7.1
The lack of hard evidence has consistently benefited the promoters of roads and it is the case with the Torbay Ring Road Stages 3 and 4, as there is a 'gut reaction' from local authorities and business organisations who consistently support these schemes.
5.8 Hard economic evidence against Stages 3 and 4
5.8.1
A perceived benefit of road building by local businesses is that it gives industry better access to potential markets. However, goods travel both ways along new roads. A new road to an economically weak area such as Torbay opens up that area to goods of economically stronger areas as well as benefiting the large retail companies operating just in time restocking practices.
5.8.2
Dr Jeremy Vanke, the author of a major study (Vanke,J. 1988 'Roads to Prosperity' The Planner) on the subject found:
"Any transport investment is symmetrical: if we reduce transport costs out of a depressed region we also decrease those into it. So when we link a strong local economy to a weak one we allow the stronger firms of the former to better exploit the weaker economy. It is the stronger end of the link that benefits."
5.8.3 Leitch, 'Advisory Committee on Trunk Road Assessment' (ACTRA) (1977)
"The argument that the road will benefit depressed areas relative to affluent ones is unconvincing. A reduction in transport costs to a depressed and peripheral area may make it easier to supply other areas from the area in question, but at the same time it will make it easier to supply that area from elsewhere. Since most of the problems of depressed areas can be traced to non-transport factors, improved communications may do more harm than good".
5.8.4 John Whitelegg 'Why New Roads are a Bad Investment' Greenpeace (1994)
"There is strong evidence that over the last 20 years the development of the UK motorway system has had the effect of concentrating rather than boosting economic activity. Over time a relatively dispersed pattern of economic activity providing local employment has been replaced by a much more concentrated pattern, with jobs lost for local economies."
5.8.5
Not everyone thinks this is a bad thing: Freight Transport Association (FTA) (quoted by SACTRA December 1994) "The FTA reported that there had been "real cost savings" through improved road links: One food industry company has reduced its distribution depots from ten to four during the past five years. These improvements have been made possible by the improved road systems between its factories and its customers.... The same company has been able to close all its depots in the South West and serve them from a West Midlands Factory, as a result of the M5 Motorway."
5.8.6
There is no causal link between good road links and economic success. New roads can suck economic activity out of a region as easily as they can stimulate it. If there is a trend, it is that new roads take economic activity out of urban areas and relocate it in green field sites. Often labour is shed in the process (Rush for Roads, Jonathan Bray for Alarm UK, December 1992).
5.9 Are local economies really loosing out
5.9.1
There are countless examples of where local councils and business leaders claim that new roads will significantly aid the local economy, claiming that businesses are loosing out through the cost of lost time resulting from poor road access to markets. Yet there is little evidence to suggest this to be the case:
5.9.2 John Whitelegg, 'Roads, jobs and the Environment' (August 1994)
"The rhetoric of government, international organisations and employee representative organisations has done a great deal to consolidate a generally accepted view that roads are good for the economy. There is no evidence whatsoever in support of this contention."
5.9.3 Leitch. ACTRA (1977)
"A further...widely held...assertion is that road transport engenders economic growth... Despite the strength of the assertions, little actual evidence has been presented to us... What evidence there is, suggests that the case is weak, and at best, not proven."
5.9.4 J G Dodgson "Motorway investment, Industrial Transport Costs and Sub-regional Economic Growth: a case study of the M62 (1974):
Studying the economic impact of the new M62 Dodgson could find no clear movement in employment as a result of the project. He analysed the costs of manufacturing companies, qualified the costs represented by the construction of the new motorway. He found the effects of road improvement on the transport costs of local firms were very small and could not be shown to result in any significant savings. He wrote "The impact of this investment on the total cost of manufacturing would reach only 0.33% of such total costs in one area and would be less in others."
5.9.5
Surely if the Torbay Ring Road Strategy were as important a factor for the economic requirements of firms in Torbay or looking to locate in Torbay as the local council's and business leaders have suggested, then presumably the major study of requirements for Torbay's economy by Owen Nankivell ('A prosperous Torbay Economy' 1994) would have referred to the Ring Road as a requirement for economic regeneration. It did not.
