Letter: We Still Have Very Much to Fear Over the Local Plan Transport Assessment

Published on: 28 Apr, 2019
Updated on: 27 Apr, 2019

From Harry Eve

In response to: Fears Over Transport Assessment Are Unfounded

I thank Cllr Furniss for providing a response to my letter.

Dealing with the three topics in turn:

1. I do urge readers to study the statement of common ground with regard to the transport evidence base. This makes it clear that SINTRAM6 was not sufficiently robust. Why would it be necessary to build a new model otherwise?

Readers may also be interested in a letter from Highways England to GBC dated 18 July 2016 (and which you should be able to find in the evidence base), in relation to SHAR2016, which includes the statement :

“Due to significant deficiencies both with the transport model and the scenario testing underpinning the Local Plan, Highways England considers that the Strategic Highways Assessment evidence base document cannot be used to consider the impacts of the GBC Proposed Submission Local Plan on the SRN. As such the Strategic Highways Assessment document is not considered Justified, Effective or “sound” in line with the NPPF.”

To be fair, Highways England were obliged to write a further letter on 5 October 2016 agreeing that it was not for them to make representations on soundness – that was a matter for the inspector. I do not know what level of expertise the inspector has in transport modelling but he showed no interest in errors found.

In my hearing statement for the first part of the Examination, I set out some detailed inadequacies that I had found after scrutinising data for my area.

2. The point that work on a revised transport assessment stopped when it was clear that the inspector would find the plan sound was in a response from Surrey Highways to a question that I put to them, and to GBC, a few weeks ago. GBC did not respond. Perhaps Cllr Furniss has requested that work should now recommence.

However, this is too late now that the Local Plan has been adopted. Large areas have had their green belt planning restrictions removed without first properly considering the traffic implications and consequent roads infrastructure requirements (that may be unviable or too expensive). Infrastructure adequacy will now be argued by transport consultants acting for developers.

3. Cllr Furniss seems to forget that, although the housing number has reduced, the sites included in the plan have not (I ignore those additional sites that his party included temporarily and then claimed credit for removing – they were not in SHAR2016 anyway).

It is also important to point out that Surrey Highways chose not to appear at the Examination (or the Wisley planning appeal) and they do seem reluctant to criticise transport assessments prepared for large developments. Also, Highways England is only concerned with the Strategic Road Network – our local road network is not their responsibility.

In conclusion, the residents of Guildford (and neighbouring boroughs) do have very much to fear over the Transport Assessment and Infrastructure Development Plan as they stand.