A1237 Planning Response

York Cycle Campaign (YCC) response to 22/02020/FULM (improvements to the A1237 York Outer Ring Road from the A19 Shipton Road roundabout to the A1036 Little Hopgrove roundabout) (hereafter A1237 YORR)

Summary

YCC objects to this application and calls for it to be refused because the proposed scheme:

  • fails to meet the criteria for sustainable transport as laid out in the The National Planning Policy Framework;
  • fails to provide infrastructure for cyclists that is safe and in line with Department for Transport guidance;
  • fails to meet the scheme’s objectives including facilitating redistribution of through traffic from the city centre;
  • may jeopardise future funding for transport schemes in York.

Failure to meet the criteria for sustainable transport as laid out in The National Planning Policy Framework (NPPF)

The NPPF paragraph 2 states that “…The National Planning Policy Framework must be taken into account in preparing the development plan”. The NPPF states:

  • (paragraph 106) “Planning policies should:  … (d) provide for attractive and well-designed walking and cycling networks with supporting facilities such as secure cycle parking (drawing on Local Cycling and Walking Infrastructure Plans)”;
  • (paragraph 110) “In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that: (a) appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location”;
  • (paragraph 112, bold YCC’s emphasis) “applications for development should: (a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas;…(c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards”.

As will be set out in more detail below, this application fails to align with paragraph 106 (there is a failure to provide an attractive and well-designed cycling network), paragraph 110 (insufficient emphasis is placed on active travel), and paragraph 112 (there is a failure to give priority to cycle movements within the scheme and in neighbouring areas and a failure to minimise conflict between cyclists and vehicles). 

Failure to provide infrastructure for cyclists that is safe and in line with Department for Transport design guidance 

Given the nature of the A1237 YORR, the context for assessing the application’s provision for cyclists is the Government’s vision for active travel Gear Change and the associated Local Transport Note 1/20 (LTN 1/20) which provides guidance for local authorities on designing high-quality, safe cycle infrastructure. 

LTN1/20 includes the Cycling Level of Service (CLoS) and the Junction Assessment Tool (JAT) which are mechanisms introduced to set minimum quality criteria. Proposed schemes can be deemed to be LTN1/20 compliant (i.e. of an acceptable standard, suitable for funding) if they have a minimum score of 70% and no critical fails under the CLoS, and no red-scored turning movements under the JAT. 

Feedback from the applicant’s consultants

The application includes a report from consultants on the provision for cyclists in the proposed scheme (Existing and Proposed Cycle Facilities W50819-PEL-GEN-ZZ-RP-CH- 0005). 

In the consultants’ report:

  • The CLOS assessment (p7, 4.4) corresponded to the minimum acceptable overall score (but noting that this was based on a cycle route extending to Monks Cross – p6, 4.2) but included critical fails and multiple ‘red’ fails i.e. not LTN1/20 compliant;
  • The JAT assessment (p9, Table 5.1) gave the following results: Shipton 39%, Clifton Moor 72%, Wigginton Road 37%, Haxby Road 100%, Strensall Road 66%, Monks Cross 47%, Little Hopgrove 27%, including multiple red-scored turning movements, i.e. not LTN1/20 compliant.

The consultants concluded that there were benefits to cyclists from the proposed scheme but also acknowledged significant concerns, namely the poor provision at junctions and missing links:

“there are deficiencies (score of zero – red) that do need addressing – principally the

uncontrolled, at grade crossing movements at Wigginton Road and Monks Cross roundabouts and the link of high volume, high speed traffic between Monks Cross and Little Hopgrove” (p7, 4.4);

“The weaknesses in the proposed cycling provision are the roundabouts where underpasses will not provide for some or all the potential movements and destinations needed by cyclists. This is particularly the case at Wigginton Road roundabout” (p11, 7).

Some minor junction amendments appear to have been made in an attempt to address some of the issues raised by the consultants but in YCC’s opinion these changes are woefully inadequate. For example, it appears that two toucan crossings have been added in the light of the concerns about Wigginton Road. However, a staggered toucan for crossing the A1237 YORR is highly undesirable (e.g. conflict with pedestrians, issues for non-standard cycles/larger groups, and questionable safety given that it seems likely that many vehicles would exceed the 40 mph speed limit as this would only apply in the immediate vicinity of the roundabout).   

There is one junction that stands out as an exception to the otherwise poor provision: at Haxby Road an expansion of existing underpasses would ensure that all cycle movements through the junction could be completed with full separation from traffic. Even here though, there is a concern that the design assumes current levels of active travel as, if underpass usage were to rise, the reliance on shared paths could become problematic. Nevertheless, Haxby Road provides an example of what could and should be achieved across the proposed scheme

As noted above, the consultants identify missing links in the cycle route. They appear to have assumed, or recommended the introduction of, a cycle track between Strensall Road and Monks Cross (“This has been principally achieved through the proposed provision of cycle tracks parallel to every link except for the easternmost Monks Cross to Little Hopgrove roundabouts”  (p6, 4.2); “The use of the Fire Station access from Strensall Road through to the proposed farm access road should be secured to provide a bound surface cycle track between Strensall Road and Monks Cross roundabouts” (p6, 4.3); “Monks Cross roundabout … is to be served by a cycle track linking it to Strensall Road” (p11, 7)) which does not appear in the submitted drawings. The consultants’ concerns about the poor cycle provision between Monks Cross and Little Hopgrove also remain unresolved.  

YCC’s assessment of the scheme 

YCC recognises that there are some benefits for cyclists in the proposed scheme but these are more than off-set by the issues. 

