Letter to Department For Transport
Dear Mr Berry
I understand that Norfolk County Council are bidding for Local Pinch Point Funds in order to replace a section of National Cycle Network route 1 with a so-called "Lynnsport New Access".
I am writing to urge you to decline funding because the bid contains many errors and omissions, because it would work against local and national strategy and because there has been so little consultation that the residents heard it first from the press.
1. The PDF of this bid published on the Norfolk County Council website (found by searching) is missing all appendices, including key details which are not commercially sensitive but vital for review of some of the claims. Essentially, the absence of appendices makes many of the points unproven for Norfolk residents and some are contrary to what appears to be evident on the ground. The weblink on the bid is simply for the council website, not the publication location.
2. The stated headline description of a direct new link from the main road network to Lynnsport could be achieved more cheaply, with less damage to public health and happiness, by opening the existing disused bus road between Bryggen Road and Reid Way to cars.
3. It seems unlikely that building such a long new road will reduce traffic volumes which would be added to the town centre AQMA, but I have not seen the modelling in the missing appendix. I wonder whether the modelling methodology is current best practice and whether the assumptions are valid.
4. The bus link that would be created by this bid previously existed, as mentioned in the point 2, but is disused. It seems unlikely that a new road would be sufficient to overcome the past service problems in these estates, such as lack of parking enforcement and vulnerability to delays on the neighbouring road network. If anything, increased traffic levels on the neighbouring road network arising from the new developments seem like they may increase the obstacles.
5. Access to the new housing developments could be provided with one shorter link from Reid Way and the drawn links from Front Way, which is an existing road, although it is shown with the same colouring as new construction on the plan. There are also partially-constructed link roads from Marsh Lane (north and south) to the Marsh Lane development and Aconite Road to the later phase, although these might not be sufficient without new links from the west.
6. The headline description claims that the signalled crossing for National Cycle Network Route 1 (NCN 1) at Edward Benefer Way will be safer, but the current crossing is already safe, with no fatal, serious or slight accidents 1998-2008, according to figure 7.2 of the King's Lynn Area Transport Strategy. It seems incredible to claim to improve on no recorded accidents, especially given that the scheme would displace some existing traffic to Edward Benefer Way, as well as add traffic from the new developments.
7. The headline description claims that the scheme will be "giving health benefits by encouraging cycling" but the scheme will cut a continuous part of NCN 1 into three or four parts linked by road crossings and move it from a stable railway bed to an unstable fen drainside, which is unlikely to encourage cycling.
8. The description of the geographical area claims that the Lynnsport site is served only by Greenpark Avenue. There are also vehicular accesses from Beulah Street and Front Way, as well as accesses from Salters Road, River Lane, Riverside, Discovery Park and NCN 1 which are usually closed to motor vehicles, and an access from Loke Road which may be closed to everyone. Not all of these would be suitable for extra traffic in their current state, but these accesses do exist. The section of Loke Road used to reach the Lynnsport site is not traffic-calmed.
9. The description of the geographical area describes Edward Benefer Way as a radial route when it is in fact a route along the northern perimiter of King's Lynn, called the northern bypass by some.
10. The Strategic Case mentions the King's Lynn Area Transport Strategy, but that strategy included a straight-line cycle route where this bid proposes to put a road, even though no cycling charities or user groups are recognised in KLATS as stakeholders.
11. The Strategic Case considers only cars and buses, which is contrary to policy CS11 of the Borough's Core Strategy that states walking and cycling are preferred to buses and cars. Furthermore, policy CS11 also says the development will need a "travel plan to show how car based travel can be minimised" which seems unlikely when a new road is being provided specially for it.
12. The proposed reallocation of the current NCN1 to cars and buses is also contrary to the Borough's Core Strategy policy CS03 King's Lynn which says "alternative links within the town for walking and cycling will be maintained". The proposed diversion will be a drainside path similar to that found between Front Way and John Kennedy Road, which is far inferior to railway paths like NCN1. Therefore, this link would be downgraded, not maintained.
13. The proposed opening of the current NCN1 to cars and buses is contrary to the County's Local Transport Plan policy 9 Travel Choice which says "Improving and promoting active travel options (walking and cycling in particular) for short journeys to schools, services and places of employment in market towns and urban areas should be the priority." As drawn, NCN1 is moved out of the way and crossed, rather than given priority.