5.10 Transport costs are marginal
5.10.1
This is hardly surprising, as previous studies have reached the same conclusions:
* that transport costs are a small percentage of overall costs.
* that the effects of a relatively short section of new road, such as Stages 3 and 4 of the Ring Road, would only account for a very small percentage of overall transport costs
* that transport costs are a relatively unimportant consideration for firms who may potentially locate in one area or another and
* therefore new roads are a poor investment in terms of economic development.
5.10.2 Leitch, 'ACTRA' (1977)
"Studies of the industrial location decision confirm the relative unimportance of transport costs as a determining factor. The most important factors appear to be the availability of labour with appropriate skills and a history of peaceful industrial relations, the price and availability of government grants. Only if all these considerations are satisfied will firms pay much attention to relative transport costs."
5.10.3 C Arnott, 'The Economic Development Impact of Road Building: Myths and Realities' (1987) - Studying the effects of six schemes in Liverpool, Coventry, North Wales, Lancashire and two in London -
Arnott concluded that the construction of new roads was one of the least effective forms of investment in economic development. He said that it was "difficult to demonstrate" that transport investment created jobs. New roads could influence economic development, he suggested only if it were part of a larger package of measures and even then, their effect would be limited to shifting investments from one area to another rather than generating new economic activity.
5.11 Could the road make matters worse
It is quite clear from this evidence (and the lack of evidence to the contrary) that Torbay is unlikely to receive any real overall economic benefits as a result of this Ring Road. Furthermore, it can be argued that the road will actually make matters worse, especially in the retail sector, and consequently the tourism industry.
5.12 Vitality and viability of town centres
5.12.1
Torbay's three town centres have suffered in recent years as a result of two major factors. Firstly, the deep recession which is beyond the scope of this inquiry and secondly, the impact that out-of-town retail stores have had in the vitality and viability of the town centres themselves. There is a need to consider the effect that the Torbay Transportation Strategy may have in undermining them still further.
5.12.2 PPG13 'A Guide to Better Practice' states:
"5.50 As each large store leaves the High Street, part of the attraction of the town centre goes with it, other small units have less customers to draw from and many close. The number of individual greengrocers, butchers and bakers has reduced significantly in the last decade with the trade generally transferring to the larger food multiples; the four largest accounting for 50 per cent of food sales. The emphasis in town centres is on comparison shopping, but this too can be vulnerable if non food retailers also seek out-of-town centre, car-borne locations."
5.12.3
The effect of Stages 3 and 4 on this process would be one of 'joining the dots' so to speak, between the existing out-of-town stores at the Willows, which includes Sainsbury's, Marks and Spencer etc, and the Plymco at Roselands. This would also include the soon to be opened Safeway, which is within a few hundred metres of Tweenaway and which best illustrates the above process by proposing to simultaneously open the out-of-town store while closing the town centre store in Paignton, Victoria Square.
5.12.4
Stages 3 and 4 of the Ring Road would, although marginally, allow the superstores to tighten their grip on the market still further by reducing their travel costs, and by encouraging consumers to travel more freely between these out-of-town stores, further setting in place car-borne shopping patterns.
5.12.5
It is difficult to see how the Torbay Transportation Strategy, which supposedly proposes encouraging traffic away from the Coast Road to Ring Road can possibly work without undermining the vitality and viability of Torbay's three town centres. All three town centres simply do not provide the quality and range of shops to compete. Especially as part of the stated strategy is to implement traffic restraint measures to reduce car-borne traffic. Consumers will simply use the free parking provided at the out-of-town locations at an increased rate.
5.12.6
In recent years there has been an increase in the number of retail units which are either empty or are used as charity shops. This general reduction in the quality of shopping experience must have a knock on effect for the tourism industry. Although this effect is unquantifiable there has been an excepted decline in the tourism sector in Torbay.