YCC (amongst others) raised concerns about the proposed scheme’s provision for cyclists during the 2020 consultation phase, including specific concerns about the Clifton Moor, Wigginton Road, Strensall Road and Monks Cross junctions. It is extremely disappointing to note that the issues raised then have not been addressed.    

YCC has undertaken its own scoring of the proposed scheme’s junctions using the JAT and (with the exception Haxby Road) this resulted in significantly lower scores than that provided by the applicant’s consultants (even allowing for changes to junction design subsequent to the consultants’ report). YCC’s JAT scores were as follows: Shipton 20%, Clifton Moor 50% or 38% (depending on the treatment of ST14), Wigginton Road 45%, Haxby Road 100%, Strensall Road 28%, Monks Cross 8%, Little Hopgrove 0% i.e. all junctions apart from Haxby Road numerically failing and with multiple red-scored turning movements.

On the basis of the above, YCC contends that the applicant’s own consultants were too optimistic in their JAT scoring and the junctions would be less safe for cyclists than the consultants’ report indicated (even allowing for changes to junction design subsequent to the consultants’ report). The apparent loss of the proposed cycle track between Strensall Road and Monks Cross is another serious concern. YCC also contends that the consultants’ argument to justify the poor provision at the eastern end of the proposed scheme fails to make adequate allowance for future development in the area and the need for significant growth in active travel in York in line with local commitments and national directives.  

YCC conclusion regarding safety, compliance and utility

The applicant’s own consultants and YCC’s assessment demonstrate that the proposed scheme is not LTN1/20 compliant (for both CLoS and JAT) and fails to provide for the safety and utility of cyclists (and, in many cases, pedestrians and horse-riders). This is unacceptable, particularly given the scale of the scheme, the level of investment, and the stated objectives which include “improving active travel facilities for pedestrians and cyclists”. 

Required mitigation

If the proposed scheme were to be granted approval, it must be on the basis of setting stringent conditions to ensure significant improvements to the cycling infrastructure, with the aim of removing critical fails and fails under CLoS and red-scored turning movements under JAT. These conditions must include providing for a comprehensive upgrading of junctions to improve cycle safety – with underpasses as standard for crossing the A1237 YORR – and addressing the missing links (Strensall Road to Little Hopgrove) on the cycle route.

Potential to jeopardise future transport funding for schemes in York

Active Travel England (ATE) is the Government’s executive agency responsible for active travel. As part of its remit, ATE states that it will (p10 of the ATE framework document):

manage funding for dedicated walking and cycling initiatives and challenge failure by withholding funding for failure to meet standards. It will assess the compliance of schemes … that deliver active travel and prevent funding for schemes that do not meet DfT design guidance.

The proposed scheme is not LTN 1/20 compliant and therefore fails to meet ATE’s requirements, thus jeopardising future transport funding for schemes in York. 

Failure to meet the scheme’s own objectives, including facilitating redistribution of through-traffic from the city centre

The applicant (Environment Statement Vol. I, Chapter 2, 2.3.1) outlines a number of objectives for the proposed scheme including:

  •  “Improved safety on the YORR through provision of contemporary design and road layouts reducing accidents”; 
  • “Provision of active travel networks primarily through delivery of a new continuous cycle and pedestrian route around most of the ring road with safe connections by underpasses or controlled crossings”; 
  • “Removal of through traffic from York city centre due to the decongestion of the YORR, which will result in a reduction of traffic emissions and as such improving local air quality”;

Given the poor provision for cyclists (see above), it can be argued that the proposed scheme would fail to deliver on points 4.1.1 and 4.1.2. The proposed scheme would also fail to deliver on point 4.1.3, firstly because there is no proposal within this application to limit through traffic from the city centre, and secondly because the assumption that the improved A1237 YORR would be less congested is flawed. The modelling presented in support of the application (Environmental Statement Volume III, Appendix 17.2, Transport Assessment (Part 1) 7.4.9) claims that the improved A1237 YORR would not induce traffic. This claim is not credible as virtually every road improvement project has led to a significant increase in traffic due to induced demand, resulting in congestion at or beyond the original starting point. 

YCC is also concerned that the applicant has made it extremely difficult for members of the public and local organisations to engage effectively with this planning application. Many detailed, technical documents have been presented for scrutiny with only a very limited and skewed attempt to explain the proposals to a lay audience. Furthermore, a key document (Existing and Proposed Cycle Facilities) was submitted late to the planning portal. No attempt was made to engage with YCC during the detailed planning phase. 

Conclusion

YCC notes that the proposed scheme for the A1237 YORR:

  • fails to meet the criteria for sustainable transport as laid out in the The National Planning Policy Framework;
  • fails to provide junction infrastructure for cyclists that is safe and in line with Department for Transport design guidance;
  • fails to meet the scheme’s objectives, including facilitating redistribution of through traffic from the city centre;
  • may jeopardise future funding for transport schemes in York.

On this basis, YCC calls for the application to be refused. Instead of undertaking road improvements that would be rapidly lost to induced demand, the Council’s focus should be on providing an excellent active transport infrastructure that would be genuinely transformative: greatly improving life for residents (air quality, health and wellbeing, accessibility for all) and ensuring that the City’s commitment to net zero can be met.     

If the Council choses to approve the proposed scheme, it must be on the basis of stringent conditions to provide for a comprehensive upgrading of junctions to improve cycle safety – with underpasses as standard for crossing the A1237 YORR – and to address the missing links on the cycle route AND a commitment (with timeline and funding proposal) to introduce specific measures to reduce through traffic in the city centre. 

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