14. The proposed reallocation of part of NCN1 to cars and buses is also contrary to the County's Local Transport Plan policy 14 Sustainable Tourism and Leisure.
15. Part b of the Strategic Case only considers some fairly bizarre alternative options, including direct access from Lynn Road - which might involve demolition of a filling station or other buildings to gain access. It fails to consider obvious options, including expanding access from any of the other existing accesses to the Lynnsport site mentioned in point 8, or by opening the disused bus link mentioned in point 2.
16. Part c of the Strategic Case repeats the absurd claim from the headline that the NCN 1 downgrade is an improvement that will deliver health benefits. However, this proposal does not follow Recommendation 1 of the NICE Public Health Guidance PH8 on Physical activity and the environment, so that seems highly unlikely. It also does the almost exact opposite of Recommendation 2 of PH8, which suggests re-allocating roads to walking and cycling, closing or narrowing roads to reduce capacity and traffic-calming schemes to restrict vehicle speeds.
17. The Economic Case - Value for Money does not point out that the roads with an increased traffic loading are one with the international cycle route running along them (Edward Benefer Way, Low Road), and one with little cycle provision and reported cycle accidents (Wootton Road). This worsening of the environment on the international cycle route seems contrary to the desire to promote sustainable tourism including walking and cycling tourism.
18. The Economic Case - Value for Money does not point out that the council's responsibilities for public health and NICE guidance PH8 suggests it would be more cost-effective to prioritise walking and cycling.
19. The Management Case - Delivery claims that CIF2 included improvements to enhance cycle and pedestrian access, but no enhancement was actually delivered. CIF2 was a net harm for pedestrian and cycling. The Southgates junction remains a mess of hazardous crossings, while the new bus lane from Wisbech Road has created new pinch points that bring buses into conflict with people walking and cycling along that former path, which has already had two sets of remedial works. This is a clear demonstration that Norfolk County Council apparently harms pedestrian and cycle access without noticing it has done so, which must bring the effectiveness of its monitoring and consultation into question.
20. The Management Case - Statutory Powers and Consents claims that the proposed road features in the adopted Great Yarmouth Borough-Wide Local Plan (2001). Great Yarmouth is about 100 miles to the east of King's Lynn. Its local plan is not relevant.
21. The proposed conversion of NCN 1 to a road did not feature in the 1998 King's Lynn and West Norfolk Local Plan, nor the 2011 King's Lynn and West Norfolk Borough Council Local Development Framework Core Strategy. The Marsh Lane development is marked on the Core Strategy King's Lynn Town inset map 31, where it is shown as linked to NCN 1 by a shared walking/cycling route and linked to Marsh Lane for vehicle access. There is no new road shown.
22. The Management Case - Stakeholder Management does not list the local CTC or Bicycle User Group as stakeholders.
23. Part b incorrectly states that the scheme cannot be considered as controversial in any way. It is obviously controversial to open a second section of NCN 1 in the town for motor vehicles, as well as the environmental impact of removing mature hedgerows and putting a new road just feet from the end of back gardens. It will probably be opposed by a wide range of route user groups, local residents and businesses that use or border the route.
24. There is an external campaign opposing the scheme.
25. No mention is made of the significance of the Sandringham Cycle Path being not only part of NCN1, but also part of the international North Sea Cycle Route and Euro-Velo route 12. Opening this section to cars could become an international controversy.
26. The Benefits Realisation is incorrect, as there is already a safe crossing for the National Cycle Network Route 1 on Edward Benefer Way. There are no better cycling facilities proposed in this scheme - this scheme would be a net harm to cycling.
27. Monitoring and Evaluation mentions cycle usage counters but does not show the current levels, nor set any metrics for them. Norfolk County Council monitoring has seemed ineffective to date, as described in point 19 above about the CIF2 works, but there are many other examples.
For these reasons, I urge you to spend the money where it can do more good. Maybe you could suggest that Norfolk County Council reconsiders its approach to highway development.
Thank you for your attention and I await your reply with interest.
MJ Ray, Setchey, Norfolk, England