5.13 PPG6 - Consultation Draft July 1996
5.13.1
This process seems to run contrary to the stated objectives and approach of the new Revised PPG6: Consultation Draft July 1995 which states:
5.13.2 "Objectives and Approach
1.1 The Government's objectives are:
- to sustain and enhance the vitality and viability of town centres, and to focus retail development in locations where the proximity of competing businesses facilities competition from which all consumers should be able to benefit;
- to ensure the availability of a wide range of shops, services and facilities to which people have easy access;
- to maintain an efficient and innovative retail sector; and
- to maximise the opportunity for shoppers and other town centre users to use means of transport other than the car.
1.2 These objectives seek to encourage sustainable development, and, in particular, reduce the need to travel and reliance on the private car. This is consistent with the Government's Sustainable Development Strategy and with PPG13: Transport.
1.3 Town centres should, wherever possible, be the preferred locations for developments that attract many trips, and local planning authorities should adopt planning policies to
* locate major generators of travel in existing centres where access by a choice of means of transport, not only by car, is, or can be, made easy and convenient;
* strengthen existing local centres, in both urban and rural areas, which offer a range of everyday community, shopping and employment opportunities;
* maintain and improve choice for people to walk, cycle or catch public transport;
* ensure an appropriate supply of attractive, convenient and safe parking for shopping and leisure trips. The private sector is often best placed to manage it, but local authorities have a prime responsibility to ensure the availability of land for this purpose; and
* limit the supply of commuter parking to a level necessary for the functioning of the town centre, to discourage car commuting where alternatives are available."
6 FAILURE TO PROPERLY CONSIDER ON-LINE IMPROVEMENTS
6.1 Lip service to on-line improvements
6.1.1
Both Devon County Council and Torbay Borough Council have only paid lip service to any consideration of on-line improvements to deal with the specific problems on the existing road. This has largely been a result of the council's holding a well established view that a new Ring Road is needed to meet future demand based on the long standing philosophy of 'predict and provide' This is highlighted in minute EP/94/313/HQ 13th April 1994 'Improving the Existing Road' which states:
6.1.2
"3.3 At the exhibition two options were shown illustrating the consequences of improving the existing Kings Ash Road. These dual carriageway (40 mph speed limit) and a single carriageway (40 mph speed limit).
3.4 Both of these alternatives would involve the demolition of 67 homes and extensive land acquisition. The residents of Kings Ash Road will be subjected to noise and air pollution which would gradually increase as the volume of traffic grows. A single carriageway option, given the flow of more than 30,000 vehicles per day, would not give a solution to the congestion problem. Whilst some properties would benefit from being accessed from severed sections of the existing road, 38 would remain with access opening directly onto the 'improved road' and with increasing volumes of traffic this would become more difficult and dangerous.
3.5 It is not considered that either of these alternatives offer a suitable solution to the problem and that a solution which bypasses the Kings Ash community is fully justified."
6.2 Kings Ash Hill
6.2.1
The existing Ring Road has a particular problem on Kings Ash Hill, where the road rises at a gradient of 1:8 between the junctions with Luscombe Road and Whitebeam
close. Devon County Council considered two possible solutions, one a dual carriageway, the other a single carriageway along the line of the existing route. It was concluded that both alternatives would require the demolition of 67 houses and that extensive land would need to be acquired. This is excessive in the extreme and more to do with pushing the costs 'through the roof' rather than a genuine desire to consider realistic proposals which deal with a problem and do not attempt to meet projected traffic demand.
6.2.2
Problems occur on the Kings Ash Hill when Heavy Goods Vehicles break down when travelling up the hill. The simple solution to this problem would be to introduce a crawler lane on the left hand side of the carriageway. This would involve the demolition of 14 properties and the acquisition of land from 19 others. I feel that Devon County Council should fully investigate these proposals as they deal with specific problems rather than attempt to meet demand.
6.3 Torbay Transportation Strategy
6.3.1
I feel that the entire Torbay Transport Strategy needs to be reviewed, so that Torbay has a transport strategy that is in tune with government guidance and is based on sustainability criteria.
6.3.2
This strategy would need to have the support of as broad a consensus as possible amongst the local population, be based on sustainable objectives, not growth objectives, as in the present strategy, have accessibility and not mobility as a fundamental principle and consider a wide range of quality of life indicators.
