Draft Core Strategy (incorporating Preferred Options) October 2010

Document Section Draft Core Strategy (incorporating Preferred Options) Transport and Accessibility Transport and Accessibility [View all comments on this section]
Comment ID 1060
Respondent Somerset County Council Enviro… [View all comments by this respondent]
Response Date 03 Dec 2010
Response Type OBSERVATION
What is the nature of this representation?
  • Observation
Comment
There is a real danger that the important messages contained within the transport chapter could get lost as the document is neither clear nor concise. It appears to repeat itself at various stages and there are confusing disjoints between the supporting text and the policies. Would a developer be able to pick up the document and find the information they require with ease?

The document is very development focussed, with little or no mention of proposals for transport other than those which are connected to or will arise as a result of developments. Bigger picture ideas, such as overarching aims for transport would help to provide a vision and context for the chapter. There appears to be more of a focus on process than outcomes, and the bulk of the document may be better situated within a best practice guide.

The strategy tends to be reactive (following a development control model) rather than proactive (following a development management model). It tends to addresses delivery of travel measures only in the context of new (residential/employment) development. It includes little regarding proactive measures and investments by SSDC and partners such as SCC or public transport operators to address the existing population and workforce's needs and problems?

Paragraph 10.3: It is important to acknowledge (and address) the considerable benefits often conferred by car travel. If modal shift is to be achieved, it is important to be realistic about this.

Paragraph 10.5: Re' new technologies it is important to note the potential to simply relocate the sources of pollution, unless the generation mix is radically changed.

Regarding the statement 'if the alternative of major highway Infrastructure investment is to be avoided'. Whilst it is unlikely that future developments will be able to avoid the need for any new highway infrastructure completely, large scale road building is unlikely to be the alternative to the successful implementation of sustainable travel measures. Unless there is a significant shift in transport and fiscal policy (locally and nationally) large scale infrastructure investment will not be possible. Therefore, a more realistic 'alternative' to success in this respect would be continued growth in congestion, environmental degradation, health costs and attendant economic effects. Thus, whilst some road infrastructure is likely to be necessary it will be vital to ensure sustainable travel measures work, as in many ways there are no alternatives.

Furthermore, questions exist over whether it is realistic to rely solely on public investment without including contingencies and alternative funding opportunities.

Amend as follows: "Consequently substantial investment inmeasures to promote sustainable travel and necessary highway infrastructure will be needed. (if the alternative of major highway infrastructure investment is to be avoided and the specifics of this will emerge in the County Council's Future Transport Plan (FTP) and Yeovil Transport Strategy Review 2 (YTSR 2)) Strategic infrastructure requirements will be identified through technical assessments being undertaken by the County Council in time to inform the Publication document for submission to an Inspector."

Paragraph 10.6: It is important to consider whether it is challenging enough to have "a reasonable aim for the modal shift policy in Chard and Yeovil". It is not clear that maintaining car use at current levels in market towns and villages is a reasonable aim when the previous sentence refers to increasing use of more sustainable modes by various measures. The strategy also needs to be clear about what "current levels" means, in particular whether it refers to absolute numbers or proportions.

Also note the target modal share for eco-town developments needs updating. Reference to "model should read" "modal".

General: An overview of the content of chapter 10 would reduce the (incorrect) impression that issues are being omitted as one reads through the chapter (e.g. cycle parking not being covered in the chapter's earlier sections). Furthermore better signposting is needed between related policies located in separate sections.

As noted, rail services (and the Heart of Wessex line in particular) have grown significantly. I am not aware of any evidence that this growth is disproportionately composed of longer distance trips. Given the stopping services that serve the Heart of Wessex line this seems unlikely. Therefore, the evidence does not seem to support the assertion that "modal shift to rail for short journeys will be difficult to achieve". As such, I would suggest that growth in local traffic is achievable and should be pursued where possible by the strategy. This suggests the absence of any significant further mention of rail travel would also need addressing.

Attachments