Response to Department for Transport Consultation: The Strategic Road Network and the Delivery of Sustainable Development
The Alliance of British Drivers (ABD) was formed in 2012 by the merger of the Association of British Drivers (founded 1992) and the Drivers’ Alliance. It campaigns for a better deal for Britain’s motorists. It is a voluntary organisation funded by subscriptions and donations from members and supporters. It currently has around 4,500 members and a further 3,000 supporters on social media sites. The ABD receives no funds from public bodies or private-sector businesses, so is truly independent. It is a member of the Parliamentary Advisory Council for Transport Safety and the National Council of Voluntary Organisations.
The ABD`s national committee has agreed the response to this consultation. The response is in line with the policies outlined on the ABD`s website. Individuals who join or support the ABD are assumed to support its policies in general, so it is not necessary (nor would it be practicable) to seek the views of the entire membership in preparing responses to consultations of this type.
The ABD`s responses to the questions asked in the consultation document are set out below.
Q.1 Does the proposed Circular explain clearly the Highways Agency`s commitment to engage at all stages with the planning system, and how this will happen?
This question is probably best answered by the Highways Agency itself, though the role it is expected to play seems clear to the ABD.
Q.2 Does the proposed Circular achieve the correct balance between supporting economic development and ensuring that the strategic road network fulfils its function of providing safe and efficient movement for current and future users?
The ABD is concerned that the balance is weighted too far towards economic development, to the possible detriment of existing users of the strategic road network. While appropriate economic development is to be encouraged, it should not be at the expense of reducing the level of service to road users in terms of journey times, journey time reliability, or safety. The Government, through the Highways Agency, should be seeking to increase this level of service by improving the strategic road network where necessary. The network has suffered under-investment for many years, with the result that levels of service have already declined in many areas. They must not be allowed to decline further.
Q.3 Does the proposed Circular signpost clearly the criteria that the Agency will use in evaluating planning proposals that affect the Strategic Road Network?
The criteria set out in paragraph 5.2 of the draft circular seem clear enough, although some other aspects of the evaluation process are rather vague. There is an over-reliance on travel plans and demand management to reduce the traffic generation from new (or existing) developments that may not realistically be achievable in practice. Consequently, there is a danger that additional traffic may be underestimated, leading to unforeseen capacity problems. (As a minor point of wording, the first sentence of paragraph 4.4 incorrectly refers to minimising trip generation, when it is apparent from the remainder of the paragraph that what is really meant is influencing the modal split, to minimise trips by vehicular traffic.)
Paragraph 5.5 states that, where insufficient capacity on the network would exist to provide for forecast demand, capacity enhancements may be agreed. This is not robust enough. If the capacity is calculated to be insufficient, either capacity enhancements must be agreed or the development refused planning permission.
Q.4 Do you agree with the approach to use of existing road capacity, and the provision of new capacity?
As indicated in response to previous questions, the ABD does not agree that existing capacity should be used where it would lead to a noticeable decline in the level of service to existing users of the strategic road network. New capacity should always be provided in such cases. Where it is calculated that traffic flows could be close to exceeding capacity by the end of the review period, any developments allowed should be designed so that future capacity enhancements are not precluded.
Q.5 Do you agree with relaxation of policy on new accesses to motorways and other strategic routes?
While paragraphs 5.5 to 5.7 of the draft circular appear to provide robust protection against the creation of new, direct accesses to motorways and motorway-standard roads, paragraph 5.8 then provides an exception, where new junctions may be identified as ‘essential’ for the delivery of strategic, planned growth. There needs to be much clearer guidance about the exceptional circumstances in which new, direct accesses may be permitted, to prevent this loophole being exploited inappropriately.
Paragraphs 5.10 and 5.11 refer to accesses to strategic roads that are not motorways or of motorway standard. It is these lower category strategic roads that are the most likely to be operating close to practical capacity and have higher casualty rates. The provision of new accesses is likely to have a significant impact on the level of service to existing road users, so should not be permitted unless additional improvements are made to mitigate any impact.
Q.6 Do you agree that it is appropriate to remove from the Circular minimum spacing criteria for roadside facilities, subject to junction separation standards, leaving consideration of such matters to planning authorities and commercial enterprise/opportunity?
While junction separation standards may give adequate protection against an excessively high frequency of roadside facilities on motorways and motorway standard roads, this may not be the case on single-carriageway routes. There may be particular safety concerns where facilities are provided on one side of the road only, if vehicular access from the other direction is permitted, requiring right turns in and out. The ABD would like to see a complete ban on new developments of any sort on single carriageway roads in the strategic network that have at-grade accesses allowing right turns in or out (unless at existing roundabouts).
Q.7 Do you agree with the removal of a restriction on retail space at motorway service areas, as a matter to be assessed and decided according to demand through the planning system?
The ABD can foresee problems with this relaxation. Paragraph B.10 of the draft circular states that the Highways Agency will only support proposals for new motorway service areas, or alterations within existing ones, if there is no overall increase in trip mileage on the motorway. If one MSA is allowed to increase its retail offer, however, it is likely to draw custom from other MSAs. These in turn would then want to restore their competitiveness by increasing their retail offer also, which might be difficult for the planning authority to refuse. The minimum outcome is likely to be that existing motorway users would visit successive MSAs to compare retail outlets, leading to more traffic leaving and rejoining the motorway. There is also a considerable risk that motorway traffic would increase overall, as the MSAs would become, in effect, a linear shopping centre.
The ABD considers that the retail space at motorway service areas should normally be limited to that needed by travellers in the course of their journeys, and should not be allowed to become destinations in their own right. There might be exceptional circumstances where an underused MSA could be redeveloped if sufficient capacity exists on the motorway (or could be provided), and if it allows congestion elsewhere on the strategic network to be relieved by relocating an existing traffic generator.
Q.8 Do you agree with the minimum requirements for signing of the various roadside facilities? What should be included or excluded?
The ABD agrees with the minimum requirements, as drafted, for roadside facilities to enable them to qualify for signing from the strategic road network.