6.3.3
It would be one thing for this inquiry to find in favour of the road proposals, it will be another thing getting them funded in the present climate, where the government has set very tight criteria for the type of schemes it will support financially. As the sustainability considerations are becoming increasingly prominent in transport decisions it is unlikely that a scheme which attempts to meet demand for traffic growth will ever be funded.
6.3.4
This in turn will create a situation where either Devon County Council or Torbay Borough Council, if they eventually gain Unitary Authority Status would continue to bid for Package funding with proposals that fail to meet the governments criteria. This would mean that Torbay will continually miss out on much needed financial support, which is likely to be the situation if the scheme is not rejected at this inquiry. This would be a wholly unacceptable situation.
7 THE PUBLIC OPINION SURVEY UNDERTAKEN BY DEVON COUNTY COUNCIL DID NOT DEMONSTRATE PUBLIC SUPPORT FOR THE PROPOSALS
7.1 Loaded consultation
7.1.1
The public opinion survey undertaken by Devon County Council was loaded in favour of building a road by only offering the choice of two routes and not a no-road option.
7.1.2
The 12 per cent response rate may suggest that only 12 per cent of people surveyed supported building a road, and even here reading the comments on the returned forms, there were many respondents who took what they saw to be the least worst proposal, as they were very concerned about the damage a road would inflict on the Westerland Valley.
7.2 Friends of the Earth postcards
7.2.1
Friends of the Earth have produced a pro-forma postcard which provides local residents with a no-road option. Over 4000 of these postcards have been individually sent to the Secretary of State for the Environment, John Gummer. These postcards have subsequently been sent to the Government Office for the South West in Plymouth.
7.2.2 The postcards state:
"I wish to formally object to the proposed Torbay Ring Road Stage 3 on the following grounds:
* That this road would destroy the beautiful Westerland Valley and the rich habitat that it provides.
* That this road would induce a significant amount of additional traffic and this in turn would exacerbate the problems of traffic congestion on Torbay's road network.
* That £20,000,000 could be better spent on the provision of public transport, cycle lanes and improved pedestrian facilities.
* That the effects of pollution and noise on the residents of Tweenaway and Great Parks far outweigh any proposed benefits.
I request that you reject proposals for a new road, in favour of sustainable, non-road building alternatives."
7.2.3
This is not something people can support without having formed a view.
7.3 Other relevant opinion polls
7.3.1
The respective response rates are supported by a recent opinion polls by Gallup which found that 62 per cent of respondents actually supported protesters who broke that law in disrupting motorway building. And a recent NOP poll which showed that almost two-thirds of motorists would like to see the use of cars "actively discouraged." (Local Transport Today 22nd June 1995)
8 CONCLUSION
8.1 The many reasons to reject the proposals
8.1.1
The Government is committed to sustainable development. This is stated on many occasions throughout the policy spectrum on transport planning.
8.1.2
If all the fine words are to be believed on sustainability proposals that cater for traffic demand, result in habitat and species loss, raise emissions of greenhouse gases, create a worsening of air quality and generally degrade the quality of life, proposals such as Stages 3 and 4 of the Torbay Ring Road would be axed for more sustainable transport options.
8.1.3
Both council's have failed to identify worthwhile alternatives to a Ring Road to meet Torbay's future transport needs. A do something sensible approach is needed.
8.1.4
The proposals are outdated and do not take account of a considerable number of recent reports, agreements and guidance on the need for demand management.
8.1.5
There has always been an almost complete lack of evidence to support the proposals for Stages 3 and 4 on economic grounds, in terms of the local economy.
8.1.6
Both council's have failed to really consider on-line improvements to deal with specific problems on the existing road.
8.1.7
Devon County Council‘s consultation exercise showed a poor response rate. This would indicate a real lack of interest in building the road.
8.2 Make our council's consider sustainable alternatives
8.2.1
I therefore urge that you reject these unsustainable road proposals and force the local authorities to begin a process to reconsider the Torbay Transportation Strategy.
